PAGENO="0001"
MOTOR VEHICLE INFORMATION AND COST SAYINGS
ACT OF 1972~-OVERSIGHT
~
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HEARIGS
BEFORE THE
SUBCOMMITTEE ON CONSUMER PROTECTION
AND FIN NCE
OF THE
COMMITTEE ON
INTERSTATE AND FOREIGN COMMERCE
HOUSE OF REPRESENTATIVES
NINETY-FIFTH CONGRESS
FIRST SE~SSION
ON
THE MOTOR VEHICLE INFORMATION AND
COST SAVINGS ACT OF 1972
MAY 2 AND 9, 1977
Serial No. 95-60
Printed for the use of the
Committee on Interstate and Foreign Commerce
[(~ERS LA'1V SCHIJOL L~$~
"~
~VERNMENT [)O1JN~EJ!T
U.S. GOVERNMENT PRINTING OFFICE
21-335 0 WASHINGTON: 1978
~ FEB ~8 ~978
~5'~-' (~O
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w
Additional material submitted for the record by-continued Page
Johnson Environmental and Energy Center, University of Alabama in
Huntsville, attachments to Dr. Schroer's prepared statement
Alabama motor vehicle diagnostic inspection demonstration project-
executive summary and final report 90
UAH report No. 195-Comparison of the accident rates of auto check
vehicles versus uninspected vehicles 102
UAH report No. 197-Evaluation of vehicle repair costs for auto check
participants 107
Transportation Department:
Automobile components and systems relating to safety and emissions. 179
Changes in auto operating costs per mile, 1972-76 8, 9
Comparative price changes: Auto maintenance and repair items,
1967-76 4, 5
Crash parts prices compared with new car prices and the cost of living,
1967-77 6, 7
Discussion of contract studies for title II 182
Norwegian 10 mph bumper system with charts 168
Raufoss-The 161m/h (10 mpr) no damage bumper system 174
Title 111-Motor vehicle diagnostic inspection demonstration projects 184
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MOTOR VEHICLE INFORMATION AND COST
SAVINGS ACT OF 1972-OVERSIGHT
MAY 6,1977
HOUSE OF REPRESENTATIVES,
SUBCOMMITTEE ON CONSUMER PROTECTION AND FINANCE,
COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE,
Washington, D.C.
The subcommittee met, pursuant to notice, at 2:15 p.m., in room
2123, Rayburn House Office Building, Honorable Bob Eckhardt,
chairman, presiding.
Mr. ECKHARDT. The Subcommittee on Consumer Protection and
Finance is opening hearings today on the Motor Vehicle Informa-
tion and Cost Savings Act of 1972. The National Highway Traffic
Safety Administration is charged as the agency to control the act.
It is the intention of this subcommittee to conduct a clear and
current overview of the existing base of consumer protection legisla-
tion. This is of the first importance to the committee.
We feel with respect to this act, that the basic act is a sound one,
but now 5 years have passed.
Much of the Motor Vehicle Information and Cost Savings Act of
1972 has not actually been put into effect, and excessive costs for
automobile repairs are even more onerous today than they were at
the time of the passage of the Act.
Except for the new car price and price of new tires, auto costs are
up more than the cost of living.
I have here several charts that~demonstrate these points [See p.4].
It will be noted here that gasoline is at the highest rate, total auto
operating costs per mile are somewhat lower. The Consumer Price
Index is considerably lower, and insurance costs, which reflect the
costs of auto repair, have shot up in 1975 to a figure that exceeds
the other costs except gas, oil and lube.
Title I of the act provides bumper standards to prevent damage to
the auto in low speed collisions. The existing bumper standard, a 5
mile-per-hour standard, only prohibits damage to safety compo-
nents. But the first standard under this act, aimed at preventive
monetary damage, has seen years of delay and will not be effective
until September of 1978.
Fender benders and other collisions requiring repairs have caused
unconscionably high repair bills and presently $3 billion a year is
expended in the crash parts industry wholly controlled by the
(1)
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2
automakers. That industry has now been under one antitrust inves-
tigation or another by the FTC since 1966, and nevertheless has
raised its prices more rapidly than any other automobile related
segment of the economy.
This second chart compares crash parts prices to the consumer
price index, and to new car prices, and you can immediately see
what is happening in that area.
As of January 1, 1977, the total increase in crash parts prices was
82.5 percent, and since 1967, it was 157 percent.
Of course, there has been some lag in the cost of insurance
occasioned by this increase in crash parts, but within 1 year, 1975 to
1976, insurance costs increased by almost 30 percent.
Title II of the act provided for a comprehensive study and
investigation of the methodology of determining comparative dam-
age susceptibility, ërashworthiness and ease of diagnosis and repair
of autos. It also provided for developing methodology for disseminat-
ing and assuring dissemination of information to consumers, and
finally for establishing procedures requiring dealers to distribute
information concerning relative costs of different makes and models
of automobiles.
There has been virtually no implementation of this section of the
act by the National Highway Traffic and Safety Administration.
Under title III, at least five diagnostic inspection demonstration
projects were to be started by January 1974. Safety and emission
standards compliance was to be studied through these projects
looking toward reduction of maintenance costs.
Senate hearings had estimated between $8 billion to $10 billion
per year was spent for unnecessary or unsatisfactory repairs. That
is about one-third of the total repair costs.
There has been some development and some informatioin gar-
nered by these five demonstration projects and we intend to hear
about the reports concerning these projects at this hearing, and also
to inquire to what extent the agency has utilized this information to
further develop the other provisions of the act. Since 1972, mainte-
nance repair costs have continued to rise more rapidly than the cost
of living, and more rapidly than any automobile-related prices
except those for crash parts.
As you will notice on the third chart, the highest of the curves
indicates repair costs, and on that curve are also the other auto
related costs for various items.
The BLS index of prices for auto repairs and maintenance, which
excludes body repairs, increased by more than 40 percent from 1972
to 1976, and by 89.7 for the longer period form 1967 to 1976.
There is a promising indication in DOT reports on the demonstra-
tion projects, provided to the subcommittee staff, that diagnostic
inspections have been able to reduce unnecessary repairs substan-
tially, while also increasing fuel economy through improved con-
sumer information about needed maintenance repairs.
In light of the vast recent increases in the cost to consumers both
of repairs and of all automobile operating expenses, the subcommit-
tee will be most interested in knowing of any such bright spot in the
overall national picture, even under experimental conditions. More
particularly, we look forward to an evaluation, by several of our
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.3
witnesses, of the potential of the diagnostic inspection concept for
obtaining any such consumer cost reductions on a larger scale.
The final title of the Motor Vehicle Information and Cost Savings
Act with which we will be concerned here is the prohibition of
odometer tampering. Some estimates of the consumer losses as a
result of this type of fraud imply annual costs to unwary buyers of
used cars in excess of $1 billion per year.
I have asked the Department :of Transportation for a status
report on this title, both with respect to defining the extent of the
illegal activities addressed and with respect to enforcement of the
title's provisions.
[The charts referred to were received for the record:]
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COMPARATIVE PRICE CHANGES:
AUTO MAINTENANCE AND REPAIR ITEMS, 1967-76
(19 67=100)
YEAR
CONSUMER,
PRICE
INDEXa
NEW CAR
PRICE
INDEXa
WHOLESALE
MOTOR VEHICLE
PARTSa
MAINTENANCE
REPAIRa
.
AUTO
INSURANCE
PREMIUMSa
STATE FARM
CRASH PARTS
PRICE INDEXb
1967
100.0
100.0
100.0
100.0
100.0
100.0
1968
`
104.2
`
102.7
105.1
102.9
-
102.3
107.1
1969
109.8
104.3
108.4
112.2
111.4
114.8
1970
116.3
107.4
112.9
120.6
126.7
117.0
1971
121.3
112.0
120.2
129.2
141.1
133.6
1972
125.3
111.0
126.0
135.1
140.5
140.9
1973
133.1
*
111.1
129.0
142.2
138.0
146.2
1974
147.7
117.5
143.8
-
156.8
138.1
174.1
1975
161.2
127.6
172.8
176.6
145.9
203.4
1976
170.5
135.7
182.7
189.7
187.9
235.3
a. SOURCE: Bureau of Labor Statistics.
Based on average `prices over the year.
b. SOURCE: State Farn Mutual Automobile Insurance Company,
State Farm Crash Parts Price Index and revisions
obtained from the State Farm off icd in
Bloomington, Illinois. Based on prices as of
July 1 each year.
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COMPARATIVE PRICE CHANGES:
AUTO MAINTENANCE AND REPAIR ITEMS, 1967-76
(19 67=100)
~ 240 C
E ~
L L
zac
180 ~ :
-~ ~ ~ CJi
~ t60
i40
.~oo
~9G7 * 19G8 l9~9 ~ ~i971. 1972. 1973 * ~L974- 1975 l97~
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6
CRASH PARTS PRICES
COMPARED WITH NEW CAR PRICES AND THE
COST OF LIVING, 1967-77
(1967=100)
* YEAR
CONSUMER
PRICE
INDEX a
NEW CAR
PRICES a
REVISED STATE
FARM CRASH PARTS
PRICE INDEXb
ALTERNATIVE
CRASH PARTS
INDEXC
1967
100.0
100.0
100.0
100.0
1968
104.2
102.7
107.1
107.1
1969
109.8
104.3
114.8
114.8
1970
116.3
107.4
117.0
117.0
1971
121.3
112.0
133.6
133.6
1972
125.3
111.0
140.9
140.9
1973
133.1
111.1
146.2
166.2
Jan. ,1974
Juiy,l974
147.7
.
117.5
151.5
151.5
174.1
-
Jan. ,1975
July,1975
161.2
~
127.6
193.0
*
189.2
203.4
-
Jan. ,1976
July,1976
170.5
135.7
229.3
215.4
235.3
-
Jan. ,1977
175.3
141.1
257.2
-
a. SOURCE: Bureau of Labor Statistics. Based on
average prices over the year, except
January, 1977.
b. SOURCE: State Farm Mutual Automobile Insurance Company,
State Farm Crash Parts Price Index and revisions
obtained from the State Farm office in
Bloomington, Illinois. Based on prices as of
July 1 each year through 1973.
c. SOURCE: Council on Wage and Price Stability, Press Release,
Feb.18,l976. This is the State Farm Index through
Jan.1974. However, the CWPS presented alternative
rates of change for Jan. ,l974-Jan. ,1975 and
Jan. ,l975-Jan. ,1976, citing an unnamed insurance
company sample of 7 crash parts for 6 current model
cars. Smaller samples used by other insurance com-
panies showed even smaller changes, according to the
CWPS release.
PAGENO="0009"
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PAGENO="0010"
8
CHANGES IN AUTO OPERATING COSTS PER MILE, 1972-76
[INTERMEDIATE CAR - 10 YEAR USAGE - 10,000 MILES PER YEAR]
Type of Cost
Per Mile
1972
1973
1974
1~75
1976
TOTAL (~)
l2.~
13.l'~
l5.9~
l7.7~
17.9~
Gas, Oil, Lube
-
3.5~
5.2~
5.5~
5~4c~
Maintenance
-
2.5
2.5
2.7
2.9
Depreciation
-
3.4
3.9
4.6
4.8
Insurance
-
2.2
2.3
2.4
3.1
Other
-
1.6
2.0
2.6
1.7
INDICES
(1972=100)
Total Cost
Per Mile
100.0
105.6
128.2
142.7
144.4
Gas, Oil, Lube
-
105.6
159.6
168.5
163.9
Maintenance
-
105.6
108.6
113.8
124.1
Depreciation
-
105.6
119.2
141.4
147.0
Insurance
-
105.6
111.0
116.3
151.3
Consumer
Price Index
100.0
106.2
117.9
128.7
136.1
SOURCE: Hertz Corporation.
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CHANGES IN AUTO OPERATING COSTS PER MILE, 1972-76
(IMTERMEDIATE CAR"- 10 YEAR USAGE - 10,000 MILES PER YEAR]
` (1972=100)
.171) E
160
16G
;i4o ~ ~ ~
` ~ ~ ~ cc
1 30 :rn
~- FEll
: - ~ J1Ei
; it FELl
~ . ~
:120 ` ~
: ~ ITI
` - ~ [Ill
~11o ~ ` ` ~ _ii
` I ~
` ` ` , TIIIEFITI
`100 197~ 1973 1974 1975
PAGENO="0012"
10
Our first witness this afternoon is Mr. Albert Benjamin Kelley,
who is Senior Vice President of the Insurance Institute for Highway
Safety.
Mr. Kelley, we are very glad to have you here. Will you identify
your associate and then you may proceed as you desire.
STATEMENT OF ALBERT BENJAMIN KELLEY, SENIOR VICE
PRESIDENT, INSURANCE INSTITUTE FOR HIGHWAY SAFETY,
ACCOMPANIED BY BRIAN O'NEILL, VICE PRESIDENT FOR RE-
SEARCH; PAUL TAYLOR, PRESIDENT, TAYCO DEVELOPMENTS,
INC. AND DOUGLAS TAYLOR, VICE PRESIDENT
Mr. KELLEY. Thank you, Mr. Chairman.
I am accompanied by Mr. Brian O'Neill, who is the Vice Presi-
dent for Research of the Insurance Institute for Highway Safety.
We are appearing today at the subcommittee's invitation to
present the results of recent Insurance Institute for Highway Safety
research bearing on the adequacy, or more precisely, serious
inadequacy, of present and prospective Federal standards to reduce
the damageability of cars in very low-speed crashes.
The motoring public has come to expect its cars routinely to
suffer hundreds and sometimes thousands of dollars in damage in
the most minor sorts of collisions; indeed, that expectation has
brought the term fender bender into the American language. Yet
most of the damage is needless; it could and should be designed out
of future cars, thus saving countless dollars otherwise spent on
repair parts and labor, and countless hours of wasted time while
cars are in the repair shop.
None of this comes as news, of course. During the past 8 years,
hearings held by this subcommittee and the full House Interstate
and Foreign Commerce Committee, two Senate committees, and the
United States Department of Transportation have developed volu-
minous records making clear that:
1. Technology for developing effective damage-preventing bumper
systems has long been available to car manufacturers, but still is
being widely withheld from their customers.
2. The cost of parts needed to repair cars after minor crashes,
parts whose damage-induced purchase also represents an inexcus-
able drain on shrinking natural resources, has soared in recent
years.
3. DOT's present standard-FMVSS 215-to prevent damage to
safety-related components of the car in very low-speed test
crashes-5 miles per hour front and rear into barrier and 3 miles
per hour corner impact with a test pendulum-has had insufficient
effect in reducing the damageability of cars made since the stan-
dard went into effect on September 1, 1972. Originally the compli-
ance test was even weaker; the rear-end test speed was only 2.5
miles per hour.
4. There is still not in effect a DOT standard, as mandated by title
I of the Motor Vehicle Information and Cost Savings Act of 1972, to
reduce property damage in front and rear low-speed crashes. After
repeated postponements at the request of auto manufacturers, DOT
in February 1976 finally announced that such a standard would
take effect in two stages, in the 1979 and 1980 model years.
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11
The first stage would require bumpers that prevent damage in
specified low-speed impacts, except damage to the bumper itself, one
of the so-called crash parts that is most costly for consumers to
replace. Some cars tested by us were meeting the first-stage require-
ments as long ago as 1975. The second stage would preclude virtu-
ally all damage, icluding to the bumper, in such impacts. At least
one manufacturer, Volvo, is certifying its cars as already meeting
the second-stage requirements.
The announced test procedures were no different than the ex-
tremely weak ones now applied for FMVSS 215, and the lead time
to the effective date of the second stage, if counted from passage of
the 1972 act, would total 7 years.
Most recently, DOT has again indicated the possibility of further
delay; it has issued a proposal to defer the second stage of its title I
standard for yet an additional year, that is, until the 1981 model
year. It did this at the request of two automobile manufacturers
who alleged in petitions that the 1979 model year effective date for
the second-stage requirements is only one year later than that of
the first-stage requirements, thus: providing what they called insuf-
ficient lead time. The petitions for yet another postponement were
written 4 years after passage of the 1972 act, with its clear intent of
reducing wasteful, avoidable property damage as spelled out in title
I.
With this testimony we are providing for inclusion in the record
on this hearing a copy of our response to DOT's present proposal
(Docket NOs. 74-11 and 73-19, Notices 13 and 10), to delay the
second-stage requirements until the 1981 model year.
Meanwhile, in the real world, new-car bumper designs reflecting
backward technology continue to flout the public-interest goal of
the 1972 act, which was to substantially reduce built-in low-speed
impact damage, the kind that does, but need not, occur in parking
lots, driveways and city streets all across the country, millions of
times a year, and thereby to ease the consequent economic burden
on consumers, insurers, and the Nation generally.
As I said a moment ago, FMVSS 215, the present safety low-speed
damage standard, did bring about some reductions in damage sus-
tained by cars that we have impact-tested since the standard took
effect in 1972. FMVSS is a performance standard, as would be a
DOT standard responsive to title I of the 1972 act; this means that
in meeting it, manufacturers may choose bumper designs of any
sort, including those that are unnecessarily heavy, costly to repair
and replace, and marginally effective, so long as they comply with
the standard's very modest impact test requirements.
As our past testimony to DOT and this subcommittee has shown,
FMVSS 215 has too often been met with bumpers that are in fact
needlessly heavy, needlessly expensive to repair and replace, and
needlessly ineffective in crashes that differ even slightly in type or
speed from those specified in DOT's weak comliance tests.
The public has been misled to believe that such bumper designs
are compelled by the Federal standard rather than by manufac-
turer decision, just as it was misled to believe that the unpopular
ignition interlock safety belt use system was developed and pushed
at Government initiative, when the truth was that the ignition
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12
interlock was developed and pushed by auto company interests,
over the objections and better judgment of the responsible Govern-
ment agency.
I note the comments in 1974 on the floor of the House of
Representatives by Chairman Moss of a companion subcommittee to
that effect.
"Mr. Moss. Mr. Chairman, I would like to make a correction in
the statement of my good friend, the gentleman from California,
Mr. Rousselot, who implied that this was some bureaucratic con-
spiracy which brought about the interlock. The interlock was
brought about ver the objections of the Department of Transporta-
tion as a result of the visit of the presidents of two of the major
manufacturers of automobiles with the President of the United
States, and at a subsequent meeting attended by Mr. John
Ehrlichman, Mr. Peter Flanagan, and another White House aide,
the order was issued to the Department of Transportation to go
along with the interlock rather than the alternative system which
the Department of Transportation had under study as an intermedi-
ate device. Now, Mr. Chairman, that is the fact." (The Honorable
John E. Moss of California, Congressioal Record - House, H8136,
August 12, 1974) Congress repealed the interlock standard in 1974.
For some years the Institute has been crash testing new cars to
determine their low-speed impact performance. Most recently we
looked at a number of 1977 model domestic and foreign cars in very
low-speed impact situations and found, to put it bluntly, a pattern
of designed-in damageability that mocks the spirit not only of the
1972 act's property damage reduction goals but also the human
protection goals of the National Traffic and Motor Vehicle Safety
Act of 1966.
Today we will show you, first, excerpts from films of our tests.
The complete damage results are attached as an appendix. As these
excerpts will show:
The present FMVSS 215 requirement has somewhat improved the
ability of new cars to resist override and damage in very low-speed
front-to-rear crashes, but much more improvement is needed and
possible.
In very minor corner impacts of the kind not covered by DOT's
compliance tests for FMVSS 215 and for its prospective title I
standard, current-model car designs invite substantial amounts of
needless damage.
The films will show the 1977 Chevrolet Impala, highly touted by
General Motors as more efficient in its use of this earth's space and
materials than full-sized cars of the past, is susceptible to damage of
a kind never before seen in our corner-impact crash test program.
Finally, in frontal crases as low as 10 miles per hour into a wall,
actually a test barrier, some new-car designs are permitting doors to
jam closed in the event of fire or other injury-threatening
emergency.
[Begin Film of 1977 Crash Tests:]
First, we are looking at the series of 1977 model cars in our low
speed crash tests [see p. 36]. We are looking at a sampling of those
tests because we have too many to show you all of them on film
today, and we are looking first at the front to rear tests with
PAGENO="0015"
13~
bumpers that meet the present so-called safety standards-FMVSS
215-of DOT.
While these bumpers are doing a somewhat better job than those
we had looked at prior to the Federal standards coming into being
in 1972, still as we see in this example, the 1977 Ford Pinto, much
needless damage is being generated by their design.
There we saw $353 worth of the damage between the two cars.
Even more costly damage resulted because of the design of the
Chevrolet Vega in this 10 mile an hour front to rear impact.
I stress that these cars do meet the minimum requirements of the
present safety standard in that they protect so-called safety related
components of the car in 5 mile an hour barrier tests and 3 mile an
hour corner impact pendulum tests. Yet they allow these many
hundreds of dollars worth of the cosmetic damage and in this case,
as we will see in a moment, the additional damage and inconve-
nience and perhaps hazard of being unable to open the trunk
following this very, very minor : impact. If one's flares and other
emergency equipment were in that trunk, the outcome is obvious.
One of the highest damage cars in the front to rear impact tests
series that we have performed this year was the newly designed
1977 Chevrolet Impala with $440 worth of damage to the two cars.
Here we see again to the bumper itself and to some of the
cosmetics, why that has happened.
Finally, the worst performer in this test and one that did manage
to produce override, even in this modest impact, with as you see
resulting damage to the impacting car-close to $600 worth of
waste-the 1977 Plymouth Gran Fury. Yet these cars do meet the
present Federal safety bumper standard.
In our 5 mile hour front into angle barrier tests, we will show you
now the five worst performers in the series, starting with the fifth
from the worst, and going on to the worst. We are looking first at
the 1977 Ford Granada, which in this very modest impact managed
to incur $256 worth of damage to itself.
Another Ford product, the Ford LTD, a larger car, was even more
with $318 worth of designed-in damage.
These cars, I repeat and stress, do pass the present Federal
standard.
Here, in just a 5 mile an hour corner impact, there had been
sufficient damage to make it very difficult to open the door.
Mr. ECKHARDT. In the last one, the bumper itself causes a great
deal of damage.
Mr. KELLEY. You are aboslutely correct, the bumper itself is an
agent of damage rather than: a protector of the car from damage.
Here it has done exactly as you describe, it has damaged the sheet
metal on the car because of its placement and because of the
insufficiency of the shock mount itself.
That is equally true of the 1977 Toyota Corolla, a small car, and
yet its repair bill was not small after its 5 mile an hour corner tap
into the wall, close to $400, and here is the worst of all of those cars
we tested in the 5 mile per hour corner series, the 1977 Datsun, this
model, the B210, with more: than $430 of damage and again, the
bumper itself was an agent of damage to the car and also a victim,
if you would, of damage because of its own design.
21-335 0 - 78 - 2
PAGENO="0016"
14
This is a 10 mile an hour front into angle barrier test, a series we
began last year, and it produced even larger amounts of damage-
and we are talking of damage now that gets up close to $1,000 per
impact, even at 10 miles an hour, the speed at which those of us
who are joggers jog routinely yet do not incur that kind of damage if
we are unfortunate enough to bump into a wall.
Here again a jammed door, and we begin seeing a pattern of
jammed doors, sealing the escape route for occupants in case of an
emergency such as fire or need for quick medical care.
The Datsun is doing very badly here, too, with more than $600
worth of damage and its completely destroyed cosmetic corner, with
the bumper again doing no good and a good deal of harm.
With the 1977 Ford LTD II, a larger car with close to $850 worth
of damage, the pattern becomes clear. A much smaller car, the 1977
Volkswagen Rabbit, yet an even greater amount of damage. We
have seen cars of all sizes in these worst performing entries in the
10 mile an hour angle barrier crash tests series.
The Rabbit, again, had a door that was jammed following this
crash, making escape, particularly for an injured person or fright-
ened person, very, very difficult. The worst performing of every car
we tested this year in this 10 mile an hour front into angle barrier
series was the 1977 Chevrolet Impala-the car General Motors
claims makes more efficient use of space and materials-with well
in excess of $900 worth of the cosmetic damage because its bumper
was so designed that it performed that way.
Another interesting thing and a frightening thing, frankly, hap-
pened in this test, and I would like you to watch very, very closely
now, not the front of the car where one would expect damage in
such a tap into a wall, but the roof of the 1977 Chevrolet Impala,
which is just now beginning to crumple. The damage has carried all
the way back to above the pillar of that car, and that is the design
that is now being offered to Americans as a new entry in the
markertplace.
Here is the 1977 Ford LTD, one of those that experienced door
jamming at 10 miles an hour front into barrier impact, where the
force is spread across the entire front of the care very modest
impact, and in the front impact alone we saw close to $700 worth of
damage.
Jammed doors have two results, as we will see in a moment, and
in this car both doors were jammed.
One result is that the occupant cannot get out without a great
deal of trying, and I was doing my best to get that door open, and
having, I must say, a terribly difficult time when I did it. The other
result is the cost of opening the door. Here, for the right front door,
it cost us close to $130 in addition to the $686 that already had been
incurred.
My colleague, Jane Bergler, attempted to get this door open and
could not get it open far enough to leave the car. We tried-we are
showing you just a glimpse of her very valiant efforts to get out-
and finally I had to go and help her by pulling the door open at the
great cost on this side of $164.30.
The jammed doors don't need to happen and the little clip of film
I am going to show you in just a moment will make that clear.
PAGENO="0017"
15
Mr. Chairman, something is terribly wrong with car designs so
flimsy they permit doors to jam in frontal impacts as low as 10
miles per hour, and in one case you saw 5 miles per hour. That such
designs are entirely unjustified is clear from this short sequence.
We would like to show you now-this was for air-bag testing, but
here is a byproduct I think you will: find relevant in connection with
the door jamming we saw just a moment ago-we are going to look
at a Volvo impacting a wall, in this case this is Volvo at 35 miles
per hour.
I urge that you not be too distracted by the mayhem that is going
on inside this car, which is not equipped with an air-bag. The
companion car was, and the dummies did very nicely. But I urge
you to look at the doors which in a moment we will open, just after
the crash.
That is the driver side, after a 35 mile an hour impact, and that is
the rear door. Those doors did not jam in a way, indeed, they did
not jam at all. They certainly did not prevent escape for the
occupants of those crashes.
As I point out, those are 1975 model cars, not 1977 model cars. In
that impact of a 1975 Volvo sedan at 35 miles per hour into a
barrier, those doors did not jam; we were able to open both of them
following the crash. Yet the doors on some new cars on the market
today cannot do as well even at :10 miles per hour, nor are they so
required by Federal safety standards.
There is no Federal standard now governing the opening of doors
in emergency situations under post crash circumstances.
As we showed you a moment ago, the new cars we tested are so
designed that they incur many hundreds of dollars worth of repair
requiring damage in bumps as low as 5 miles per hour corner-into-
barrier. Yet designs have been available for years to totally elimi-
nate such damage.
In 1971, in testimony before the Senate Antitrust and Monopoly
Subcommittee, the president of a leading manufacturer of shock
absorbing devices disclosed that his company was ready and willing
to produce and sell to auto manufacturers high performance, low
cost bumper mounts that would substantially exceed existing Fed-
eral compliance test requirements; 10 weeks ago, after analyzing
the results of our 5-mile per hour corner impacts of 1977 models, we
got in touch with that company, Tayco Developments, Inc., to ask
whether it could develop-using its long available technology-a
prototype bumper with the same general characteristics as a stan-
dard bumper, but with the ability to prevent damage to itself and
its car in such impacts.
The film you are about to see shows the result of that inquiry.
First you will see our 5-mile per hour corner impact of a 1977
Gremlin with its standard bumper. Then you will see another 1977
Gremlin in a 5-mile-per-hour corner impact test, this time equipped
with the bumper prototype developed by Tayco Developments, Inc.,
in less than 8 weeks.
Finally you will see the latter car in a front-into-barrier test that
substantially exceeds the present as well as prospective Federal
low-speed impact standards.:
May we have the final film, please?
PAGENO="0018"
16
After the title we will be looking at a 1977 Gremlin, in a 5-mile-
per-hour corner barrier impact, equipped with its own standard
bumper as it came when we purchased it from the dealer all our
test cars are purchased from dealers.
This car, which performed comparatively well-if you will recall
some of the dollar figures in our other tests, it was not much better
or worse than any other at its repair cost of a little less than $250
for the impact-was not untypical of the results in standard auto-
mobiles in 5 mile an hour impacts.
The damage was cosmetic, and also to the bumper itself. That is
the post crash car, you see the crinkling of the sheet metal and
crinkling of the bumper itself.
Now we will look at another Gremlin, an identical Gremlin, but
modified with the Tayco developments bumper. That is the Tayco
developments bumper, made at our request under very severe time
constraints, I must say, shortly after they were asked to do this
work.
You are seeing in this film Mr. Paul Taylor, who is the president
of the company and himself an engineer, in the foreground doing
the last of the installation of the bumper, and following this they
did some more bolting on of things.
Mr. ECKHARDT. Is that really all the time it takes?
Mr. KELLEY. No, sir; we are just looking at one of the sequences;
they did a great deal more than that. I was simply trying to give
you a look at the bumper itself.
Here is that bumper on that same car in a 5-mile-per-hour corner
impact such as one might get into with a low retaining wall in a
parking lot or wherever-not much of an impact, although it's $200
or $300 worth of damage on today's marketplace car-and here it
was no damage at all. Independent appraisers, incidentally, did the
appraising of the results of the test, and found no damage whatso-
ever in this impact not one penny's worth.
There is the post crash car compared to the standard Gremlin,
the Gremlin with the standard bumper, following the impact.
We wanted then to see and assure ourselves that the Tayco
bumper would perform as well in a front into barrier 5-mile-per-
hour test; but we decided to be just a little tougher on it than we
had been on marketplace cars, and so we upped the speed to 7 miles
an hour, which is considerably tougher in physics, incidentally,
than 5 miles per hour.
Again, we had no damage at all. I might point out that the
bumper you are seeing had previously been impacted on Mr.
Taylor's own car, the one that is at the hearing today outside the
hearing room. It had been put through other tests and so these were
not the first impacts it had withstood. It will do that over and over
again.
Paul and Douglas Taylor, whose company developed the proto-
type bumper shown in the film, are here and available to answer
questions about their work should you have any.
Mr. Chairman, the history of the 1972 act, as well as the DOT's
own interpretation of the act's purposes, makes clear that the
elimination of damage at such very low speed bumps as those
represented by DOT's compliance tests-5 miles an hour front and
PAGENO="0019"
17:
rear into barrier and 3 miles an hour pendulum into corner-was
seen as only the first in a series of standards-making steps that
ultimately would substantially reduce designed-in crash damage in
front and rear impacts at higher speeds and across a wide range of
crash types.
As of today, none of these steps has been taken, not even the first
one of putting in place a firm effective date for the title I standard
to eliminate damage in such compliance tests. So, the waste goes on.
Thank you.
[Mr. Kelley's prepared statement and appendixes follow:]
FOR RELEASE UPON DELIVERY -- EXPECTED 10:00 AM, FRIDAY 4/4/75
STATEMENT OF ALBERT BENJAMIN KELLEY
SENIOR VICE PRESIDENT
INSURANCE INSTITUTE FOR HIGHWAY SAFETY
BEFORE THE
NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
PUBLIC MEETING
DOCKET NO. 74-11, NOTICE 7; DOCKET NO. 73-19, NOTICE 6
BUMPER STANDARD
April 4, 1975
I sin appearing today to describe Insurance Institute for Highway
Safety research results that bear on NHTSA's proposed bumper standard
under Title I of the Motor Vehicle Information and Cost Savings Act
of 1972.
The Institute is an independent, nonprofit scientific and educational
organization dedicated to reducing the losses -- deaths, injuries and
property damage --resulting from crashes on the nation's highways. We
are supported, indirectly or directly, by insurance companies writing
the bulk of auto coverage in the United States. Since 1969 we have been
PAGENO="0020"
18
conducting collision testing and other research involving a wide range of
pre-crash, crash and post-crash factors that contribute to the huge
amounts of unnecessary death, injury and property loss on the nation's
highways.
Under Title I of the Motor Vehicle Information and Cost Savings
Act, the Department of Transportation is required to establish a bumper
standard that will reduce property damage in low-speed autonobile impacts.
The Act became law two and one half years ago. But even as of today,
no such standard yet has been introduced.
In the most recent in its two-year series of proposals for such
a standard, the National Highway Traffic Safety Administration suggests
that a Title I property damage requirement for new-car bumpers will take
effect no earlier than the 1977 model year, and possibly as far off in
the future as the 1979 model year.1 This contrasts with NHTSA's original
plan of an effective date of September 1, 1974, for a Title I
2
requirement -- a date that, of course, has long since passed.
The current NHTSA proposal would:
1. Combine the present Motor Vehicle Safety Standard No. 215, which
requires that new cars be able to withstand damage to their safety-related
components in very low-speed impacts, with the proposed requirements of the
Title I property-damage bumper standard. In planning to merge these two
requirements, the agency correctly recognizes that the technological ways
1 NHTSA Docket No. 74-11, Notice 7; Docket No. 73-19, Notice 6, 40 Federal
Register 11598, published March 12, 1975.
2 NHTSA Docket No. 73-19, Notice 1; 38 Federal Register 20899, published
August 3, 1973.
PAGENO="0021"
19
for protecting people and for protecting their property in lower-speed
crashes are not only compatible, but usually inseparable)
2. Establish, effective for the 1977 model year or later, a Title I
bumper standard that would permit costly, needless damage to the entire
bumper system under the specified impact tests. This represents a substantial
backsliding from the agency's August 3, 1973, proposal -- which was that
a barrier standard take effect for new cars of the 1975 model year and that
an additional pendulum test requirement take effect a year later.
That proposal allowed no safety or material damage of any kind, includi~g~
to bump~ers.
3. Establish, effective for the 1980 model year or later, a modified
Title I bumper standard permitting, under the standard's impact tests, no
damage to the car other than bumper face bar damage described as "no per-
manent deviation greater than three-eighths of an inch from its original contour."
In testimony on March 14 of this year, given at the request of the
Senate Commerce Committee, we characterized the current proposal as a
"technological anachronism." I am submitting a copy of that testimony
for your record in these hearings. As you ~ll see in a moment, the con-
clusion that the proposed, damage-permitting standard represents too
little protection, effective later than necessary, is bolstered by the
performance of new-car designs already available to consumers.
1 Statement of William Haddon, Jr. M.D., President, Insurance Institute
for Highway Safety, before the U.S. Senate Committee on the Judiciary,
Subcommittee on Antitrust and Morfopoly Legislation, March 17, 1970.
PAGENO="0022"
20
As we pointed out in our testimony to the Senate committee, the
NHTSA's "otherwise lucid notice of March 12," which contains the
current proposal, is devoid of "any rationale whatsoever for this
new plan to allow car designs that lead to costly destruction of bumper
systems in 5 mile per hour parking lot or garage-door taps, with all
of the consequent economic burden and bother."
It is understandable that the notice offers no justification for the
weakened proposal; there is no justification. Quite to the contrary, as
we told the Senate committee, the evidence is that "the state of auto
design art is, and has been for some time, easily able to meet the five
mile per hour barrier impact test requirements of the newly-proposed,
off-in-the-future standard."
This should come as no surprise, incidentally, to NMTSA. Some
twenty months ago the agency was aware, as a matter of record, that
its then-proposed bumper standard for 1975 model cars was already an
anachronism. According to a memorandum in its docket dated August 17, 1973
and signed by the director of NHTSA' s engineering systems staff, the agency
had learned from domestic and foreign "manufacturers' comments" that, "Most
1974 model vehicles will meet FMVSS 215 requirements and most of Title I
Bumper Standard NPRM Docket 73-19; 5/5 no damage barrier requirements." 1
(Emphasis added.)
We will look now at a set of 5 mile per hour front and rear barrier
crash tests of 1974 and 1975 model cars. These tests, shown at the
Senate Committee hearings, were part of the low-speed impact research program
conducted by the Institute since 1969; results of tests involving earlier
ESS Meetings with Big-4 and Foreign Manufacturers Concerning Providing
Implementation Costs and Consumer Damage Savings Impacts Concerning
Title I PL 92-513 Bumper Standard NPRM Docket 73-19. (Memo to The Racord
from Director, Engineering Systems Staff, NHTSA, dated August 17, 1913.)
PAGENO="0023"
21
model years have been made available to NHTSA in previous docket filings
by the Institute. The tests we are about to see are drawn from the larger
presentation of filmed crash test research results presented at your Feb-
ruary 18, 1975 hearing.1 (Test and repair cost estimate procedures for
these tests, together with repair cost estimates for all tests conducted
in the 1975-model car test series, are shown in our testimony of March 14
before the Senate Commerce Committee hearing, which is being made a part
of this hearing record.)
The tests we will see now are of bumper performance, on 1974 and 1975
model cars, that meets the 5 mile per hour barrier test not only of the
existing DOT safety bumper standard, but also of DOT's proposed "1977-
model-year-or-later," Title I property-damage standard, which permits
bumper damage.
(FILM BEGINS HERE)
1 Statement of William Haddon, Jr., M.D., President, Insurance Institute
for Highway Safety, at the National Highway Traffic Safety Administration
Public Meeting on a Proposed Bumper Standard, February 18, 1975.
PAGENO="0024"
22
FILM
Section I: 5 MPH Front Into Barrier
1974 Ford Pinto $4.00
1975 Ford LTD $4.50
1975 Ford Pinto $4.50
1975 Chevrolet Inipala $5.40
1974 Chevrolet Vega $70.40
Section II: 5 MPH Rear Into Barrier
1975 Chevrolet Impala so.oo
1975 Ford LTD $0.00
1975 Ford Pinto so.oo
1975 ANC Gremlin $0.00
1975 Datsun 610 1 $0.00
(lightweight bumper)
1"lightweight bumper" refers to systems weighing less
than four ~er cent of the vehicle's total curb weight.
PAGENO="0025"
23
FILM
Section III: 5 MPH Front, Rear Into Barrier
1974 Chevrolet Impala $0.00
1974 AMC Gremlin $0.00
1974 Datsun 610 $0.00
(lightweight bumper)
1975 ANC Gremlin : $4.50
1975 Datsun 610 1 $7.20
(lightweight bumper)
1975 Toyota Corolla 1 $26.70
(lightweight bumper)
1975 VW La Grande $122.45
(lightweight bumper)
1975 Chevrolet Vega $142.66
(END FILM HERE]
bumper" refers to systems weighing less
than four per cent of the vehicle's total curb weight.
PAGENO="0026"
24
In sum, these test results demonstrate that some current model cars
are so designed that they now meet the barrier test criterion of the proposed,
1977-or-later bumper standard, yet in some cases still sustain pocket-
picking, avoidable damage. The test results further demonstrate that some
current model cars can even meet the barrier test criterion of the 1980-or-
later standard, which forbids most bumper damage.
How well do the bumpers on these same cars perform when tested both
in pendulum and barrier impacts, as specified in the proposed Title I
property-damage bumper standard? Such information is an essential baseline
from which to develop bumper performance requirements that do more than
simply put NHTSA's belated stamp of approval on what already has been
substantially accomplished in the design of real-world, on-the-road auto-
mobiles.
To find out how currently-available new cars may perform under the
proposed, damage-permitting Title I bumper standard, the Institute completed,
literally hours ago, a series of pendulum and barrier impact tests on eight
1975-model automobiles -- eight of the same make and model as those shown
to the Senate hearing of March 14 and, earlier today, to this hearing. The
test procedure for each car, in the following order, was: left front corner
pendulum (high), left rear corner pendulum (high), right front corner
pendulum (low), right rear corner pendulum (low), front left offset
pendulum (low), rear left offset pendulum (low), front centerline pendulum
(high), rear centerline pendulum (high), front barrier and rear barrier. 1
The cars you will see tested, in order of appearance, are the 1975
La Grande, 1975 Toyota Corolla, 1975 Chevrolet Impala, 1975 Ford Pinto,
1 The test procedure is described in detail in Appendix A.
PAGENO="0027"
25
1975 Ford LTD, 1975 Datsun 610, and Chevrolet Vega. (Films of the 1975 AMC
Gremlin's test were processed too late for this hearing, but will be trans-
mitted to the docket later.)
(FIL~ BEGINS HERE),,:
Section IV
1975 VW LA GRANDS This La Grande is seen in each of
TOTAL ESTIMATED . the full range of pendulum and
REPAIR DAMAGE: $95.05
barrier tests -- the four corner
pendulum impacts, the four longitu-
dinal pendulum impacts and the two
barrier impacts. (In the interest
of time, we will show excerpts of
pendulum tests conducted on the other
vehicles.) The VW's front bumper
is so designed that the face bar
experienced no damage in the tests.
The dust cover from the front bumper's
right energy absorber fell off, but
was not damaged. The rear bumper,
seen here, was slightly dimpled.
Total estimated repair cost for this
bumper-only damage: $95.05
PAGENO="0028"
1975 TOYOTA COROLLA
TOTAL ESTIMATED
REPAIR DAMAGE: $108.48
26
The Toyota's estimated damage
repair cost of $108.48 was entirely
to the bumper system and components.
The front and rear bumpers required
realignment, and the rear bumper
face bar had to be replaced. Other
than to the bumper, no damage occurred.
1975 CHEVROLET IMPALA
TOTAL ESTIMATED
REPAIR DAMAGE: $195.55
1975 FORD PINTO
TOTAL ESTIMATED
REPAIR DAMAGE: $212.25
Bumper face bar dimpling accounted
for most of the Impala's repair cost
estimate of $195.55. Here, the
rear bumper filler panel is seen
after having been displaced in the
tests. It was repositioned, without
damage, literally by a flick of the
wrist.
The Pinto's non-bumper damage was
minor -- a paint scratch on the right
rear fender, repairable for $8.50.
Bumper damage, some of it seen here,
accounted for almost all of this car's
$212 in estimated repair cost.
PAGENO="0029"
1975 FORD LTD
TOTAL ESTIMATED
REPAIR DAMAGE: $222.70
1975 DATSUN 610
TOTAL ESTIMATED
REPAIR DAMAGE: $257.54
1975 CHEVROLET VEGA
TOTAL ESTIMATED
REPAIR DAMAGE: $371.38
(FILM ENDS HERE)
27
All of the LTD's estimated repair
cost of $222 involved damage to
bumper face bars and guards.
These dimples on the front and
rear bumpers tell much of the story.
Other than a tiny paint scratch,
the Datsun' s estimated damage cost
of $257 was entirely due to bumper-
related damage. Front and rear
bumper guards sprung their damage-
inviting chrome inlays.. .a dent in
the right rear bumper.. . and, the
$8.50 paint scratch on the left
front fender.
The Vega' s bumper bace bar deforma-
tion and energy absorber damage,
along with $125.15 in damage to the
front grill, trunk floor and other
non-bumper parts, added up to a
total of $371 in estimated damage.
PAGENO="0030"
28
Also included in our test series was the 1975 AMC Gremlin, films
of which are still being processed. The Gremlin's only non-bumper damage
was a scratch to its right rear fender, with an estimated repair cost of
$8.50. The remaining $234 of the Gremlin's damage was accounted for by
damage to the bumper face and reinforcement bars and to the bumper absorber
cover.
(A detailed report of each of the above tests will be submitted to the
docket, together with a print of the film shown here and film of the
Gremlin impact tests.)
A breakdown of damage in each of the tests described aboi.~e is shown in
Appendix B. Appendix C shows the estimated repair costs associated with
that damage, also on a car-by-car basis.
In Appendix C is shown the estimated damage repair cost, car by car,
resulting from bumper damage -- the kind permitted by NHTSA' s proposed
Title I property damage standard -- contrasted with that for non-
bumper damage. As the chart shows:
-- Nearly $200 in estimated repair costs per car, on average, resulted
from bumper damage of the sort that would continue to be allowed by the
proposed standard until the 1980 model year. The bumper damage ran from
a high of $249 for the Datsun to a low of $95 for the VW.
-- No itore than about $20 in estimated repair costs per car, on
average, involved non-bumper damage that would be prevented by the standard.
The non-bumper damage ran from a high of $125.15 for the Chevrolet Vega to
a low of zero dollars for four of the eight tested cars.1
1 (Without the Vega, with its exceptionally great acount of non-bumper
repair cost, the average would drop to less than $4 per car.)
PAGENO="0031"
29
In our tests, each vehicle was subjected to the full range of
pendulum and barrier impacts indicated in the proposed "1977-or-later"
standard. If the test results are an indication of the proposed standard's
contribution to low-speed crash protection -- protection for consumers,
that is, against needless, pocket-picking repair bills in minor impacts --
the proposal is worse than a technological: anachronism. It is a retreat
that would allow costly, avoidable bumper damage in very low-speed
impacts for another four model years. Even after that, the proposed
1980 model year version of the standard -- which might be a modest step
forward were it to take effect sooner -- will continue to permit some
bumper damage.
Turning to another issue raised at the Senate hearings of March 14:
Although the present safety bumper standard (FMVSS 215) has been accompanied
by some reduction in underride-override in our 10 mile per hour front to
rear impact tests, the problem continues, to crop up on cars that meet the
standard's criteria, with unfortunate and costly repair consequences for
the owners. The following film of Institute two-car crash test research
illustrates the point.
(FIlM BEGINS HERE)
Section V: 10 MPH Front to Rear Impacts Exhibiting Override-Underride
Characteristics
1974 Plymouth Fury III $325.89
1975 Ford Pinto $327.70
21-335 0 - 78 - 3
PAGENO="0032"
30
1975 Chevrolet Impala $339.49
1975 Plymouth Gran Fury $375.11
(FIU4 ENDS HERE)
In passing, as we noted at the Senate hearing, it is interesting
that a senior official of the company that manufactures the Plymouth sedans
that did so poorly in those impacts -- impacts between identical cars of
the same make -- told the recent NHTSA bumper standard hearing, To us,
the most important aspect of good bumpers has always been to make sure that
bumpers meet each other, and the new pendulum impacts brought in in 1974,
and in effect for 1975, ensure that bumpers are substantially the same
height. l That the pendulum impacts don't always ensure against override-
underride is evident from the film we have just seen.
CONCLUSION
As our tests indicate, existing cars already are substantially able
to meet the terms of NHTSA's proposed bumper standard that won't take effect
until 1977 at earliest. If the agency holds to its present timetable, the
public will not begin until the 1980 model year at earliest to realize
any of the additional bumper protection benefits envisioned by Title I when
the Congress passed it two and one half years ago. NHTSA's currently pro-
posed standard thus represents not an advance, but a retreat. The public
deserves better.
1 Statement of Sidney Terry, Chrysler Corporation, before the February 18
hearing, following testimony of William Haddon, Jr., M.D.
PAGENO="0033"
31
APPENDIX A
- Test Procedures
INTRODUCTION
The test vehicles were subjected to. low speed front and rear pen-
dulum and barrier impacts in accordance with the March 7, 1975 proposed
Part 581 Bumper Standard of Title I of the Motor Vehicle Information and
Cost Savings Act of 1972. The test requirements applied were those
proposed for passenger cars manufactured after August 31, 1976.
The vehicles were evaluated against the-present and future safety
and damage criteria of Part 581 Bumper Standard. Each vehicle was
examined by three damage appraisers following the test sequence,
and a damage estimate was prepared.
PROCUREMENT
New, ~l975 model year vehicles :were purchased from manufacturer
authorized retail dealers and transported to the test facility. No
vehicle had been driven more than 30 mi les.
TEST PROCEDURES
Detailed inspections were performed before and after the test
sequence on each vehicle including all items covered in the proposed
Part 581 Bumper Standard. Measurements of the bumper system were
made before and after the test sequence). Before and after each
impact, visual inspections of the bumper systems, and additional
PAGENO="0034"
32
contour measurements of the bumper were performed. Pre-test
preparation included draining gasoline from the fuel tank, dis-
connecting the fuel line at the fuel pump inlet, and installing a
small auxiliary fuel tank to the pump inlet. The vehicle fuel tank
was then filled with Stoddard fluid. Brakes were not, applied
during the impacts. The vehicle transmissions were in neutral.
For, the barrier impacts, the vehicle engine was idling.
TEST SEQUENCE AND SPECIFICATIONS
The test sequence, with specifications, was performed on each
vehicle in accordance with Table I.
DAMAGE APPRAISAL
Fol lowing the test sequence, each vehicle was examined by
a panel of three independent professional damage appraisers.
Cost-to-repair estimates were prepared using the current part
prices from Motor Crash Estimate Guide, and for imported auto-
mobiles, from authorized dealers, and a labor rate of $9.00 per
hour.
PAGENO="0035"
33
TABLE I
Impact Test
Number Type Location Height _______
Left front
corner*
Left rear
corner
3 Right front
corner
4 Right rear
corner
5 Front midway
between center-
line and left
corner : 16.1-16.2 in.
6 Pendulum Rear midway
between center-
line and left
corner
Front-center-
line
Rear center-
line
Front
10 Barrier Rear -- 4.8-4.95 mph
*Corner is specified as the corner location where plane A of the test
device forms an angle of 600 with a vertical longitudinal plane.
Pendulum
2 Pendulum
Pendu I um
Pendu I um
Pendu I um
19.9-20.0 in.
19.9-20.0 in.
16.1-16.2 in.
16.1-16.2 in.
Speed
2.8-2.95 mph
2.8-2.95 mph
2.8-2.95 mph
2.8-2.95 mph
4.8-4.95 mph
4.8-4.95 mph
4.8-4.95 mph
4.8-4.95 mph
4.8-4.95 mph
7 Pendulum
8 Pendulum
9 Barrier
16.1-16.2 in.
9.9-20.0 in.
19.9-20.0 in.
PAGENO="0036"
34
INSURANCE INSTITUTE FOR HIGHWAY SAFETY
PENDULUM AND BARRIER IMPACT TESTS
DESCRIPTION OF DAMAGE - 1975 MODELS
Rerneer System Damate
APPENDIX B
1 Under S5.3.Bof proposed amendment to 49 CFP ports 571, 581 dated Morch 7,1975, damage would be permitted "to the
bumper face bar and the components and fasteners that directly attach the bumper face bar to the chassis frame."
2 Includes items such as filler panels, etc.
Face Bar,
Attachment
Components
and Fasteners
Other2
Non-Bumper
Damago
VW LaGrande
Front Right front energy absorber
rear dust seal displaced
Rear Face bar dimpled
and misaligned
None
None
None
None
Front
Toyota Corolla
Rear
Face bar misaligned
Bumper guard deformed
~
Face bar deformed
and misaligned
Bumper guards deformed
None
None
~
None
None
None
Chevrolet Impala
Front
-~
Rear
Face bar dimpled
~
Face bar dimpled
Filler panel displaced
. .
Filler panel displaced
and scratched
None
*
Ford Pinto
Front
Rear
Face bar deformed
and misaligned
License bracket deformed
Face bar deformed
and misaligned
Filler panel displaced
None
None
Right fender scratched
FordLTD
Front
-~
Rear
Face bar dimpled
and misaligned
Bumper guard deformed
~-~-
Filler panel displaced
-
None
-
Face bar deformed
and misaligned
BumperguarddefOrrned
None
None
-
AMC Gremlin
Front
Rear
Face bar deformed and
misaligned, loose absorber
cover, rear
Face bar deformed
and misaligned
None
~
None
None
Right fender scratched
Datsun 610
.
Front
Rear
Face bar deformed
and misaligned
Bumper guard deformed
Face bar deformed
and misaligned
Bumper guard deformed
None
None
Left fender scratched
None
Chevrolet Vega
Front
Rear
Face bar deformed
and scratched
Back bar deformed
License bracket deformed
Face bar deformed
and scratched
Energy absorbers deformed
Filler panel damaged
None
Frame deformed
Grille deformed
Right fender scratched
Trunk floor deformed
Right fender scratched
IIHS, April 1975
PAGENO="0037"
35
Bumper System Damage
Face Bar,
Attachment
Components
and Fasteners1 Other2
1 Under S5.3.8of proposed amendment to 49 CFP p&ts 571, 581 dated March 7, 1975, damage would be perrnitted "to the
bumper face bar and the components and fasteners that directly attach the bumper face bar to the chassis frame."
2 Includes items such as filler panels, etc.
3 Minor repositioning that could be accomplished by damage estimator daring appraisal.
IIHS, April 1975
INSURANCE INSTITUTE FOR HIGHWAY SAFETY
PENDULUM AND BARRIER IMPACT TESTS
REPAIR RESIMATES - 1975 MODELS
APPENDIX C
Non-Bumper
Damage Total
VW LaGrande
Front
Rear
$ 2.70
92.35
0
0
0
0
$ 2.70
92.35
Combined
95.05
95.05
Toyota Corolla
Front
Rear
21.65
86.83
-
0
0
0
0
~-
21.65
86.83
Combined
108.48
108.48
Chevrolet Impala
Front
Rear
-~-~
93.10
102.45
~
NC.3
NC.3
---
0
0
93.10
102.45
Combined
195.55
195.55
Ford Pinto
Front
Rear
~
Combined
105.60
98.15
NC.3
0
0
8.50
~
105.60
106.65
203.75
8.50
212.25
Ford LTD
.
Front
Rear
103.90
118.80
~-.
NC.3
0
~
0
0
~_
103.90
118.80
Combined
222.70
222.70
AMC Gremlin
Front
Rear
~
110.23
123.99
0
0
-
0
8.50
- -- -
110.23
132.49
Combined
234.22
8.50
242.72
Datsun 610
Front 123.50
Rear 125.54
NC.3
0
8.50
0
132.00
125.54
Combined
249.04
8.50
257.54
Chevrolet Vega
Front
Rear
104.05
127.40
14.78
0
~
75.05
50.10
193.88
177.50
Combined
231.45
14.78
125.15
371.38
Average
Front :
Rear
83.09
109.44
~
1.85
0
10.44
8.39
95.38
117.83
Combined
192.53
1.85
18.83
213.21
PAGENO="0038"
36
10 MPH Front into Rear Tests
1977 Ford Pinto
1977 Chevrolet Vega
1977 Chevrolet Impala
1977 Plymouth Gran Fury
10 MPH Front into Angle Barrier Tests
1977 Ford LTD
1977
1977
1977
1977
Datsun B2l0
Ford LTD II
VW Rabbit
Chevrolet Impala
$256.85
$318.45
$359.40
$386.55
$436.86
$804.71
$823.58
$844.25
$848.16
$928.00
Jammed Doors: 1977 Ford LTD 10 MPH
Front into
$686.30
$128.40
$164.30
Barrier Tests
(front-end damage)
(passenger door)
(driver side door)
Low Speed Crash Tests: 1977 Model Cars
$353.05
(both
cars)
$427.45
(both
cars)
$440.70
(both
cars)
$594.21
(both
cars)
5 MPH Front into Angle Barrier Tests
1977 Ford Granada
1977 Ford LTD
1977 Plymouth Gram Fury
1977 Toyota Corolla
1977 Datsun B2l0
PAGENO="0039"
a***a*a***aa******a***a***aa***a3~,*,*a******** a************a*a*a**a*a****a*aaa*a*a*a****a*****a******a***a***
TEST PROGRAM 1977 MAY 3, 1977
ESTIMATED COST TO REPAIR S * iui~
05MPH 10 MPH
FRONT TO FRONT TO
ANGLE BARRIER ANGLE BARRIER
10 MPH
FRONT TO
BARRIER FRONT
359.140
318.145
237.30
97.70
219.30
233.70
256.85
222.06
122.140
252.15
236.20
176.55
109.71
1436.86
386.55
223.50
720.76
804.71
928.00
726.80
844.25
668.50
659.55
518.35
791.93
576.60
675.76
552.45
848.16
823.58
720.31
457.70
445.58. 148.63
16.40 260.10
163.00 277.70
115.90 238.45
212.60 135.75
139.40-128.60
137.60 179.95
101.86 137.76
170.50 256.95
205.55 147.50
98.45 97.35
95.05 95.05
61.26 54.65
72.12 72.15
41.20 89.95
2.20 2.20
129.92 145.17
594 .21
276.50
440.70
354.35
348.35 C.A~
268.00
317.55
239.62
1427.145
353.05
195.80
190.10
115.91
1144.27
131.15
4.40
PRICES AS OF 1976
LABOR RATE $ 11.00
SUBLET RATE $ 14.00
a a a a a * a a a a a a * a aa a wa a a a a a a a a ** a a * a * * a a *a * a a a a a a a a a * a a a a a * a * a a a * a * a a a a aa a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a
10 MPH
TO REAR
BOTH
1977 PLYMOUTH GRAN FURY
1977 FORD LTD
1977 CHEVROLET IMPALA
1977 CHEVROLET CHEVELLE
1977 FORD LTD II
1977 CHEVROLET NOVA
1977 FORD GRANADA
1977 PLYMOUTH VOLARE
1977 CHEVROLET VEGA
1977 FORD PINTO
1977 AMC GREMLIN
1977 CHEVROLET CHEVETTE
1977 VW RABBIT
1977 DATSUN B210
1977 TOYOTA COROLLA
1976 HONDA CIVIC CVCC
AVERAGE
1438.50
686.30
5144.35
396.70
5140.30
521.23
2143.014 707.311
275.09
PAGENO="0040"
38
L1i5a~! c~.ttL.l~ *i;,e ~
FOR RELEASE ON DELIVERY CONTACT: LYNNE SMITH
ESTIMATED 2 P.M. EDT, MAY 6, 1977 PHONE: 202/333-0770
New-Car Bumpers Flout Intent
Of `72 Law, HHS Tests Show
Despite passage of a law five years ago to bring about more damage-resistant bumpers on new cars,
1977 model cars still have been designed so that they incur many hundreds of dollars worth of damage in
corner bumps as low as five miles per hour, the Insurance Institute for Highway Safety told a House hearing
today.
Testifying before the Subcommittee on Consumer Protection and Finance, the Institute presented
the filmed results of its latest low-speed impact tests of current-model domestic and foreign cars, showing
that:
o The present federal "safety" bumper standard "has somewhat improved the ability of new cars
to resist override and damage in very low-speed front-to-rear crashes - but much more improvement is
needed."
o "In very minor corner impacts [not now covered by the federal standard[, current-model car
designs invite substantial amounts of needless damage."
o The 1977 Chevrolet Impala, claimed by General Motors to have a "more efficient" design, "is
susceptible to damage of a kind never before seen" in the Institute's comer-impact crash test program.
o "In frontal crashes as low as 10 miles per hour into a wall, some new-car designs are permitting
doors to jam closed." sealing occupants in the car and cutting off rapid escape in the event of fire or other
emergency.
Benjamin Kelley, senior vice president of the Institute, told the subcommittee that "the technology
for developing effective damage-preventing bumper systems has long been available to car manufacturers,"
but most are still'withholding such improvements from their customers. He said that since passage of the
Motor Vehicle Information and Cost Savings Act in 1972 - which contemplated what the chairman of the
subcommittee has called "immediate" low-speed bumper protection - the auto companies have been able
to stall federal deadlines for such systems until the 1980 model year.
Kelley noted that tlse Department of Transportation has now proposed, at the request of two car
makers, yet anotlser delay of the standard's effective date, to the 1981 model year.
TIse Institute also showed crash test film of a bumper designed by Tayco Developments, Inc., using
long-available technology, that was able to prevent all damage to itself and the vehicle, not only in five
miles per hour comer impacl tests but also in seven miles per hour front-into-ban-icr tests conducted by the
Institute.
A car equipped wilh the new bumper was available for viewing during and after the hearing.
(The full text of Kelley's statement is attached. Film of the IIHS crash tests is available from Lynne
Smith at the hearing or at IIHS offices, Suite 300, Watergate Six Hundred, Washington, D.C. 20037,
202/333-0770.)
The Insunanco Institute ton Highecay safety is an independent, nonpnof~t, scientific and educational onganization. it is dedicated to ~educing the
losses-deaths, injunies and p,ope,ty damage-nesulting t,om cnashes on the nation's highacays. The Institute is suppo,ted by the A,ee,ican
losu,ance Highetay Safety Association, the National Association of Automctice P.lctual Insunance Companies, the National Association of
Independent I nsute~s safety Association and seuenal indicidual in scnancec ómpanies.
PAGENO="0041"
39
Mr. ECKHARDT. That last photograph there was an angle crash,
too, wasn't it?
Mr. KELLEY. Mr. Chairman, the very final of those sequences was
a front end to barrier flat crash.
Mr. EcKHARDT. How about the one before that?
Mr. KELLEY. That was an angle crash.
Mr. ECHKHARDT. That was at 5 miles per hour?
Mr. KELLEY. Yes, the last one was 7 miles an hour front end to
flat barrier, and the second was 5 miles an hour front into corner
barrier.
Mr. ECKHARDT. I recall when we had this bill up originally; it had
been sent back to the subcommittee by the full committee, and I
just wanted to demonstrate that some of the statements about the
extra costs and weight were not true. We ultimately did get it out f
the subcommitte and passed.
That was some 5 years ago, and at the time we had a bulldozer
out here in the front of the building, and we drove an ordinarily
equipped Saab automobile into the bulldozer, in a flat impact, with
no damage. I suppose that probably wouldn't have taken an angle
blow, that bumper on a Saab at :that time at that speed, would it?
Mr. KELLEY. We have not tested a Saab so I hesitate to speculate.
Mr. EcKHARDT. That was the standard bumper at the time.
Mr. KELLEY. I understand, yes, sir. I hesitate to speculate on how
it would have performed in a 5-mile an hour corner barrier impact,
but I must tell you that not one car we have tested, whether foreign
or domestic has performed without damage in that 5-mile an hour
corner barrier impact test. As I said in my testimony, Volvo' has
been certifying that it at least meets all of the current Federal
compliance tests, which include: the 5-mile an hour flat barrier and
3-mile an hour corner swinging pendulum, with absolutely no
damage of any kind, not only safety but no economic damage as
well.
Mr. EcKHARDT. The existing : corner standard is only 3 miles an
hour?
Mr. KELLEY. That is correct yes, sir, and it is not with a barrier, it
is with a rather strangely shaped pendulum that is intended to
minimize the possibility of override and underride. But as you saw
in the impact front to rear of the Plymouth car, the Chrysler
product, it does not sufficiently minimize it, and we are still getting
underride and override.
Mr~ EcKHARDT. I think we will now take a brief recess and see the
demonstration car, and meet back here immediately afterwards for
questions.
[Brief recess.]
Mr. ECKHARDT. The subcommittee will be back in session.
During the period of time we were looking at the demonstration
bumper, I was asked by one of the members of the media if we were
going to ask the automakers ,~` why they were not utilizing the best
technology to reduce repair costs?
We have notified the automakers and asked them if they would
appear, or if they desired to appear, and it is my understanding that
`all have declined to appear.:
A little further statement On that point will be made later, but I
thought it only fair to let it be known on the record that that is my
PAGENO="0042"
40
understanding of the situation at this time. If I am incorrect in that
understanding, I am sure there will be sufficient time to correct it
before the end of these hearings.
Mr. Kelley, you stated that you tested cars in 1975 and found that
some already met the phase 1 bumper standard requiring no dam-
age to the automobile itself in a 5-mile per hour front and rear, 3-
mile per hour corner bumps.
What percentage of the market did the complying cars represent
at that time?
Mr. KELLEY. Mr. Chairman, our tests were run on a relatively
small sample of cars in a relatively short period of time when the
Department of Transportation was considering a proposed standard
under title I. I would be reluctant to state it in terms of share of the
market because I don't think our sample size was sufficient, but my
recollection is that a number of the cars that we tested did manage
to go through the 5-mile an hour barrier test and the 3-mile an hour
corner impact pendulum test with absolutely no damage, and we
would be happy to submit the list of cars to you for the record.
My recollection is about half of what we tested, and I think we
tested seven or eight cars that did that.
Mr. ECKHARDT. Without objection, the record will be held open for
such information [See p. 22].
Have you had any experience this year?
Mr. KELLEY. We did not this year run the 5-mile per hour front
into barrier test series because we have found since the application
of the so-called safety bumper standard, Federal Motor Vehicle
Safety Standard 215, that new cars are doing generally much better
in that test series. Manufacturers are of course certifying compli-
ance with that standard, as they must under the law in order to sell
cars in this country, and so we felt that it was not necessary and
somewhat superfluous for us to continue that test series, and we
have turned our resources to the corner tests that you have seen.
Mr. ECKHARDT. If the technology is widely available, why has
NHTSA not required anyone to meet the standard earlier?
Mr. KELLEY. Mr. Chairman, I can't answer on behalf of the
National Highway Traffic Safety Administration, but as an outsider
looking at that agency, I have been saddened and puzzled by the
pattern of delay, of foot-dragging, of refusal to implement the
standard required by title I and strengthen the compliance test
requirements of Federal Motor Vehicle Safety Standard 215. I can
think of no legitimate excuse for the amount of delay that has
taken place.
Mr. ECKHARDT. What arguments did the automakers make, if you
know?
Mr. KELLEY. My recollection of the auto manufacturers' argu-
ments is that they have argued, as they have time after time in
safety standard proposal after safety standard proposal, that they
needed many, many years of lead time to apply the most basic kinds
of modern technology to their cars. They have said that in meeting
performance standards, they would-and as a matter of discretion
unhappily they can-choose designs that were needlessly costly,
that were needlessly heavy that were needlessly inefficient, and
PAGENO="0043"
41
they have said that their customers did not want these kinds of
improvements.
I hesitate to attempt to paraphrase the automobile industry's
arguments because frankly I do not understand them at all.
Mr. ECKHARDT. It puzzles me too. I remember many, many years
ago my family had, I think, a 1917 Franklin automobile, and I
remember that even that early model had a rather rudimentary
shock absorbing mechanism-a curved bar that could bend, and it
stood out about 8 inches, I suppose, from the front of the car.
Well, from 1917 to within a few years ago, they managed to
regress to the point where a bumper was virtually a piece of
chromium plate on the frame of the car, so there certainly has not
been any advancement toward efficient bumpers, or there was not,
until the government began to take an interest in it. At least that
has been my experience.
I don't know, does yours in any way vary with respect to that
point?
Mr. KELLEY. I am afraid mine: is precisely as you have described
it, and the institute's precisely as you have described it, Mr.
Chairman, and I find the NHTSA's failure to act even more
puzzling, in light of the fact that within its own files and its own
research films and results from test work done in connection with
its research safety vehicle program, it has clear evidence of the
ability to manufacture and design cars that can withstand impacts
up to 7, 8 and 9 miles an hour front end into barriers, corner and
head on, with no damage whatsoever. These are a matter of record
within NHTSA, and I would hope that the agency will make that
material available to the subcommittee.
Mr. ECKHARDT. One of the reasons for these oversight hearings is
this: You know Congress is frequently charged with having done
nonproductive things. At the time we passed this bill in 1972, we
said that it would result in saving a billion or so dollars in
automobile repairs. Of course the bill has not had that effect
because it has not been implemented, and that is precisely the
reason why we want to see why it wasn't implemented. In that
period of time a very, very substantial amount of money has been,
in my opinion, expended unnecessarily by the automobile-owning
public.
Mr. KELLEY. My own observation, Mr. Chairman, not supported
necessarily by statistics, but at least by personal experience, is that
many, many people in this country think and have been led to
believe that there already is in effect a Federal property damage
bumper standard required by Congress, and that because of that
standard, the public is being given inefficient, heavy, costly to buy,
costly to repair, costly to replace bumpers. Somehow the notion has
gotten abroad to the public and I know of no move by auto
manufacturers to stop this notion, that it is the fault of law and the
government that manufacturers are providing these atrocious
bumpers, rather than the fault of manufacturers' design discretion.
Mr. ECKHARDT. As I recall it, about 1971 or 1972 the automakers
were making precisely that argument, that there would be a sub-
stantial weight penalty as a result of any standard of the nature
that we were then describing, and they even carried it so far as to
PAGENO="0044"
42
talk about a lesser fuel efficiency, which seemed to me to be utterly
ridiculous.
Mr. KELLEY. Yet the fact of the matter is that today, while for
some cars there is a substantial weight penalty, there is no stan-
dard yet that requires any improvement in bumpers, and so that is
purely a matter of manufacturer discretion.
Mr. ECKHARDT. Are there some manufacturers who could not
meet such standard without severe economic harm or loss of com-
petitive position?
Mr. KELLEY. Not to my knowledge, Mr. Chairman.
Mr. ECKHARDT. Do any of the manufacturers beside Volvo survive
a higher speed crashes without damage to the car?
Mr. KELLEY. We do not from our own testing experience know the
answer to that question. I would hope that any manufacturer who
could meet a higher standard would proclaim it loudly to the
marketplace so that its customers would know and additional
customers would come to purchase its automobile.
Mr. ECKHARDT. It would appear to be a very effective
advertisement.
Mr. KELLEY. I would think so, yes, sir.
Mr. ECKHARDT. Would a high speed standard be feasible now in
your opinion?
Mr. KELLEY. Yes, and has been feasible for some years.
Mr. ECKHARDT. What speeds do you think would be technologi-
cally feasible?
Mr. KELLEY. Based on our understanding of the technology, and
the technology as it existed as long ago as 1969 and 1970, and as it
was discussed in great detail before the Senate Commerce Commit-
tee and the Senate Antitrust and Monopoly Subcommittee at that
time, there is no excuse, none whatsoever, for designs that permit
any appreciable amount of damage in impacts up to 10 miles an
hour front and front angle, rear and rear angle, or permit any
damage whatsoever in the sorts of 10-mile an hour front-to-rear
impacts that we saw at the outset of our film today, not to speak of
designs that permit underride and override.
Mr. ECKHARDT. You state that Volvo already meets the phase 2
requirements of no damage to the car or to the bumper.
Mr. KELLEY. They have so stated, yes, sir.
Mr. ECKHARDT. At 5 miles per hour.
Mr. KELLEY. And 3 miles an hour.
Mr. ECKHARDT. 5 miles per hour.
No, front and rear, and 3 miles per hour corner.
Mr. KELLEY. Yes, sir.
Mr. ECKHARDT. Once you have met phase 1, how hard is it to meet
phase 2?
Mr. KELLEY. At least in Volvo's case, I gather that they decided
not to waste time or their customers' money meeting phase 1 and
instead decided to go immediately to phase 2, and my personal
opinion is that any cost-conscious manufacturer would make ex-
actly that same decision. There is no reason to bother with meeting
phase 1.
Mr. ECKHARDT. What arguments were advanced in the manufac-
turers' petitions to NHTSA for the delay in phase 2?
PAGENO="0045"
43
Mr. KELLEY. Essentially the argument, as I understand it as
presented by General Motors and Ford Motor Company, the two
petitioners on that issue, the argument was that the 1-year space
between the application of phase 1 and the application of phase 2
would not provide enough lead tithe, and would present too tight, a
time frame within which they would have to move from one phase
to another, and that therefore there should be at least a space of 2
years between those two phases.
Mr. ECKHARDT. Are there other manufacturers beside Volvo who
meet phase 2 that you know of today?
Mr. KELLEY. Not that we know of, Mr. Chairman, but that does
not mean that they are not out there.
Mr. ECKHARDT. You filed comments to the notice of proposed
rulemaking to delay the phase 2, deadline.
Did you petition for or were you interested in having the depart-
ment conduct a hearing on that question?
Mr.KELLEY. We filed comments with the department on its notice
of proposed rulemaking for delay of the phase 2 deadline. We are
now waiting for action on that notice of proposed rulemaking. We
have urged the department very, very strongly on the record not to
grant those petitions.
Mr. ECKHARDT. It is my understanding that they are required to
hold a hearing under those circumstances.
Have they indicated to you their position with respect to the
statutory requirement?
Mr. KELLEY. No, sir, they have not.
Mr. ECKHARDT. You stated that there was some reduction in
damage sustained by cars as a result of the present standard 215.
Did that result in a decrease in insurance or an increase at a
lesser rate than it would have otherwise increased?
Mr. KELLEY. Mr. Chairman, I am not competent to answer that
question. The institute's work, which is entirely funded by auto
casualty insurance companies, does not in any way get into analyses
or contact with insurance pricing matters. I would hope if you do
have insurance companies or trade association witnesses they would
be able to answer that.
Mr. ECKHARDT. Thank you.
In what ways are the DOT áompliance tests weak in your opin-
ion? I think you have already indicated that the pendulum test is
such as to give the most leeway for override.
Mr. KELLEY. If I may answer the question empirically, the DOT
compliance test, both for the present safety standard and the
identical test for the proposed no property damage bumper stan-
dard, will continue to permit the sorts of damage that we saw in the
films today, in the 5-mile per hour corner barrier impacts, and in
the override-underride situatiOns. Those will not be precluded by
those tests, and so we feel that those tests are not sufficient to take
into account enough real world damage situations to do the con-
sumer as much good as modern technology allows.
Mr. ECKHARDT. You know it has always puzzled me that, in a
time of high level technology, there is something as primitive as the
swinging of a pendulum. It, would seem to me that some very
sophisticated tests could be devised that might be quite different
PAGENO="0046"
44
from a mere mechanical impact and that would rather precisely
determine possible damage from blows in many different ways. I am
not an engineer, but it would seem to me that electronic analysis
would be better than a single blow from a single mechanical object.
Could you comment on that?
Mr. KELLEY. In general, Mr. Chairman, I am absolutely sure that
you are right, that modern testing technology could come up with
much more productive and much more revealing tests for the
adequacy of bumpers. I would say, as Mr. O'Neill has just reminded
me, that the pendulum test is in part due to the face of the
pendulum being designed to somewhat standardize the heights of
bumpers, and as I think I mentioned a few moments ago, its intent
is the proper one of minimizing override and underride. Unfortu-
nately, as we have seen, it does not accomplish that intent, but
coming back to your question and your comment, I think you are
absolutely right.
I have always been led to believe, and I have believed, that
Detroit was one of the world's leaders in engineering and engineer-
ing design prowess, and it appalls and saddens me that that engi-
neering design prowess is not being applied on behalf of the con-
sumer both in designing cars to resist damage and in finding tests to
better replicate what is happening in the real world so as to further
improve those designs.
Mr. ECKHARDT. Your comments about the consistent use by man-
ufacturers of heavy and inefficient bumpers to meet the Federal
standard imply that one should be skeptical of cost-benefit analyses
showing that title I cannot be met in a way that provides net
benefits to consumers.
Would you clarify this point and comment on whether you think
the agency could use its present authority to set peformance stan-
dards in such a manner as to restrict inefficient design and encour-
age more cost beneficial design? If not, would you recommend that
the agency be permitted to set design as opposed to performance
standards?
Mr. KELLEY. Let me try to break that question down into a few
pieces, if I may, Mr. Chairman.
First, as to the cost-benefit aspect of the question, Mr. O'Neill and
I a few years ago wrote a commentary on this point which might be
an appropriate inclusion in the record, if you wish it. It is not very
long, and goes right to the heart of the question you have raised.
Mr. ECKHARDT. Without objection, it will be admitted in the
record at this point.
[The information referred to follows:]
PAGENO="0047"
Copyright ©Society of AuV notive Engrneers. Inc. ft
All rights reserved.
Costs, Benefits, Effectiveness
and Safety:
Setting he Record Straight
Brian O'Neill and A. B. Kelley
Insurance Institute for Highway Safety
SOCIETY OF AUTOMOTIVE ENGINEEF~J
Automobile Engineering Meeting
Toronto, Canada
October 21-25, 1974
740988
21-335 0- 78 -4
PAGENO="0048"
46
740988
Co~t~, Benefits, Effectiveness and Safety:
Setting the Record Straight
Brian O'Neill and A. B. Kelley
Insurance Institute for Highway Safety
Society's goals for safer motor
vehicles are expressed in two laws:
the National Traffic and Motor Ve-
hicle Safety Act of 1966 (l)* and
the Motor Vehicle Information and
Cost Savings Act of 1972 (2).
These two laws direct the Federal
government, through the National
Highway Traffic Safety Administra-
tion (NHTSA), to translate motor
vehicle safety goals into motor
*Nuinbers in parentheses designate Refer-
ences at end of paper.
ABSTRACT
vehicle safety standards. The
standards are minimum performance
(not design) criteria for new car
safety.
The concepts of "cost-benefit"
and "cost-effectiveness" are in-
creasingly cropping up in debate
over present and future motor ve-
hicle standards. Often they are
introduced to attack, or justify,
a particular standard. Just as
often, they are misunderstood and
misused.
The concepts of "cost-benefit" and
"cost-effectiveness" are increasingly crop-
ping up in debate over present and future
motor vehicle standards. Often they are
introduced to attack, or justify, a partic-
ular standard. Just as often, they are
misunderstood and misused.
Since a motor vehicle safety perform-
ance standard has no costs per Se, it can-
not be evaluated either in cost-benefit o'r
cost-effectiveness terms. It is the par-
ticular design alternatives available to
manufacturers to achieve the objectives of
a standard that have societal costs. The
various design alternatives can be eval-
uated.
chosen to minimize societal costs, and
until there is evidence that cost-
effective designs have been chosen,
cost-benefit studies are premature.
Even then, because of the major con-
ceptual and methodological difficulties
in the valuation of life and limb, cost-
benefit studies will be appropriate p4y
in the evaluation of designs not primar-
ily intended to save lives and reduce
injuries -- that is, vehicle designs to
reduce property damage. Until manufac-
turers are forthcoming with accurate
cost data, neither cost-effectiveness
nor cost-benefit studies in this field
- can be relied upon. Pending legislation
may resolve this.
INTRODUCTION
Cost-effective designs should be
PAGENO="0049"
The purpose of this paper is to
define these two concepts of eco-
nomic analysis, to show how very
different one is from the other,
and to provide discussion and ex-
amples of their growing misapplica-
tion in the area of motor vehicle
safety standards development.
COST-BENEFIT ANALYSIS
Cost-benefit analysis measures
a planned program's costs against
its expected benefits, using iden-
tical monetary units of measurement
-- most often dollars -- on both
sides of the ledger. To over-
simplify: the dam will cost $10,000
(in manhours, materials, land,
alternative land uses, displaced
houses, etc.) to build. It will
produce $12,000 worth of benefits
(hydroelectric power, arable land,
flood reduction, increased recrea-
tion area, etc.).
Cost-benefit analysis can, in
theory, be used to obtain socially
efficient solutions to the resource
allocation problems of an economy,
and as such is an application of
welfare economics. Such an analy-
sis is concerned with the welfare
of the complete economy, not any
subset of it.
Cost-benefit analysis is based
on the concept of the so-called
"potential Pareto improvement,"
which is defined as a costless eco-
nomic rearrangement in which the
gains can be distributed so as to
make everyone in the community
better off (3).
In a cost-benefit analysis the
present and future benefits and
costs associated with the project
under consideration are determined
and compared. Future benefits and,
costs are usually discounted at
some rate to reduce them to present
values. In order to compare them,
both the benefits and costs must be
47
expressed in common monetary units.
They are usually compared either
by computing the ratio of benefits
to costs (the well known "benef it-
cost ratio") or by subtracting
costs from benefits (the net bene-
fits). Benefit-cost ratios great-
er than one or positive net bene-
fits are usually considered as
economic justification for the
adoption of the project under con-
sideration.
There are no substantial theo-
retical or conceptual difficulties
for cost-benefit analyses of pro-
jects in which the costs and
benefits can reasonably be quanti-
fied in monetary units. If, how-
ever, the principal benefits -
anticipated are savings in lives
and/or reductions in the frequency
and severity of injuries which
cannot be reasonably quantified in
monetary units, serious theoretical
and conceptual difficulties arise.
The same difficulties also arise
where the costs of a project in-
volve the loss of life and/or
increases in the frequency and
severity of injuries.
Virtually all cost-benefit
studies involving the loss of life
or limb have assigned fixed mone-
tary values to human life and
limb. Values for a life in such
studies are typically obtained
either by computing the discounted
future income of individuals or by
computing the discounted differ-
ences between future earnings and
personal consumption. These con-
cepts and approaches have been
criticized on a number of grounds
(4,5) and, in a detailed critique,
Mishan (3) concluded that they
are "economically irrelevant."
It is well worth noting that
NHTSA has expressed a similar
view. In its recent notice of
proposed rulemaking concerning
PAGENO="0050"
school bus crashworthiness, the
agency stated that it `has con-
ducted conventional cost-benefit
studies on school bus safety, but
the normal valuation techniques evi-
dently do not adequately reflect
general public opinion on the im-
portance of protecting children
from death or injury. Itis ob
vious from voluminous nail and
Congressional interest that society
places a much higher value on the
safety of its children than a con
ventional cost-benefit analysis
would indicate." (Emphasis added.)
(6)
Goodwin (7) suggested that the
criticisms of these "values of a
life" can be avoided "only if it is
clearly specified that the money
value arrived at is a minimum that
society would find it worthwhile
spending in order to avoid a fatal
accident." NHTSA (8) also empha-
sized "that placing a value on a
human life can be nothing more than
a play with figures. We have pro-
vided an estimate of some of the
quantifiable losses in societal
welfare resulting from a fatality
and can only hope that this esti-
mate is not construed as some type
of basis for determining the
`optimal' (or even worse, the `maxi-
mum') amount of expenditure to be
allocated to saving lives."
Mishan (3) also concludes that
other approaches as well are "eco-
nomically irrelevant concepts."
The only economically justifiable
concept, he finds, is one based on
the notion of "compensating varia-
tion," which is the amount each
member of the community is willing
to pay or to receive, in order to
feel that his overall welfare is
unchanged, in compensation for the
estimated change in risk. But this
approach, while justifiable eco-
nomically, is not practical at the
present time and may never be so,
because of the fundamental
48
impossibility of accurately mea-
suring each person's compensating
variation.
It is clear from the preceding
discussion that cost-benefit anal-
yses involving the loss of life
and limb are fraught with con-
ceptual and methodological diffi-
culties. Accepting the suggestion
of Goodwin (7) and NHTSA (8) that
the values conventionally used
for a human life in cost-benefit
analyses be considered as the
minimum that society should find
worthwhile spending in order to
avoid a fatal accident leads to
~ minimum values for the
benefit-cost ratios and the net
benefits. There is no acceptable
method for setting upper values.
Thus, if validly interpreted,
cost-benefit studies involving
the loss of life and limb --
particularly those studies that
have used unfavorable benef it-
cost ratios to criticize motor
vehicle safety standards, such
as the RECAT report (9) and Lava
and Weber (10) (studies with
additional serious methodological
deficiencies) -- can only yield
very limited conclusions.*
Furthermore, these shortcomings
of method and approach could lead
to the rejection of socially de-
sirable solutions.
COST-EFFECTIVENESS ANALYSIS
Cost-effectiveness analysis
compares the cost of alternative
means for effectively achieving
an agreed upon goal. The means
*Joksch (11) has presented a critical
appraisal of the applicability of cost-
benef it analysis to highway safety,
highlighting a number of additional
problems and difficulties associated
with cost-benefit analyses applied to
this area.
PAGENO="0051"
may be programs, technologies,
devices, or combinations of ap-
proaches. The goals are often ex-
pressed in public policy as laws
and standards.
Much of the philosophy and
methodology of cost-effectiveness
analysis was derived from cost-
benef it analyses. As a result,
there are many similarities in the
techniques and many people confuse
the two.
The three requirements of a
cost-effectiveness analysis were
outlined by Fabrycky and Thuesen
(12) as follows:
First, the systems or projects
being compared must have common
goals or purposes. (The compari-
son of passenger car occupant pro-
tection devices with passenger car
property damage protection devices
would not be valid.)
Second, alternative means for
meeting the goal must exist. (In
the case of virtually all vehicle
`safety performance standards, such
alternatives exist, whereas with
design standards there would be no
alternatives.)
Finally, the capability of mea-
suring the cost and effectiveness
of each system must exist.
One of the fundamental differ-
ences between the cost-benefit
method and the cost-effectiveness
method is contained in the first
requirement. This simply states
that the systems 1~eing compared
must have common goals or purposes,
which do not have to be expressed~
in monetary units. Thus, for ex-
ample, an objective could be a
target reduction in the annual num-
ber of motor vehicle occupant
fatalities, with no requirement
that this objective be translated
into monetary units. In the cost-
49:
benefit approach, both costs and
bénef its must be measured and
compared in monetary units.
Clearly, since there are in
general going to be several alter-
native designs and methods avail-
able for satisfying the objectives
of a motor vehicle safety standard,
a socially responsible manufacturer
should choose the cost-effective
design; that is, that design which
satisfies the objectives of the
standard with the lowest cost to
society among the various alter-
natives.
DISCUSSION
The appropriate uses for cost-
effectiveness methods and cost-
benefit methods in motor vehicle
safety improvement will be dis-
cussed in a moment. First, how-
ever, it is essential that one
point be very clearly understood.
A motor vehicle safet~pg~
formance standard has no costs
per se and therefore it cannot be
evaluated either in cost-benefit
or cost-effectiveness, terms. A
performance standard is a minimum
goal, and must not be confused
with the means for achieving the
It is the particular design
chosen by a manufacturer to
satisfy the objectives of the
standard that has costs.* The
*It is important to note that standards
do not always increase manufacturing
costs, they have in some instances re-
duced costs. Furthermore, there are
frequently significant cost increases
or reductions to society in addition to
those of manufacturing; these (sometimes
referred to as indirect or spillover
costs and/or benefits) must be considered
in both cost-effectiveness and cost-
benefit studies.
PAGENO="0052"
design alternatives, of course, can
be evaluated. -
Accepting the premise that the
goals established by Congress are
society's goals, it then becomes
the manufacturer's obligation to
society and government to demon-
strate that his particular design
choice for meeting the objectives
of a particular standard is cost-
effective. Until there is some
convincing evidence that a cost-
effective design has been chosen
by the manufacturer, it is in-
appropriate and premature to under-
take a cost-benefit study of de-
signs that may be substantially
more costly than is necessary.
Even then, because of the major
conceptual and methodological
difficulties in the valuation of
life and limb, cost-benefit studies
will be appropriate only in the
decision-making processes involving
standards not primarily intended to
save lives and reduce injuries --
that is, vehicle safety standards
to reduce property damage.
Congress recognized this dis-
tinction. Under Title I of the
Motor Vehicle Information and Cost
Savings Act (2) -- principally in-
tended to reduce property damage
losses resulting from low-speed
crashes -- it included a mandatory
requirement for the Department of
Transportation (DOT) to consider
both the costs and the benefits
and to report to Congress the cost
savings resulting from the admini-
stration of this title. However,
in considering the National Traffic
and Motor Vehicle Safety Act (1),
which empowered DOT to set motor
vehicle safety standards aimed at
reducing deaths and injuries, Con-
gress rejected draft language re-
quiring such studies for safety
standards. (13)
50
the inappropriateness of applying
cost-benefit criteria to develop-
ing motor vehicle standards for
reducing death and injury, it is
necessary to ask why so-called
cost-benefit studies are increas-
ingly being forced into the stand-
ards-making process, where they
clearly do not belong. (Cost-
benefit analysis does, however,
have a legitimate place in the
development of property damage
standards under the Motor Vehicle
Information and Cost Savings Act
of 1972, but not before there is
evidence that cost-effective de-
signs have been or will be chosen
and that their advantages have
not been or will not be negated
by the pricing policies of the
manufacturer.)
Turning now to cost-effective-
ness: this method is a useful tool
for comparing alternative ways to
~d~chieve a predetermined vehicle
safety objective and selecting the
most desirable way. It does not
appear, though, that cost-effect-
iveness techniques are being used
very much for that purpose.
In illustration, consider
Federal Motor Vehicle Safety
Standard (FMVSS) 215 (14). This
exterior protection standardwas
issued in April 1971 and was in-
tended to provide protectioh,
beginning with the 1973 models,
against damage to a limited range
of "safety related equipment" in
low-speed crashes. Although this
was a standard aimed at protecting
safety related equipment, it was
widely hoped that one of the
principal benefits would be re-
duction in the amounts of property
damage occurring in low-speed
crashes. Thus, the designs chosen
by the various manufacturers to
satisfy the requirements of this
standard have been used to esti-
mate both the benefits and the
costs in cost-benefit studies
Since Congress itself recognized
PAGENO="0053"
(15, 16, 17, 18), including the
mandated DOT study, to justify or
refute the proposed motor vehicle
standard issued under Title I of
the Motor Vehicle Information and
Cost Savings Act.*
*At the present time there is no federal
motor vehicle standard that is directed
exclusively toward the reduction of prop-
erty damage. Under Title I of the Motor
Vehicle Information and cost Savings Act,
a proposed standard (19) is due to go into
effect beginning with the 1976 model year.
The cost-benefit analysis required by law
under this Act has been based inapprop-
riately and almost entirely on the per-
formance of recent- model year vehicles
that conform with FMVS$ 215 (16).
**It is important to note the distinction
between cost, which is the real cost to
the manufacturer, and the price which is
that charged to the consumer. At the
present time there is no reliable informa-
tion publicly available, or available to
the Federal government, concerning the
relationship between prices and costs.
51
same function strongly suggest
that cost-effectiveness has not
been a concern of the manufac-
turers in meeting this standard.
The law leaves it entirely to
the manufacturer to choose front
and rear end designs that meet
the minimum requirements of FMVSS
215. The manufacturer may under
the standard develop, for in-
stance, front and rear end designs
with the following characteristics
that would be costly to society:
unnecessarily heavy com-
ponents that increase fuel con-
sumption.
Expensiveness of repair
and/or replacement.
While such design choices
would not be cost-effective to
society, they could return sub-
stantial profits and also could
create for the manufacturer large
future sales of replacement and
repair parts. It is. also pos-
sible that the manufacturer could
generate consumer hostility to
the standard by choosing these
unfavorable characteristics.
The manufacturer may, on the
other hand, develop designs that
seek to incorporate the following
characteristics that should re-
duce society's costs:
There is no evidence that the
designs chosen to meet the require-
ments of FMVSS 215 are cost-
effective. On the contrary, there
is considerable evidence to suggest
that the degigns chosen by certain
manufacturers are far from cost-
effective. Casassa, et. al. (20)
have shown huge differences in the , --- A low performance level,
replacement prices** of bumper sys- so as to meet the standard yet
tems for seven domestic 1974 models;.~ permit sheet metal damage (not
front bumper replacement prices covered by the standard) at five
range from $111 to $347 and rear miles per hour.
bumper replacement prices range
from $80 to $296. Comparing re-
placement prices for subcomponents
among the same seven domestic 1974
models, the bumper energy absorbers,"
range in replacement prices from
$13 to $67, a more than fivefold
difference. Such huge price ranges'
f or designs intended to perform the,
Ineffectiveness at higher
speeds, so as to virtually guaran-
tee costly damage -- and attendant
sale of replacement and repair
parts -- in impacts at speeds
higher than five miles per hour.
Effectiveness in reducing
PAGENO="0054"
auto body damage both at and above
the five mile an hour minimum rë-
quirements, so as to further re-
duce owner and insurer costs in
Orashes.
Easiness and inexpensiveness
of repair and/or replacement.
Lightweight components that
reduce fuel consumption.
The example of Standard No. 215
typifies the difference between the
standard, which is an objective
that cannot be measured in cost
terms, and the alternative ways
available to meet it, which can be
subjected to cost-effectiveness
evaluation.
The difference is also apparent
in examining other standards. For
instance, FMVSS 202 (21) requires
the provision of protection against
whiplash injuries in rear-end
crashes. Manufacturers have chosen
to meet the standard in a variety
of ways, ranging from designs re-
quiring considerable adjustment by
the user, to designs that are so
well integrated with the seat back
that no adjustment whatsoever is
required.
FMVSS 301 (22) requires, as
another example, that new cars be
able to withstand a 30 mile per
hour front-into-barrier crash with-
out hazardous loss of fuel. The
range of options available to manu-
facturers for meeting this standard
includes relocation of fuel tanks
and fuel lines, use of bladder-
inner tanks (as in the 1975 model
Chevrolet Corvette), and a wide
variety of additional design and
manufacturing alternatives.
Motor vehicle safety standards
do not necessarily increase the
manufacturing costs. For example,
FMVSS 211 (23), which precludes the
use of wheel nuts, wheel discs and
hub caps that constitute a hazard
to pedestrians and cyclists, has
eliminated `scythe like" hub caps.
These were presumably more costly
to manufacture than less hazard-
ous hub caps because they were
invariably priced higher to the
consumer; thus, in this instance
costs were reduced as a result of
a motor vehicle safety standard.
Consider, for another example
of cost-reduction opportunities
flowing from a still hypothetical
standard (although one within the
power of NHTSA to issue) limiting
the maximum speed performance of
new cars. A manufacturer could
meet such a standard by adding a
clumsy, inefficient "governor"
device to its existing design for
an overpowered automobile. But
it also could meet the standard
by redesigning the engine, power
train and transmission to produce
less horsepower, which would at
the same time reduce the weight
of the automobile and use less
valuable metal and other resources,
lower its fuel consumption, and
lower its pollutant emissions,
thereby substantially reducing
both the direct and indirect costs
to society.
(To say that a standard, as a
goal, cannot per se be measured
in cost-effectiveness terms is
not, of course, to say that its
effectiveness cannot be evaluated
at all. On the contrary, safety
standards must be subjected to
continuing evaluation against the
possibility that a standard's
language may defeat its purpose.
For example, recent studies (24,
25) have indicated that the word-
ing of FMVSS 203 (26), requiring
that steering assemblies be de-
signed to absorb the driver's
energy in a crash, may actually
be precluding steering assembly
designs that would perform better
than those now available.)
52
PAGENO="0055"
It is clear that cost-effective-
ness methods have a useful place in
comparisons of alternative means
for meeting the objectives of a
motor vehicle safety standard,
but not for assessing the stand-
ard itself.
It is also clear that cost-
benef it analysis has a legitimate
role in evaluating the desirability
of a motor vehicle property damage
standard once the most cost effect
ive way to meet the standard is
chosen, but does not have a legiti-
mate role in evaluation of stand-
ards whose benefits are lives and
health, not dollars and cents.
A closing note of caution: No
cost-benefit or cost-effectiveness
analysis can be performed if the
costs of the system under scrutiny
are unknown. For approaches to
motor vehicle standards compliance,
those costs are in fact largely un-
known to all but the auto manufac-
turers themselves.
NHTSA has not made full use of
its existing statutory power to
obtain from the manufacturers de-
tailed, reliable data as to the
costs of alternative designs that
meet particular safety standards.
Nor have the manufacturers been
forthcoming with any but vague and
general information about costs.
The undependability of manufac-
turer-provided cost figures has
been exemplified often. Recently
the former director of General
Motors Corporation's air bag pro-
ject provided NHTSA with informa-
tion on air bag system costs that
was far more precise -- and far
more encouraging for the public --
than the cost and price estimates
that General Motors itself has re-
leased (27). After doing so, he
stressed that his figures were
"quite markedly different from pos-
sible other claims that you have
accurate cost data from manufac-
turers, cost-effectiveness and
cost-benef it techni~ues can become
5a
heard as to how much the air cush-
ion should cost."
Earlier this year a European
auto manufacturer told the General
Accounting Office (GAO) of its
belief that industry-generated
cost information is not useful for
valid cost-effectiveness measure-
ment. "... the auto industry,"
Volvo told GAO, "has in some in-
stances taken advantage of the
lack of methodology and released
biased material aimed purely at
resisting regulation." (Volvo
addedits belief that cost- -
effectiveness should be an NHTSA
consideration, "but not neces-
sarily the overriding considera-
tion, in establishing the,;need
for regulation.") (28)
In its report on "benefit-cost
analyses" issued in August, GAO
itself was critical both of NHTSA's
methods for collecting usable cost
information involving standards,
as well as the industry's reluct-
ance to furnish such information.
(29)
On October 11, 1974, the Senate
passed a bill -- earlier agreed
on in conference between the two
houses -- which may hold the key
to solving this problem (30).
The bill provides that manufac-
turers opposing an NHTSA standard
on the "ground of increased cost"
be required to submit cost infor-
mation -- "information with re-
spect to alleged cost increases
resulting from action, by the
Secretary, in such form as to per-
mit the public and the secretary -
to make an informed judgment on
the validity of the manufacturer's
statements" including "both the
manufacturer's cost and the cost
to retail purchasers."
If the bill becomes law, and
if NHTSA makes vigorous use of the
bill's provision for acquiring
useful tools in the motor vehicle
safety field -- so long as they
are used appropriately.
ACKNOWLEDGEMENT
The comments of William Haddon, Jr., M.D. and Leon S. Robertson,
Ph.D. are gratefully acknowledged,.
PAGENO="0056"
54
REFERENCES
1. National Traffic and Motor Vehicle Safety Act, Public Law 89-563,
September 9, 1966.
2. Motor Vehicle Information and Cost Savings Act, Public Law 92-513,
October 20, 1972.
3. E. J. Mishan, "Cost-Benefit Analysis." New York, N.Y.: Praeger
Publishers, 1971.
4. J. G. U. Adams, "London's Third Airport." Geograph J., Vol. 137,
1971.
5. T. C. Schelling, `The Life You Save May Be Your Own." Problems
in Public Expenditure Analysis, Brookings Institution, 1968,
pp. 127-176.
6. Department of Transportation, National Highway Traffic Safety
Administration, "Notice of Proposed Rulemaking on School Bus
Passenger Crash Protection," Federal Register, Vol. 39, No. 147,
July 30, 1974, pp. 27585-27589.
7. P. B. Goodwin, "On the Evaluation of Human Life in Accident
Studies." Accident Analysis and Prevention, Vol. 5, 1973,
pp. 287-293.
8. Department of Transportation, National Highway Traffic Safety
Administration, "Societal Costs of Motor Vehicle Accidents."
Preliminary Report, April 1972.
9. Executive Office of the President, Office of Science and Tech-
nology, "Cumulative Regulatory Effects on the Cost of Automotive
Transportation (RECAT) ." Final Report, February 28, 1972.
10. L. Lave and W. Weber, "A Benefit Cost Analysis of Auto Safety
Features." Applied Economics, Vol. 2, 1970.
11. H. C. Joksch, "A Critical Appraisal of the Applicability of
Benefit Cost Analysis to Highway Traffic Safety." Prepared for
the Insurance Institute for Highway Safety, October 1974.
12. W. J. Fabrycky and G. J. Thuesen, "Economic Decision Analysis."
Englewood-Cliffs, N.J.: Prentice-Hall, 1974.
13. Hearings Before the Committee on Interstate and Foreign Commerce,
U.S. House of Representatives, 89th Congress, 2nd Session, on
HR 13228, "Part 2, Traffic Safety," p. 1203.
14. Federal Motor Vehicle Safety Standard 215, "Exterior Protection."
Code of Federal Regulations, Title 49, Part 571.215, October 1,
1973.
PAGENO="0057"
55
15. D. L. Nordeen, "An Analysis of the Cost Effectiveness of 1974
Bumper Systems," Private Communication: D. L. Nordeen, 1032
Whitman Drive, East Lansing, Michigan 48823, 24 July 1974.
16. Department of Transportation, National Highway Traffic Safety
Administration, Transportation Systems Center, "Damage Resistant
Bumpers." TSC Report No. (DP-SP-30), July 19, 1974.
17. Ford Motor Company, Comments on National Highway Traffic Safety
Administration Docket No. 74-11, Notice 2 and 73-19, Notice 3,
August 23, 1974.
18. General Motors Corporation, "General Motors Benefit-Cost Analysis
of 1973 Exterior Protection Systems and Field Evaluation of 1973
Automobile Collision Losses, USG 1045, Part ii." Attachment to
General Motors' Comments to National Highway Traffic Safety
Administration Docket No. 74-11, Notice 2 and 73-19, Notice 3,
August 20, 1974.
19. Department of Transportation, National Highway Traffic Safety
Administration, "Notice of Proposed Rulemaking on Motor Vehicle
Safety and Damage Standards." Federal Register, Vol. 39, No.
132, July 9, 1974, pp. 25237-25240.
20. J. Casassa II, W. W. Sorenson and R. E. Gardner, "Bumpers:
Effective, But How Cost Beneficial?" Paper 740986 presented at
SAE International Automobile Engineering and Manufacturing
Meeting, Toronto, October 1974.,
21. Federal Motor Vehicle Safety Standard 202, "Head Restraints."
Code of Federal Regulations, Title 49, Part 571.202, October
1, 1973.
22. Federal Motor Vehicle Safety Standard 301, "Fuel Tanks, Fuel
Tank Filler Pipes, and Fuel Tank Connections." Code of Federal
Regulations, Title 49, Part 571.301, October 1, 1973.
23. Federal Motor Vehicle Safety Standard 211, "Wheel Nuts, Wheel
Discs, and Hub Caps." Code of Federal Regulations, Title 49,
Part 571.211, October 1, 1973.,
24. P. F. Gloyns, "The Impact Performance on Some Designs of
Steering Assembly in Real Accidents and Under Test Conditions."
Department of Transportation and Environmental Planning,
University of Birmingham, England, December 1973.
25. J. W. Garrett and D. L. Hendricks, "Factors Influencing the Per-
formance of the Energy Absorbing Steering Columns in Accidents."
Calspan Corporation, Buffalo, N.Y. presented at the 5th Inter-
national Technical Conference on Experimental Safety Vehicles,
London, England, June 1974.
PAGENO="0058"
56
26. Federal Motor Vehicle Safety Standard 203, "Impact Protection for
the Driver from the Steering Control System." Code of Federal
Regulations, Title 49, Part 571.203, October 1, 1973.
27. John DeLorean Corporation, Briefing to Department of Transporta-
tion, National Highway Traffic Safety Administration on Occupant
Crash Protection, September 17, 1974.
28. Volvo of America Corporation, Letter to U.S. General Accounting
Office, May 29, 1974.
29. Government Accounting Office, "Need to Improve Benefit-Cost
Analyses in Setting Motor Vehicle Safety Standards," Report No.
B-164497(3), July 22, 1974.
30. Section 105, House Report No. 93-1452 on S.355, Congressional
Record, p. H 10184, October 8, 1974.
ThiS p~p~ ~ St~te~,~ts ~ F~ ~ t~ p~bIish this pspss is sil its ptst, sssttsct th~ SAE Pssbliss-
sdssssc,d its ptsptsss ss discsststisss ate the atsthss', assd ate that Disiaiass.
I hi, ~espaasibi1ita, rat the Sasiety',. Ditaatsiaa ta-ill he Peetaat taithiag a ,abatit papets a be a-aatideted fat pteseatatiaa at pabliaa-
~ !~~) ptiatedtaiththe ptpetif it it pssblithad its SAE Ttaatstatiaat. tiaa thtaagh SAE shatald ,ead the aaaatatipt at a 300 aatd abattaat af, pta-
patadatttassta-tiptto:Sactetaty,EagiaeetiagAatiaitie~Baatd,SAE.
Society of Automotive Engineers, Inc.
16 page baahl,t Patted a U.S.A.
PAGENO="0059"
57
Mr. KELLEY. The point made in that commentary, and the point
that I would wish to make, is that the department has power only
1o set performance standards, and not design standards, and there-
fore is always one step removed frOm reaching cost-benefit conclu-
sions about the effect of its standards. The department may not and
does not direct that a manufacturer put some specific costs
assessable design on its cars. It simply tells the manufacturer that
the car shall perform in such and such a fashion under such and
such crash or other conditions, and :leaves within the broad latitude
of the manufacturer the choice of selecting from available alterna-
tive designs-and in the case of bumpers, they might be designed
such as Mr. Taylor's bumper, they: might employ alternative kinds
of shock mounts, they might be soft nose, or use plastics that do the
energy absorbing job in a variety : of different ways-any one of a
number of alternatives, each with a different cost, but none with
the final cost in the cost-benefit sense.
It seems to me that the department must limit itself, once
manufacturers have selected their alternative designs, to assessing
the results of those choices, and then where necessary the depart-
ment must persuade, encourage, cajole manufacturers to do design
jobs that are more cost effective in meeting those performance
standards. That comes to the last part of your question. Should the
government be authorized to set design standards for auto
manufacturers?
My own feeling is that the government would not do a good job of
designing automobiles, and I would hope that the auto manufactur-
ing industry will not bring upon itself that which it says it fears
most, the mandating of automobile designs by government because
of the industry's reluctance to give good design to American con-
sumers under existing peformance standards, and yet I see that
happening more and more, and: it alarms me greatly.
Mr. ECKHARDT. I rather agree with you, because of course perfor-
mance standards leave a lot more room to innovation and change,
and I think that is true not only with respect to safety and cost
saving, but with respect to all design. I am wondering though if
sometimes because we have to approach this in a somewhat obtuse
or indirect way we don't find ourselves faced with arguments which
are really not valid, and would obviously not be valid if we were
looking at a prototype design. I am just thinking out loud here.
What would be wrong with the agency affording a specific design
as an option? "We will not hold you to a design standard, but here
is what you could do, and if you did this, it would be acceptable."
Mr. KELLEY. That certainly is one interesting and very possibly
productive approach, Mr. Chairman. I think another part of the
answer to the question and to this issue generally is one's interpre-
tation of the word performance in the setting of performance
standard. It seems to me-and :1 hasten to interject here that I am
not an attorney and I am not an expert on statutory language-but
it seems to me that the weight of a bumper, the sorts of materials a
bumper uses, the impact on the nation's resources that the manu-
facturing and processing of that bumper may present are, in and of
themselves, performance matters, and they perhaps are subject to
performance criteria just as much as how the bumper will perform
PAGENO="0060"
58
in the crash is subject to performance criteria, so I am not suggest-
ing that performance is such a broad term that within it any
manufacturer or any other interest should be allowed to do any-
thing. How components of cars perform in consonance with national
criteria, with new priorities in the nation, it seems to me, is a very
legitimate subject to which performance standards may address
themselves.
Mr. ECKHARDT. Let me pose a question without suggesting in. the
question any solution.
It has been intimated in the discussions that I have had with
persons familiar with this subject that manufacturers will meet
precise performance standards, and in so doing, permit considerable
damage within the interstices of these standards.
Now that seems to me to be a very bad thing, because it may tend
to cause design calculated to prevent the theoretical test risk, but
not to prevent the actual risk.
I don't know how you really ever answer that, unless your
performance standards are subjected to of much more sophisticated
testing than that which is now used.
Mr. KELLEY. I am afraid that our own testing experience, and my
own knowledge of the auto industry's past record, suggests that you
are entirely accurate, and that what is being met too often is not
the intent of a standard, not the public interest goal, not the goal of
giving the consumer the best, but instead the barest possible mini-
mum interpretation of the performance standard, and often in ways
that violate other of the consumers' needs, and that the spirit-and
I know of no other way to put it, although it may sound trite-that
the spirit of the law and the spirit of the standards and the concern
that gave rise to them in the first place are not being responded to.
What is being responded to is the need for simply getting by, by
meeting, just barely meeting, a compliance test, and never exceed-
ing it.
Mr. ECKHARDT. You say that the technology has been available at
least since the passage of this act, to put damage preventing bumper
systems on all U.S. cars. You have also conducted extensive crash
testing in which you have measured the repair damage to particular
makes and models in low speed crashes.
Can you, on the basis of your research, provide any sort of
estimate of the aggregate dollar losses suffered by consumers per
year or for a longer period as a result of unnecessary crash damage?
Mr. KELLEY. Our data, Mr. Chairman, don't produce an overall
aggregate figure for the total amount of dollars being needlessly
wasted by damage that has been designed into automobiles for
being sustained in low speed crashes. I am sure it would be, if
computed, an absolutely mind-staggering figure. It does not come
out of our data.
Mr. ECKHARDT. That really leads somewhat to title II, which was
designed to obtain some figures that would constitute a gross
damage measurement, and also permit a comparison of
repairability costs by makes and models of automobiles. I would like
to ask you this. You have not addressed title II of the act in your
statement, but I would like to ask you what role the Highway Loss
Data Institute, which is funded by your organization, has played in
meeting the requirements of the title.
PAGENO="0061"
59
Mr. KELLEY. Yes.
Mr. Chairman, the Highway Loss Data Institute, which is a
companion organization to the Insurance Institute for Highway
Safety, was set up a few years ago as a mechanism for gathering
data based on insurance company information, gathering data on
the size and frequency of various kinds of damage and human
injury claims by individual make and model of automobile, and the
Highway Loss Data Institute makes public the results of all of that
data.
Mr. O'Neill, who is with me here today, is, in addition to being
the vice president of Research of the Insurance Institute for High-
way Safety, a special consultant to the Highway Loss Data Insti-
tute. He was one of those instrumental in designing that organiza-
tion and is now instrumental in designing its work, and I would like
him to describe for us, if yoi.i would agree, how the Highway Loss
Data Institute works and how its Operation fits in with the title II
requirements.
Mr. ECKHARDT. We would very much like to have him do that. We
had intended title II as a title in which the Federal agency would
utilize such information and give it more or less the imprimatur of
official sanction. I assume your agency, sir, is assembling some of
the kind of data that we had in view in title II.
Mr. O'NEILL. Yes, Mr. Chairman. The Highway Loss Data Insti-
tute was formed in December of 1972, and at the present time it is
collecting data on insurance coverages for damage both to the
vehicles and to their occupants. At the present time 10 of the larger
insurers in this country are supplying data to HLDI, and among
them we think they respresent something over one third of all
insured vehicles in the country. The Highway Loss Data Institute
has produced 21 reports so far, and produces reports each year on
the current model year. We collect data on the most recent three
model years at any given time, sO right now we are collecting data
on the 1977 models, 1976 models, and 1975 models. Beginning in
September of this year we will begin collecting data on the 1978
models.
We think the results that we have produced so far go a very long
way towards providing the sort, of information that was required
under title II of this act.
Mr. ECKHARDT. Title II has been criticized to me on grounds that
information could not be assembled soon enough to give consumers
information with respect to chobsing among present models. It has
always seemed to me that this is not entirely a valid criticism.
First, there is frequently a similarity among models and designs,
and in model from year to year. Second, even if a change is made to
take care of defects revealed in the title II data, and if the maker is
unduly prejudiced by a bad report on his last model, he certainly
has access to advertising to show that he has an improved model.
This is very much as I have seen in certain eating establishments
with large signs saying, under new management", that always seem
to indicate that the last one was very bad.
Would you care to comment on that point?
Mr. O'NEILL. I think you are correct, Mr. Chairman.
PAGENO="0062"
60
The first model year that we collected data and produced results
for the Highway Loss Data Institute was the 1972 model year,and
we have produced results on the loss experience of every model year
since then, and we have seen, over these model years, a certain
amount of consistency from year to year among the same makes
and models. I think this is increasingly the case. We are seeing
fewer and fewer design changes with the cars each new model year,
and certainly there has been some consistency in the results for
particular make and model, from year to year.
Mr. ECKHARDT. Of course actually this information is not all
negative to manufacturers. It may also reveal year-to-year model
improvements which are to the credit of the automobile maker.
Mr. O'NEIu~. Yes, sir.
Mr. Chairman, certain makes and models have been performing
consistently better than average, and other makes and models over
the years have been performing consistently worse than average, so
yes, it works both ways.
Mr. KELLEY. I might say, Mr. Chairman, that the Highway Loss
Data Institute has as one of its goals the publishing of its data as
early as possible, for individual makes and models, and certainly for
market classes, and as much as possible publishes those data within
the model year while that car is still on the market. I think that
goes to your point about the timeliness of the availability of data to
consumers.
Mr. ECKHARDT. Thank you very much for your presentation.
Mr. KELLEY. Thank you, Mr. Chairman.
Mr. ECKHARDT. There is one other thing. I wonder if Mr. Taylor
would like to make a few comments or reply to a few questions.
Mr. Taylor, how heavy is your bumper system compared with the
regular Gremlin system?
Mr. TAYLOR, SR. The standard bumper system on the car weighs
62.4 pounds. Ours weighs 62.6 with the bumper guards on. If you
add the bumper guards on the standard AMC, which are an option,
it comes out 2 pounds heavier than ours.
Mr. ECKHARDT. How heavy would such a bumper be in mass
production?
Mr. TAYLOR, SR. You could take about 2 pounds `ff that existing
bumper system, using their steels. If you were to use steels that are
available which would reduce the weight still further, you could
take it down to the 38 pounds, the weight of our original Hornet of
1971, which passes all the specifications of this present Gremlin.
Mr. ECKHARDT. I assume then that you are saying that bumper
systems that would give much better performance than present
bumpers could be produced economically and without weight
increases?
Mr. TAYLOR, SR. Yes, definitely.
Mr. ECKHARDT. Your bumper system does not have a plastic filler
panel, a so-called gravel guard between the bumper and the body,
like many other cars in the film. Why not?
Mr. TAYLOR, SR. That strip is a particular sore point with me. I
was called to AMC to lengthen my bumper shock a half-inch stroke
so that filler strip would not dent the trunk. It should not really be
called a gravel shield. In truth it is a trap.
PAGENO="0063"
61
Under my present Volare test car, which has the same strip on
the back, during the Buffalo blizzard, I was appalled to get under
the car and find out that the bumper was packed solid with ice and
snow from the bumper to the body and in a 2-mile-an-hour crash I
would have done $500 damage to the car. Now that is only part of
the problem.
This is a strip, the first one I could catch.
Mr. ECKHARDT. You just happened to have that with you?
Mr. TAYLOR, SR. Just happened to have it with me. It is a
particular sore point. Its cost is $40. They cannot afford a nickel
more for a shock absorber, but they put that strip worth $40 on the
car.
Now for the real clincher. To put that on 5 million vehicles
requires 22.5 million gallons of petroleum per year, to make the
strip, and that is enough fuel to fly Pan American's entire flight of
747s, 707s, 727s for 10 days, and it is absolutely useless.
Mr. ECKHARDT. Is that at an extra cost?
Mr. TAYLOR, SR. Extra cost and absoutely unessential. The Pacer
does not have it on, the Gremlin does not have it on, on the
Matador coupe, we prevailed on them to just cover the bumper
shock. The Matador station wagon has it, and when I complained to
AMC aBout it, they said well, GM has it on. We all have to follow
suit.
Mr. ECKHARDT. Well, I guess you have to put the shiny chromium
on. Then you have to cut down the glaze or the shine with some-
thing to cover it over.
Mr. KELLEY. Mr. Chairman, if I may, the Department of Trans-
portation has within the past day or so issued an amendment, or a
clarification if you will, of the phase 1 bumper standard under title
I. The question before it, put by the auto manufacturers was: Is that
filler panel part of the bumper, meaning can it be damaged under
phase 1, or is it not part of the bumper, meaning no, it may not be
damaged? Here is the agency's decision on that question:
"The agency has reexamined the role of filler panels and stone
shields in the bumper system, and finds that although they do not
actuallly hold the bumper to the vehicle frame, they are cosmetic
components that are part of the entire system that performs the
task of attaching the bumper to the frame of the car."
"NHTSA has concluded that permitting damage to filler panels
and stone shields will not significantly degrade the level of perfor-
mance required for vehicles manufactured after September 1,
1978."
In short, it may now also be damaged under phase 1, even though
it is a cosmetic component.
Mr. ECKHARDT. When I heard the first part of that I thought the
answer was going to come out the other way.
Mr. KELLEY. When I read the first part of it this morning, I
thought that the answer would come out the other way.
Mr. ECKHARDT. I have had that happen to me as a lawyer,
particularly when a judge starts talking
Mr. KELLEY. I was reminded,: of Secretary Coleman's airbag deci-
sion when I got to the punch line this morning.
Mr. ECKHARDT. Mr. Taylor, how many people worked on the
development of your system, and how long?
21-335 0 - 78 -
PAGENO="0064"
62
Mr. TAYLOR, SR. I think I will defer to my son and he will refer to
the design process because he was in the middle of it also.
Mr. TAYLOR, JR. As Mr. Kelley had explained, this entire system,
which you saw the films of was designed, built, constructed, tested
in a turnkey type of operation within a period of around 45 days, I
guess. The basic system which we have come up with managed to
utilize the existing face bar from the Gremlin vehicle. We modified
the back-up structure to the bumper. We came up with our own
mounting brackets, and of course used the bumper shock absorber,
which was of our design, which was used on American Motors cars
in 1974, a 3-year-old bumper shock to meet a standard that people
have trouble meeting today.
The entire system was developed, built, complete, by three engi-
neers and one machinist in that period.
Mr. ECKHARDT. Of course, Mr. Taylor, one can always produce a
prototype that will do a particular job. I suppose the real question is
whether or not the prototype is practical for mass production.
Can you comment on whether or not within your view the type of
energy absorber that you are showing us here can be produced at a
reasonable cost?
Mr. TAYLOR, JR. I think it is important to remember that the
bumper system is more than just the energy absorber. It is a
system. It includes the steel parts, the energy asorbers, the mount-
ing brackets, a rubber trim, vinyl strips, whatever.
As I mentioned, the actual energy absorber which we used on
that car was an original equipment 1974 American Motors part.
You can go down to a used car lot and find a 1974 Ambassador
wagon, remove the energy absorber from it, and you have essen-
tially the same energy absorber that we have on the car right out
there.
Mr. ECKHARDT. So what you are showing us is an assemblage of
equipment, all of which has been mass-produced; is that correct?
Mr. TAYLOR, JR. As I said, the actual chrome face bar is the
original American Motors face bar. The two small rubber bumper
guards which we used on the bumper to prevent local denting and
scratching, those were a 1977 American Motors Gremlin rubber
bumper guard which is an option on the vehicle.
The back-up structure to the bumper, steel rim reinforcement
and the mounting brackets, were fabricated from scratch by our
firm using a very common, readily available automotive type of
steel alloy, in this case manufactured by Republic Steel and avail-
able just about in any quantity that you wish, so it is very, very
conventional in construction. The uniqueness of it is the particular
combination of components used, quite frankly, which gets you
around the problem of a damage-preventing angle barrier hit
merely by combining such components as are necessary to get
around that problem.
Right now the auto makers have no requirement really in the
present law to produce a zero damage system, and it is evident from
the films that they have elected not to do so.
Mr. ECKHARDT. I want to thank all of you gentlemen for your aid
to this subcommittee.
Mr. KELLEY. Thank you, Mr. Chairman.
PAGENO="0065"
63
Mr. ECKHARDT. Mr. Andre Maisoñpierre. We are glad, sir, to have
you before this committee again.
STATEMENT OF ANDRE MAISONPIERRE, VICE PRESIDENT,
AMERICAN MUTUAL INSURANCE ALLIANCE AND ON BEHALF
OF THE NATIONAL ASSOCIATION OF INDEPENDENT INSURERS
Mr. MAISONPIERRE. Thank you very much, Mr. Chairman.
Today I am appearing on behalf of the American Mutual Insur-
ance Alliance, and also on behalf of the National Association of
Independent Insurers, which is an association of 600 property and
casualty insurance companies.
I believe, Mr. Chairman, that you have received a letter from Mr.
Mertz, the president of the association.
MR. ECKHARDT. Without objection, it will be inserted in the record
at this point [See p. 78].
Mr. MAISONPIERRE. Mr. Chairman, in view of the time constraint,
I would like to skip over parts of our statement, but I would
appreciate it if the whole statement could be made a part of the
record.
Mr. ECKHARDT. Without objection, it will be so ordered.
Mr. MAISONPIERRE. Thank you very much, sir.
My name is Andre Maisonpierre. I am a vice president of the
American Mutual Insurance Alliance. We are the major national
association of mutual property and casualty insurance companies.
Our members provide automobile insurance coverage for both per-
sonal and commercial vehicle owners in all 50 States and the
District of Columbia.
We appreciate the opportunity to appear before this subcommit-
tee to present our views on the implementation of the Motor
Vehicle Information and Cost Savings Act of 1972, Public Law 92-
513.
The purposes of Public Law 92-513 are to promote competition
among motor vehicle manufacturers in the design and production of
safe motor vehicles and to reduce the cost of automobile ownership
and maintenance to consumers. These objective are to be achieved
by improving the quality of automobiles and by attempting to
develop consumer information systems which will facilitate consum-
ers' market choice.
Our testimony today will assess Title I-Bumper Standards, and
Title IT-Automobile Consumer Information Study, as related to the
act's stated objectives.
TITLE I-BUMPER STANDARDS
The alliance is disappointed by the lack of effective action in the
area of bumper standards. A brief look at the history of bumper
- standards wil illustrate some of the causes of our discontent.
Title I requires the National Highway Traffic Safety Administra-
tion, NHTSA, to develop new bumper standards for passenger cars
which would limit property damage caused by low-speed collisions
and provide "the maximum feasible reduction of cost to the public
and to the consumer..."
PAGENO="0066"
64
Prior to the act, NHTSA could ony set safety-related standards.
Ths had been done in Federal Motor Vehicle Safety Standards No.
215, still the only bumper standard in effect, which prohibits
damage to safety-related parts such as radiators and breaklines in
low-speed impacts.
In August 1973, NHTSA proposed a property damage bumper
standard, which would also incorporate the current Federal safety
standardon bumpers, to be effective with 1976 models. In a series of
subsequent rulemaking actions, the proposed effective date was
repeatedly delayed. Finally, in March 1976, NGTSA adopted a final
rulemaking the property damage standard effective for 1979 models
with more stringent requirements going into effect for 1980 models.
In March of this year, NHTSA has proposed yet another delay in
its standard limiting property damage to cars in most speed crashes.
In response to requests from General Motors and Ford Motor
Company, the agency is proposig to delay for 1 year the effective
date of the more stringent second phase of its standard. NHTSA has
proposed the delay even though the auto makers already have been
given more than three model years, since adoption of the standard
in March 1976, to prepare for the 1980 model year bumper
requirements.
Actually, Mr. Chairman, this lack of effective Federal action is
what we feared 6 years ago when we testified on the bills which
eventually led to the enactment of title I. At that time there had
already been some state action requiring auto manufacturers to
provide better auto bumpers.
California had enacted a law requirig that cars sold after Septem-
ber 1, 1973, be equipped with bumpers capable of sustaining a 5-
mile-per-hour impact without appreciable property damage to the
front or rear of the vehicle. Maryland, Florida, Georgia, North
Carolina, and Minnesota had enacted similar legislation.
Our concern was that the Federal bill would preempt these
enacted State laws and either set standards below existing State
programs or stop any further State action while the applicable
Federal standard was being developed. This is exactly what has
happened.
Despite the inclusion of a grandfather clause for existing State
laws, the enactment of title I forestalled any enforcement action by
these States. Apparently States were wooed, as we were, into the
false belief that the required national standard would be forthcom-
ing shortly with Federal enforcement. Unfortunately, this has not
occurred.
Mr. Chairman, the alliance believes that the interests of the
consumer have ben ill-served by this lack of effective action. Any
further delay in the implementation of the bumper standards, as is
proposed, would subject automobiles to needless damage and their
owners to financial loss.
In comments to NHTSA, we have joined with the other insurance
associations in protesting the proposed delay. Our joint comments
are attached, Exhibit A [See p. 76].
TITLE 11-AUTOMOBILE CONSUMER INFORMATION STUDY
Two years ago in similar oversight hearings, the alliance recom-
mended that serious consideration be given to the repeal of title II.
PAGENO="0067"
65
At that time it had already become evident that in spite of the very
best of will and cooperation by both the Department of Transporta-
tion and the insurance industry, little benefit coud be expectd to
flow from this title.
We believe that the additional information and knowledge devel-
oped since then has proven that our recommendation was a correct
one.
The purpose of this title was stated to be the development of a
comprehensive consumer information system which would allow
automobile buyers to compare the followig characteristics of passen-
ger cars by make and model:
a. damage susceptibility,
b. crashworthiness,
c. ease of diagnosis and repair.
In addition, this title required DOT to promulgate a regulation
directing automobile dealers to provide prospective automobile pur-
chasers with comparative insurance costs of various makes and
models.
Shortly after the enactment of Public Law 92-513. the insurance
industry established a representative all-insurance industry com-
mittee to fully cooperate with DOT in the implementation of this
title.
It soon became evident that DQT apparently thought insurance
companies' loss data could be used as the primary source of infor-
mation to judge make and model for the characteristics mentioned
above.
Just prior to the enactment of, Public Law 92-513, the insurance
industry was in the process of establishing th Highway Loss Data
Institute, HLDI, as a nonprofit organization to gather, process, and
provide the public and private sectors with expanded information
concerned with human and economic losses resulting from highway
crashes.
The industry offered to use HLDI as one source through which
DOT data needs could be met. However, it was soon recognized that
the information being captured by the industry through HLDT did
not truly reflect damageablity by make and model in the real word.
Let me explain.
The insurance industry pays automobile damage losses under two
separate coverages: collision and property damage liability. Prop-
erty damage liability losses are inaccurate reflections of
damageability. Hence, only collison losses paid to insureds repre-
sent actual losses incurred. However, collision losss tend to empha-
size front-end damages and ignore rear-end damages which are
usually paid as property damage liability claims.
As a result, DOT inquired whether more balanced loss informa-
tion might be secured from data contained in inusrance company
claims files. The industry did not think so but agreed to particpate
in a joint project to assess the availability of useful data from this
source. Accordingly, a limited review of the availablity of data from
claims files was conducted jointly by DOT and the insurance repre-
sentatives. This showed that less than 50 percent of the claims files
examined contained data needed to establish damageability or
crashworthiness characteristics.
PAGENO="0068"
66
Additionally, this study demonstrated the unreliability of gather-
ing data through manual claims file analysis.
In spite of the discouraging results of this initial claims file
analysis project, the industry cooperated with the Department of
Transportion and its contractor, General Electric, in a substan-
tially-expanded claim file study.
In its final report to DOT, General Electric stated:
"Even though a particular make/model may experience a higher
accident involvement, reflect a high injury rate, as well as high
damage in terms of cost to repair, it cannot be said that thse
adverse characteristics are soley a function of the car itself. The
type of driver-high or low risk-and driving environment to which
the vehicle is exposed-rural, urban, time of day, weather, geo-
graphic location, et cetera-are factors which influence a vehicles's
record and must therefore be considered."
While General Electric tried to develop methodologies to account
for such nonvehicle factors, it found, however, that:
"Available data have not permitted adjustments for many of
these factors in the demonstration analysis."
GE went on to say that:
"Although differences between make/models of cars were found
in all three areas of concern, the magnitudes of the differences were
small. These small differences may have a negligible influence on
the consumer."
Mr. Chairman, the combined experience under title II by the
insurance industry, the Department of Transportation and DOT's
contractors has shown that tools are not presently available to
forecast the damageability or crashworthiness characteristics of
new cars during the better part of their initial model year.
These characteristcs can, however, be identified after these new
cars have generated enough loss data of their own, but this takes
time. Presently HLDI is in fact collecting these data and has
extracted from them a wealth of information. These data indicate
that there are considerable differences in damageability by body
styles and market classes and, most importantly, that full size cars
have a better loss experience that smaller models.
More recently, HLDI started collecting some injury data from
losses paid under personal injury protection-no-fault-and medical
pay coverages. These data indicate that occupants of small cars run
a much greater risk of being killed or injured in a crash than
occupants of large cars.
Thus, the HLDI find that occupants of small cars face a double
risk-their vehicles are more likely to sustain damage and offer less
protection against injury than larger vehicles.
This is valuable information. For instance, it shows that we can
expect more damage and injuries as our national energy require-
ments force substantial decreases in average car sizes unless small-
er cars are built with better damage protection and equipped with
better occupant protection, such as airbags.
But this information comes to us after the introducton of the
new makes and models. It takes approximately a year before
enough data are accumulated for analysis. These data are not
PAGENO="0069"
67
representative of all crash situations. They do not reflect all crash
losses.
Nevertheless, we are optimistic that eventually the industry may
find a way to use these data in their rates. One large company has
already started a plan which will reflect some of the collision
experience for some cars. Other companies may follow this lead. In
any case, the rest of the industry will be carefully monitoring this
experiment.
We submit, Mr. Chairman, that the voluntary efforts of the
industry in the marketplace are an effective substitute for title II.
When Congress enacted the Motàr Vehicle Information and Cost
Savings Act, it declared its objective to be to reduce the economic
loss resulting from damage to passenger motor vehicles involved in
motor vehicle accidents. Our companies wholeheartedly support
that objection.
We believe, however, that title :11 Has not and wil not achieve
that objective.
We suggest that title II has served its usefulness and there should
be no further allocation of resources devoted to it.
While we acknowledge that the efforts devoted to its implementa-
tion have provided valuable experience in determining which con-
sumer information system would or would not work, we do not
believe that spending additional private and public funds for any
further implementation of title II would be in the public interest.
[Mr. Maisonpierre's prepared stat~ment and attachments follow:]
PAGENO="0070"
68
Statement of the
AMERICAN MUTUAL INSURANCE ALLIANCE
My name is Andre Maisonpierre. I am a vice president of
the American Mutual Insurance Alliance. We are the major
national association of mutual property and casualty insurance
companies. Our members provide automobile insurance coverage
for both personal and commercial vehicle owners in all fifty states
and the District of Columbia.
We appreciate the opportunity to appear before this sub-
committee to present our views on the implementation of the
Motor Vehicle Information and Cost Savings Act of 1972 (PL 92-513).
The purposes of PL 92-513 are to promote competition among motor
vehicle manufacturers in the design and production of safe
motor vehicles and to reduce the cost of automobile ownership
and maintenance to consumers. These objectives are to be
achieved by improving the quality of automobiles and, by attempting
to develop consumer information systems which will facilitate con-
sumers' market choice.
Our testimony today will assess Title I - Bumper Standards
and Title II - Automobile Consumer Information Study as related
to the Act's stated objectives.
TITLE I - BUMPER STANDARDS
The Alliance is disappointed by the lack of effective action
in the area of bumper standards. A brief look at the history of
bumper standards will illustrate some of the causes of our dis-
content.
Title I requires the National Highway Traffic Safety
Administration (NHTSA) to develop new bumper standards for
passenger cars which would limit property damage caused by low
PAGENO="0071"
69
speed collisions and provide tithe maximum feasible reduction
of cost to the public and to the consumer
Prior to the Act, NHTSA could only set safety-related
standards. This had been done in Federal Motor Vehicle Safety
Standards No. 215, still the only bumper standard in effect,
which prohibits damage to safety-related parts such as radiators
and breaklines in low speed impacts.
In August 1973, NHTSA proposed a property damage bumper
standard, which would also incorporate the current federal
safety standard on bumpers, to be effective with 1975 models.
In a series of subsequent rule making actions, the proposed
effective date was repeatedly delayed. Finally, in March 1976,
NHTSA adopted, a final rule, n~aking the property damage stan-
dard effective for 1979 models with more stringent requirements
going into effect for 1980 models.
In March of this year, NHTSA has proposed yet another
delay in its standard limiting property damage to cars in most
speed crashes. In response to requests from General Motors and
Ford Motor Company, the agency is proposing to delay for one
year the effective date of the more stringent second phase of
its standard. NHTSA has proposed the delay even though the
auto makers already have been given more than three model years,
since adoption of the standard in March 1976, to prepare for the
1980 model year bumper requirements.
Actually, Mr. Chairman, this lack of effective Federal
action is what we feared six years ago when we testified
PAGENO="0072"
70
on the bills which eventually led to the enactment of Title I.
At that time there had already been some state action requiring
auto manufacturers to provide better auto bumpers. California
had enacted a law requirIng that cars sold after September 1, 1973,
be equipped with bumpers capable of sustaining a 5-mph impact
without appreciable property damage to the front or rear of the
vehicle. Maryland, Florida, Georgia, North Carolina and
Minnesota had enacted similar legislation.
Our concern was that the Federal bill would preempt these
enacted state laws and either set standards below existing
state programs or stop any further state action while the
applicable federal standard was being developed.
This is exactly what has happened.
Despite the inclusion of a "grandfather" clause for
existing state laws, the enactment of Title I forestalled any
enforcement action by these states. Apparently states were
wooed, as we were, into the false belief that the required
national standard would be forthcoming shortly with federal en-
forcement. Unfortunately, this has not occurred.
Mr. Chairman, the Alliance believes that the interests
of the consumer have been ill-served by this lack of effective
action. Any further delay in the implementation of the bumper
standards, as is proposed, would subject automobiles to need-
less damage and their owners to financial loss.
In comments to NHTSA, we have joined with the other
PAGENO="0073"
71~
insurance associations in protesting the proposed delay.
Our joint comments are attached (Exhibit A).
TITLE II - AUTOMOBILE CONSUMER INFORMATION STUDY
Two years ago in similar oversight hearings, the Alliance
recommended that serious consideration be given to the repeal
of Title II. At that tine, it had already become evident that
in spite of the very best of will and cooperation by both the
Department of Transportation and the insurance industry, little
benefit could be expected to flow from this Title. We believe
that the additional information and~ knowledge developed since
then has proven that our recommendation was a correct one.
The purpose of this Title was stated to be the development
of a comprehensive consumer information system which would
allow automobile buyers to compare the following characteristics
of passenger cars by make and model:
a. Damage Susceptability
b. Crashworthiness
c. Ease of Diagnosis and Repair
In addition, this Title required DOT to promulgate a
regulation directing automobile dealers to provide prospective
automobile purchasers with comparative insurance costs of
various makes and models.
Shortly after the enactment of PL 92-513, the insurance
industry established a representative all-insurance industry
committee to fully cooperate with DOT in the implementation of
this Title.
PAGENO="0074"
72
it soon became evident that DOT apparently thought in-
surance companies' loss data could be used as the primary
source of information to judge make and model for the charac-
teristics mentioned above.
Just prior to the enactment of PL 92-513, the insurance
industry was in the process of establishing the Highway
Loss Data Institute (HLDI) as a non-profit organization to
gather, process and provide the public and private sectors
with expanded-information concerned with human and economic
losses resulting from highway crashes.
The industry offered to use HLDI as one source through
which DOT data needs could be met. However, it was soon
recognized that the information being captured by the industry
did not truly reflect damageability by make and model in the
real world. Let me explain.
The insurance industry pays automobile damage losses
under two separate coverages: collision and property damage
liability. Property damage liability losses are inaccurate
reflections of damageability. Hence, only collision losses
paid to insureds represent actual losses incurred.
However, collision losses tend to emphasize front-end damages
and ignore rear-end damages which are usually paid as property
damage liability claims.
As a result, DOT inquired whether more balanced loss in-
formation might be secured from data contained in insurance
company claims files. The industry did not think so but
PAGENO="0075"
73
agreed to participate in a joint project to assess the
availability of useful data from this source. Accordingly, a
limited review of the availability of data from claims files
was conducted jointly by DOT and the insurance representatives.
This showed that less than 50% of the claims files examined
contained data needed to establish dámageability or crash-
worthiness characteristics. Additionally, this study demon-
strated the unreliability of gathering data through manual
claims file analysis.
In spite of the discouraging results of this initial
claims file analysis project, the industry cooperated with the
Department of Transportation and its contractor, General Electric,
in a substantially expanded claim file study.
In its final report to DOT, General Electric stated:
though a particular make/model may ex-
perience a higher accident involvement,
reflect a high injury rate, as well as high
damage in terms of cost to repair, it can not
be said that these adverse characteristics are
solely a function of the~car itself. The type
of driver (high or low risk) and driving en-
vironruent to which the vehicle is exposed (rural,
urban, time of day, weather, geographic location,
etc.) are factors which influence a vehicle's
record and must therefore be considered."
And while General Electric tried to develop methodol-
ogies to account for such mom-vehicle factors, it found, however,
that:
"available data have not permitted adjustments for
many of these factors in the demonstration analysis."
GE went onto say that:
- "although differences between make/models of
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74
cars were found in all three areas of
concern, the magnitudes of the
differences were small. These small
differences may have a negligible
influence on the consumer.'
Mr. Chairman, the combined experience under Title II by
the insurance industry, the Department of Transportation and
DOT's contractors has shown that tools are not presently
available to forecast the damageability or crashworthiness
characteristics of new cars during the better part of their
initial model year.
These characteristics can, however, be identified
after these new cars have generated enough loss data of their
own. But, this takes time. Presently HLDI is in fact
collecting these data and has extracted from them a wealth
of information. These data indicate that there are considerable
differences in damageabiljty by body styles and market classes
and, most importantly, that full size cars have a better loss
experience than smaller models.
More recently, HLDI started collecting some injury data
from losses paid under personal injury protection (no-fault)
and medical pay coverages. These data indicate that occupants
of small cars run a much greater risk of being killed or
injured in a crash than occupants of large cars.
Thus, the HLDI data find that occupants of small cars
face a double risk - their vehicles are more likely to sustain
damage, and offer less protection against injury than larger
vehicles.
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75
This is valuable information. For instance, it shows
that we can expect nore damage and injuries as our national
energy requirements force substantial decreases in average
car sizes unless smaller cars are built with better damage
protection and equipped with better :occupant protection
such as airbags.
But this information cones to us after the introduction
of the new makes and models. It takes approximately a year
before enough data are accumulated for analysis. These data
are not representative of all crash situations. They do not
reflect all crash losses.
Nevertheless, we are optimistic that eventually the
industry nay find a way to use these data in their rates.
One large company has already started a plan which will reflect
some of the collision experience for some cars. Other
companies may follow this lead. In any case, the rest of the
industry will be carefully monitoring this experiment.
We submit, Mr. Chairman, that the voluntary efforts of
the industry in the marketplace are an effective substitute
for Title II.
When Congress enacted the Motor Vehicle Information and
Cost Savings Act, it declared its objective to be "to reduce
the economic loss resulting from damage to passenger motor
vehicles involved in motor vehicle accidents." Our companies
wholeheartedly support that objective. We believe, however,
that Title II has not and will riot achieve that objective.
We suggest that Title II has served its usefulness and
there should be no further allocation of resources devoted
to it. While we acknowledge that the efforts devoted to
its implementation have provided valuable experience in
determining which consumer information system would or would
not work, we do not believe that spending additional private
and public funds for any further implementation of Title II
would be in the public interest.
PAGENO="0078"
76
Exhibit A
MOTOR VEHICLE SAFETY AND DAMAGE STANDARDS
Commentary on the Proposed Amendments to Bumper Requirements
49 CFR Parts 571, 581, Docket Nos. 74-11; 73-19; Notice 13; 10
Submitted On Behalf Of:
American Insurance Association (AlA)
American Mutual Insurance Alliance (AMIA)
National Association of Independent Insurers (NAIl)
National Association of Mutual Insurance Companies (NAMIC)
The interests of the american consumer would be ill-served by the
NHTSA's proposal to delay the effective date of its 1980 standard
for limiting property damage to cars in low-speed crashes.
We have reached the above firm conclusion on the basis of the following
considerations:
1. In the Motor Vehicle Information and Cast Savings Act of 1972,
Congress directed the Department of Transportation to set
effective standards for reducing designed-in damage in low-
speed auto crashes, Thus, the auto manufacturers will have
had eight years "lead time" by 1980 to develop improved
bumper designs.
2. In February of 1976, NHTSA issued a minimal property damage
bumper standard that limits costly damage to the vehicle in 5
M.P.H. crashes, effective in stages for the 1979 and 1980
models. NHTSA has indicated that "most cars already come
close to meeting the performance level specified foi~ September 1,
1978, Thus, major redesign to conform to the initial requirements
would probably not be necessary. `1
3. Probably the most important point of all, we observe that the
auto manufacturers are now in the process of re-designing their
cars to meet future energy requirements. From their own
statements, the car of tomorrow must be smaller and lighter
than today's highway population. The Highway Loss Data Institute's
1. Federal Register, Vol. 42, No. 37, Dated February 24~ 1977
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77
research reports, based on real-world experience on the
highway, clen~onst rate that sniall cars are more Ir t~qut'nUy
and more severely damaged than large vehicles. This being
the casc', an increase in the small car population as a result
of national energy policy will have an~adverse impact on the
consumer and on the national economy unless substantial
improvements are made in vehicle damageability.
4. Instead of delaying the 1980 implementation of the current
standard, NHTSA would best serve the interests of consumers
by retaining the 1980 effective date and by embarking immediately
on additional proposed rule-making for the yea1~s beyond.
NF~TSA research already has demonstrated the feasibility of
vehicle damage standards calling for, improved damageability
characteristics at higher crash speeds than todayts minimal
standard.
Any further delay in the implementation of the bumper standards,
as is proposed, would subject automobiles to needless damage and
their owners to financial loss. The technology needed to comply with
the bumper standards was available in 1972, the year of the "Motor
Vehicle Information and Cost Savings Act." Even better technology
is available today, making it feasible to move beyond the minimal
crash speeds specified in standards adoptçd in February 1976.
21-335 0 - 78 - 6
PAGENO="0080"
78
National Association _______ of Independent Insure rs
2600 RiVER ROAD, DES PLAINES, ILLINOIS 60018
312/297-7600
Arihur C. Mertz, President
May 5, 1977
Honorable Bob Eckhardt
Chairman, Consumer Protection &
Finance Subcommittee
U.S. House of Representatives
Washington, DC 20515
Dear Mr. Chairman:
The National Association of Independent Insurers has a long
and continuing interest in both motor vehicle safety and
darnageability. Therefore, we are pleased at the opportunity
to join the American Mutual Insurance Alliance in urging
prompt implementation of bumper standards under Title .1 and
in ending the allocation of resources to Title II of the
Motor Vehicle Information and Cost Savings Act.
NAIl is a trade association of more than 600 property and -
casualty insurance companies, ranging in size from the
smallest one-state companies to the very largest national -
writers. They are comprised of both stock and non-stock
corporations. They reflect all forms of merchandising --
independent agency, exclusive agency, and direct writers.
They include insurers which serve a general market and those
which specialize in serving particular consumer groups such
as farmers, teachers, government employees, military personnel,
and truckers.
Sincerely
Arthur C. Mertz
President
PAGENO="0081"
70
Thank you very much, Mr. Chairman.
Mr. ECKHARDT. You disagree with the assumptions of the capabil-
ity of the insurance industry to provide information under title II of
the act relating to differences in damageability, crashworthiness
and the ease of diagnosis and repair~ of automobiles. This I gather is
largely because of the fact that claims are categorized as either
collision or property damage and the latter includes extraneous
information, as you referred to it.
Mr. MAISONPIERRE. This is one of the reasons.
Mr. ECKHARDT. In what way precisely is this information not
useful? I mean, if it's available, and it is, can't it be weighted to give
useful information?
Mr. MAISONPIERRE. Property damage liability settlements, Mr.
Chairman, do not reflect the true damage to the car or the true
costs of repairing the car.
Since liability concept is involved in the settlement of those
claims, and quite often the settlement of these claims involve
compromises, the exact nature of the true damages are remote and
not reflected in the company files. Hence, these figures are likely to
understate what the true damages in an automobile accident will
be.
Mr. ECKHARDT. To understate them.
Mr. MAISONPIERRE. Yes, because property damage liability settle-
ments are a compromise, so they will understate the actual damage.
Mr. ECKHARDT. I see. So most of the recovery is in personal injury
and perhaps a personal injury recovery in a small accident may
greatly exceed actual personal injury, but may be used to repair the
car.
Mr. MAISONPIERRE. Either that, Mr. Chairman, or if we had a
collision involving no personal injuries, but a questionable liability
claim, the property damage liability claim will be compromised and
will not be paid in full.
Mr. ECKHARDT. I understand that, and of course, there is no
question but that there is a slippage between the information that
you receive and what the actual repair cost is, but how about a
comparison between makes and models? Wouldn't errors be in the
same magnitude and would not, therefore, information of this type
give you at least some comparative relationship between crash
worthiness of different makes and models?
For instance, you have people driving Chryslers; they are not
more litiguous with respect to their personal injury claims than
people driving Chevrolets. There may be errors involved, but
wouldn't the comparison still be useful?
Mr. MAISONPIERRE.. It probably would give some rough idea, Mr.
Chairman. Again, however, we have to recognize it takes a consider-
able amount of lead time to be able to capture enough information
to be able to measure. As I said in our statement, it takes approxi-
mately 1 year before a model year performance can be analyzed,
and by that time the public has just about bought all of the cars
which are going to be manufactured by the auto manufacturers.
So this is the lead time necessary to gather real world experience,
and it is a very troublesome factor, since we have to establisn rates
on a prospective base.
PAGENO="0082"
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Mr. ECKHARDT. How is your argument here not always applicable
to information gathered by the Highway Loss Data Institute? I
think you feel that the Highway Loss Data Institute is something
that has been useful.
Mr. MAISONPIERRE. I indicate, Mr. Chairman, it is providing us
with valuable information. It has not as yet been used in the real
world for insurance rating, pricing purposes.
One company at this time is looking into the feasibility of using
the Highway Loss Data Institute material as a tool to develop rates
for certain model cars.
Mr. ECKHARDT. Is that Allstate?
Mr. MAISONPIERRE. This is Allstate, sir; that is correct.
Mr. ECKHARDT. We had asked them to come to the hearing, but
they have declined, and we would like to look into that question.
Mr. MAISONPIERRE. I might mention this is still in the develop-
ment stage.
Mr. ECKHARDT. However, let us assume for a moment that the
information gathered by the Highway Loss Data Institute may not
be useful with repect to establishing precise levels of insurance
coverage. Nevertheless, may it not be useful in obtaining certain
information concerning a relationship between auto design and cost
of repair?
Mr. MAISONPIERRE. Very much so, sir, and this is why we are
saying we think the efforts of the private sector, the industry,
through the insurance industry, has really replaced the need for
title II.
Mr. ECKHARDT. You are saying this is a good thng, if it's done by
industry and it is sufficient. But if the compilation of information is
done through the Federal agency, it would not be useful, because it
is already being done. What I am suggesting is that the Highway
Loss Data Institute has the same problems with respect to utilizing
and digesting information as would exist in connection with the
Federal agency.
Mr. MAISONPIERRE. This is right. Here they will have the same
problem in establishing differences between make and models on a
prospective base, prior to the issuance of the model year.
Mr. ECKHARDT. But Mr. O'Neill said a moment ago that there was
a remarkable continuity of rate of damageability amongst auto-
mobiles over several model years, that you could see patterns
within certain makes and models that were not frequently altered.
Mr. MAISONPIERRE. There is a relationship between make and
model. If one were to assume that a manufacturer were to substan-
tially change some basic characteristics of the make and model, we
could not assume than that the relationship which existed in the
past will necessarily exist in the future.
Mr. ECKHARDT. I think that is true, and if one were to estabish
rates on that basis, there would be some flaw in that procedure. At
least there would conceivably be such. But let me touch on another
question.
Mr. MAISONNPIERCE. Let me make one additional observation, Mr.
Chairman. As Mr. O'Neill has indicated, the information secured
through HLDI is receiving wide distribution and, of course, the
Department of Transportation is receiving all of the materials
PAGENO="0083"
81,
relevant to the HLDI data. There is no reason why the Department
of Transportation could not use the HLDI data for its own purposes
in establishing and publicizing for its own purposes what it believes
to be differences by make and mOdel.
Mr. ECKHARDT. That is one thing I really do criticize the Depart-
ment for not doing. They have information available presently, and
they are called upon under the act to utilize that information, and
so as far as I know very little money has been expended for the
purpose of putting into effect the, provisions of title II.
I remember when we drafted title II I felt we didn't envisage as
any major purpose the determination of actual rates as the result of
this data, but rather some impelling influence on the automobile
manufacturer who over a good number of years showed a bad
record with respect to cost of repair of a vehicle.
For instance, not to make his automobile in such a way that, if
you had a bump on the front fender, it would translate to the top,
as we saw in one of the films a mOment ago: or to not manufacture
his automobile with a curve in the bumper that would actually
itself do damage to the fender. Things of this nature, if revealed
over a period of time, even though they might not be too useful
either in establishing premium costs with respect to that models,
nor with respect to advising the customer as to the current model,
might nevertheless impel the manufacturer to improve those
defects.
That seemed to me to be a very desirable purpose of the title, and
I still don't see how that purpose has been in any way impugned by
your testimony.
Mr. MAISONPIERRE. I agree with you, Mr. Chairman, that it was
our feeling that this was really the objective of the title. It was
primarily to attempt to influence the marketplace, influence people
in their purchasing decisions.
Mr. ECKHARDT. Also influence the manufacturer in meeting the
demands of the marketplace.
Mr. MAISONPIERRE. That is cOrrect, sir.
The Department of Transportation, on the other hand, seemed to
have interpreted its mandate differently, and this is the reason the
Department tried so hard in the development, in its development of
title II to attempting to establish on a prospective base what
ranking should be given for eaáh model and make of automobiles.
We believe that at this stage the data needs to implement the
program whch you are contemplating and which you have just
stated; the data needs are available. They are available through
HLDI and they are being made available to the Department of
Transportation, to the auto manufacturers, and to the public at
large.
Mr. ECKHARDT. You do think, then, that DOT should do a study of
the information whch is already available?
Mr. MAISONPIERRE. I think, Mr. Chairman, DOT should make use
of the information presently available, and should not attempt to
develop different or new systems, since we already have the tools at
hand.
Mr. ECKHARDT. I think your testimony might lead us to reconsider
the specificity of title II, but it would still seem to me that the
PAGENO="0084"
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purpose of title ii in formalizing data and in bringing it through
some official agency that may not be considered to have a bias in
favor of a particular manufacturer, or in favor of one industry as
against another, is advantageous. Perhaps we are too specific in
that section; perhaps we should state goals, and permit obtaining of
data as a result of rules promulgated by the agency.
What would you think about that?
Mr. MAISONPIERRE. I would think that the Department of Trans-
portation should be encouraged to use available data wherever
possible.
Mr. ECKHARDT. You have been talking somewhat in terms of
repealing title II. I am suggesting that title II has a useful function
in requiring DOT to utilize data in the field, and without title II
there is no congressional mandate to do so.
In fact, it seems to me that DOT has pretty much ignored the
mandate of title II up to the present time by not using the data in
the field that is being developed by the industry.
Mr. MAISONPIERRE. I would suggest, Mr. Chairman, that DOT has
misinterpreted its mandate, and our proposal or our suggestion to
repeal title II is based on `the present conception of the mandate
which DOT has as to what it should do with title II.
Mr. ECKHARDT. We believe strongly that DOT should make every
effort to use whatever information is available to alert the purchas-
ing public to provide information to the purchasing public,
particulary today, in light of the drive toward smaller cars, as to
what is and what is not a good buy. I have always thught of that as
the major mandate of title II. Perhaps we need to look at it further.
Mr. MAISONPIERRE. I believe so, sir.
Mr. ECKHARDT. Thank you.
Mrs. Foldes, do you have anything?
Mrs. FOLDES. No, Mr. Chairman.
Mr. ECKHARDT. Title II also has another purpose besides that of
advising consumers, it seems to me. That is giving DOT a reach to
receive information obtained through the insurance industry that
might be useful in further implementing the law.
For instance, title I deals with bumper standards. Perhaps that is
a very inadequate kind of standard. That may be a very limited
standard that should be further enlarged. Have we done everything
necessary to try to insulate the door from damage as a result of
bending the fender, danger that one of those films would indicate?
If we could obtain other information from the insurance industry,
we might be better equipped to know what is effective or what is
desirable with respect to safety and damage reduction standards.
Would you not feel that that is another purpose and another
reason why Title II might be useful?
Mr. MAISONPIERRE. Precisely, Mr. Chairman; this is the reason
why the industry estabished what we call an all-industry committee
representing all types and size of companies of to work with DOT in
attempting to develop data systems which would provide DOT with
more information useful in the development of standards, in the
development of Title II. We worked very closely both with DOT and
DOT's contractor, General Electric.
We tried different approaches. As it turned out, there were only
two sources of information whch DOT thought ultimately might be
PAGENO="0085"
83
of some use. One was HLDI which has already been mentioned. The
other one was the statistical organization known as the Insurance
Services Office, whch gathers a lot of data and statistics for the
insurance industry.
Both the Insurance Services Office and HLDI in conjunction with
General Electric and DOT established a model data gathering
system to assist DOT In capturing information which DOT thought
might be useful in the development of title II. As it has turned out,
DOT, through General Electir, felt that the information being
captured was really not of substantial use to it.
However, let me emphasize the fact that DOT was considering
prospective use of this information. But again, we have continued to
operate through HLDI. We have broadened the base of HLDI, and
as I said before, we have made this information available to DOT,
and we have advised DOT on a cOntinuing base that the informa-
tion from the industry continues to be available.
Mr. ECKHARDT. Mr. Maisonpierre, your testimony has been, as
usual, thoughtful and useful to the subcommittee, and we thank
you.
Mr. MAISONPIERRE. Thank you very much, sir.
Mr. ECKHARDT. I understand Mr. Schroer and Mr. Noettl have
planes to catch, and I will take you a little out of order at this time
if that will convenience you.
Mr. Schroer, please?
STATEMENT OF BERNARD J. SCHROER, PH. D., ACTING DIRECTOR,
JOHNSON ENVIRONMENTAL AND ENERGY CENTER, UNIVER-
SITY OF ALABAMA IN HUNTSVILLE, ACCOMPANIED BY JOSEPH
F. PETERS, STAFF MEMBER AND PROJECT DIRECTOR OF AUTO
CHECK
Mr. SCHROER. Mr. Chairman, I am the Acting Director of the
Johnson Environmental and Energy Center.
To my immediate right is Mr. Joseph Peters, who is a member of
the Center staff, and also projeét director of auto check.
I have been asked to testify on the findings and the benefits of
our program.
The Alabama Motor Vehicle Diagnostic Inspection Demonstration
project, which we call Auto Check, is one of five similar projects
estabilshed by the Department of Transportation National Highway
Traffic Safety Administration under the provisins of Title III of the
Motor Vehicle Information and Cost Savings Act, Public Law 92-
513. Auto Check is conducted by the University of Alabama in
Hunsville for the Alabama Office of Highway and Traffic S afety.
The original Federal grant was for $2,750,249 which was matched
by State funds of $305,584 for a total of $3,055,833.
The grant was awarded on October 15, 1974. Automobile inspec-
tions began on March 19, 1975. Since then, 18,000 vehicles have
received 30,000 inspections under three separate projects: The origi-
nal demonstration project under Public Law 92-513; a University
funded period of June 1, 1976 to December 31, 1976; and the project
extension funded by Public Law 94-364 from January 1, 1976 to
date.
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The University inspection period was funded by an appropriation
of $108,000 from the University's general fund. No Federal funds
were expended on automobile inspections during this period.
The current project, beginning January 1, 1977, was authorized
by Public Law 94-364 and by a grant of $225,000 from DOT and
$121,7717 from the State of Alabama. Inspections under this exten-
sion will cease on September 30, 1977.
It is improtant to realize that our contract with NHTSA was to
only collect data and to forward these data to NHTSA's data
processing contractor. Our initial contract did not include any
analyses of the data. The original project and the extension were
designed by DOT to determine if the motorist could obtain neces-
sary repairs at a lower cost if provided with specific or diagnostic
inspectin data.
Half of the motorists received diagnostic inspection results. The
other half received generalized results typical of a State vehicle
inspection. After the automobile was was repaired it was again
ispected to determine if the repairs had been properly accom-
plished. Repair cost data fuel and maintenance data were also
requested from the motorists.
The results from the original project were reported in the Final
Report, dated October 1, 1976. I would like to submit the executive
summary of this report for the record.
Mr. ECKHARDT. How long is that?
Mr. SCHROER. I think it's 10 pages.
Mr. ECKHARDT. Without objection, it will be admitted to the
record at this point [see p. 90].
Mr. SCHROER. Thank you.
Basically, we reported on the seven major items mentioned in
title III of Public Law 92-513. In our opinion, diagnostic inspections
are potentially cost effective. That is, the potential savings to the
consumer are equal to or greater than the cost.
There are several aspects of the Auto Check project which I feel
make it unique. First, the facility has been designed, constructed
and equipped solely to support the demonstration program. The
facility is easily accessible to the public by being on the university
campus. The facility has specially constructed waiting rooms for
educating the motorist during his wait, including a 30-seat mini-
theater and private rooms for interaction between the counselors
and motorists.
A second unique aspect is that the project is supported by a staff
of highly trained automotive specialists. The Chrysler Huntsville
Electronics Division provides technical support personnel under
contract to the university. These engineering specialists were re-
sponsible for training inspectors, maintaining and calibrating equip-
ment, quality control of all data, and for general engineering
support. As a result, the Auto Check project was able to provide the
most accurate and meaningful data than any of the five projects.
A third unique aspect is that the project had the foresight to
maintain its own computerized data base for storing all inspection
results. As a result of several study contracts with DOT, the data
base has been expanded to include motorist repair costs, accident
records from the Alabama Department of Public Safety, and the
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vehicle registrations from the County Vehicle Registration Depart-
ment. This data base provides Auto Check with the capabilities for
not only storing additional data, but for conducting a variety of
consumer-related studies.
The results of the Auto Check inspections indicated that:
93 percent of the cars had at least an item failure on their first
inspection;
34 percent failed brakes;
31 percent failed emissions
26 percent failed wheel alignment;
10 percent failed suspension;
2 percent failed steering;
These failures were reduced significantly on the second 6 months
inspection.
I might make a note here: The State of Alabama does not have a
mandatory inspection law.
The automotive repair industry; in Alabama has demonstrated
the capability to repair deficiencies found by a diagnostic inspec-
tion. The incidents of unsatisfactry repairs has decreased with the
age of the project indicating that the consumer and repair industry
are learning to work with the system. The availability to the
consumer of an idependent inspeôtion facility which makes after-
repair inspections to certify the c rrectness of the repairs has been
effective in reducing unsatisfactory as well as unnecessary repairs.
Most Vehicle-In-Use standards were found to be adequate. The
test criteria for brakes system integrity were found to be too
fatiguing for personnel involved in high-volume inspections. As a
result of adjustment was made to the test criteria. The Original
Equipment Manufacturer's specification for wheel alignment were
found to be much too strict for practical vehicle safety inspection.
Consequently, the Motor Vehicle Manufacturers Association specifi-
cations were found to be preferable. The road wheel shake test was
found to be inadequate to identify all unsafe steering linkages.
Minor changes to this test procedure corrected the problem.
Vehicle designs did not pose any serious problems for the inspec-
tors. There was no significant ~; interface problems between the
vehicles and the inspection equipment.
It was not possible for Auto Check to explore the standardization
of diagnostic systems and test equipment because the number of
inspections required that the equipment be identical. Auto Check
has three inspection lanes, each with identical equipment. This
equipment allowed Auto Check to inspect 106 items on a car in 40
minutes. The counseling after the inspection and the administrative
tasks extended the total time a consumer was in the facility to 1
hour.
The design of the Auto Check facility was found to be adequate
and efficient. Each lane has the capacity of inspecting 76 vehicles
per 8-hour shift or 228 for all three lanes. Since participation in
Auto Check was voluntary, as Alabama does ot have a mandatory
vehicle inspection law, the maximum capacity was never tested.
However, during 1 day 76 vehicles were processed through one lane
in an 8-hour shift.
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Auto Check used University students as inspectors. These inspec-
tors were part time employees working nly four hours a day. We
believe that students make excellent diagnostic inspectors after a
brief 2-week training period.
During the inspection period funded by the university we found
that the consumer was willing to pay for the inspection. Surveys by
an outside organization show that most were willing to pay $10 to
$15 for an inspection.
Because of judicious management of th funds, the university was
able to provide several significant analyses to DOT that were
beyond the scope of the original agreement and at no additional cost
to the Government.
All of these studies resulted from unsolicited proposals made by
the university and approved by DOT. Only one study required
committing additional funds of $58,225 to the project. The total
value of these additinal tasks was close to $300,000, or 10 percent of
the original grant.
These additional tasks were:
Effects of Auto Check on accident rates;
Effects of Auto Check on vehicle repair costs;
A number of consumer related studies of the Auto Check Project.
The university was awarded additional funding from NHTSA to
evaluate the effects that Auto Check has had on the accident rate
in the Hunstville area. The procedure was to compare the accident
rate of the Auto Check vehicles with the accident rates of the
uninspected vehicles. The Auto Check sample consisted of 7,750
cars. The uninspected sample consisted of 33,758 cars. These cars
were involved in 3,019 accidents in the county for a 13-month period
beginning in April 1975. I would like to briefly highlight the results:
First, the Auto Check cars had 12 percent fewer accidents than
the uninspected cars. This difference is after the data were adjusted
for sex, age and income. We were unable to isolate the reason for
this accident rate reduction other than the possibility that the Auto
Check participants are more careful drivers or that the vehicles
were safer.
Second, our results indicate that 53 percent of the Auto Check
cars which were involved in accidents were driven by females. This
is the complete opposite of the national statistics that indicate
males are ivolved in 71 percent of the accidents. As a result of this
difference, we looked at the drivers of the Auto Check cars the year
before the opening of Auto Check. We found that 55 percent of
these drivers were males. This difference suggests that the principal
driver of the Auto Check vehicle changed after it was inspected. For
example, the husband lets his wife or daughter drive the car after it
was inspected.
A third result is that by comparing the Auto Check participant
with the driver in the accident, we found that the person who
brings the car for the Auto Check inspection is probably not tne
principal driver. In most cases, the married middle-age male
brought the car to Auto Check but he was not the principal driver.
The exceptions are the single female and single male.
Fourth, the results indicated that an unexpectedly high accident
rate for middle-aged females. This may be due to the large number
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of mothers picking up their children after school. I should note that
Huntsville has a minimal transportation system.
A fifth result which we were unable to validate is that the older
uninspected cars had a higher accident rate than the older in-
spected cars. This suggests a dependency of the accident rate on the
car's mechanical condition.
I might make a note that this study was only conducted on 1968
through 1973 cars.
The University also received NHTSA approval to evaluate the
vehicle repair costs of Auto Check participants. A total of 3,567
repair actions associated with the engine, brake, alignment, suspen-
sion, and steering systems were analyzed. These repair actions
represented $76,532 in repairs to 2,062 vehicles. Each repair action
was categorized as being a required repair-that is it failed the
Auto Check inspection-a recommended repair, an optioinal repair,
or an unnecessary repair.
I would like to summarize the results of this study:
First, 24 percent of all repair actions were unnecessary, that is
repairs to non failed items. Also, 32~ of every dollar was spent on
unnecessary repairs.
Second, 36 percent of the suspension, 30 percent of the engine, 24
percent of the brake, and 9 percent of the alignment repair actions
were unnecessary.
Third, 28 percent of tire dealer, 27 percent of service station, 26
percent of chain stores, 24 percent of car dealer, 24 percent of
independent garage, and 19 percent of owner repairs were
unnecessary.
Fourth, the unnecessary repair~ rate was significantly higher for
female than male participants, 27 versus 24 percent.
Fifth, females also spent statistically more for unnecessary re-
pairs than males-38 cents versus 30 cents.
Sixth, the unnecessary repair rate was the same-24 percent-for
both the control and diagnostic groups.
The most significant finding of the study is that there appears to
be a learning function operating during the lifetime of the Auto
Check project. A substantial decrease was noticed over time in the
rate and cost of unnecessary repairs. In 13 months the rate of
unnecessary brake repairs decreased 30 percent. The rate of unnec-
essary engine repairs decreased 50 percent.
This learning effect could be a result of improved communication
between Auto Check, the consumer, and the repair shop. Or, this
learning effect could be a result of better understanding by the
repair shops of the Auto Check Inspection Form. A third factor
could be a change in the attitudes and practices of the repair
industry.
Our estimates are that the consumer who had his car inspected at
Auto Check is saving, on the average, $2 in unnecessary brake
repairs and $3 in unnecessary: engine repairs.
Consumer Aspects of the Auto Check Project.
A number of consumer-related studies were also approved by
NHTSA and are discussed in detail in our final report.
I would like to briefly summarize the findings of one of these
studies. This study consisted of interviewing Auto Check partici-
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pants in an attempt to identify how they would relay our inspection
results to the repair industry.
The results were:
The more items that fail in the inspection the greater the change
that the motorist will give improper repair instructions to the
repair shop.
The more items that fail in the inspection the greater the chance
that the motorist will not show the inspection form to the repair
shop.
These results indicate that even though the consumer has the
detail inspection results he still may have unsatisfactory or unnec-
essary repairs done. The problem is to get the consumer to use the
inspection results. The interviews indicated that the main areas of
consumer confusion and potential improper repair appears to be
engine repairs and brake repairs.
AREA5 OF ADDITIONAL STUDY
The primary thrust by NHTSA on the title III demonstration
program has been at providing data relevant to the actual inspec-
tion process, especially in the areas of diagnostic equipment design
and reliability and facility efficiency and operation. Significant data
have been collected to address these areas.
It is our opinion that two things must be done before any
meaningful conclusions can be reached. First, very little analyses
have been done by NHTSA on the data from the five projects. The
only exception is the several studies that we have conducted at
Auto Check. Additional studies should be made to completely ana-
lyze already collected data, especially regarding the consumer
aspects.
Some of the analysis which should be done on the existing data
are:
1. Vehicle outage rates should be computed by critical system
component and mileage. Here the American Association of Motor
Vehicle Manufacturers has expressed an interest to us for these
data.
2. Unsatisfactory repairs should be analyzed. These results should
be compared with other facilities such as the AAA facility in
Missouri.
3. Emissions of cars with catalytic converters should be analyzed.
Here the auto manufacturers and the Motor Vehicle Manufacturers
Association have expressed an interest to us in* this area.
4. More detailed analyses of repair costs should be done. Here the
Federal Trade Commission has expressed an interest.
5. The extent to which the method of mechanic payment has on
unnecessary repairs should be analyzed.
6. The extent to which the certification of mechanics has on
unnecessary repairs should be analyzed.
7. The inspection results should be compared with NHTSA's
vehicle defect and recall information.
8. The analysis of what is the optimum time between inspections
should be made.
9. The evaluation of consumer acceptance of Auto Check should
be analyzed. We are currently asking all motorists to complete a
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questionnaire upon enrolling and after returning for repair
inspection.
Second, it is our opinion that there are a number of relating
factors which must also be addressed before terminating the demon-
stration program. Most of these factors are consumer-related and
are most critical before considering national mandatory inspection
legislation.
I would like to briefly describe several of these factors. One is the
consumer interface with the inspection facility. Our studies have
shown that too much diagnostic information can be given the
consumer. Experiments must be conducted to reduce this problem.
For example, one experiment that we are doing is the use of
prescription form similar to the doctor's prescription where we
attempt to prioritize those safety-related items requiring immediate
attention.
A second factor which must be addressed is the consumer interac-
tion with the repair shop. The consumer should be armed with the
necessary information to effectively communicate with the me-
chanic. Equally important, the consumer should be convinced to
actually relay this information to the mechanic. Our studies have
shown that many of the consumers do not use the forms and do not
tell the shops the results of the inspection or the items which failed.
Experiments must be conducted addressing this problem.
Many billions of dollars are spent each year replacing good
automotive parts. Many parts are replaced in the name of preventa-
tive maintenance or overall economy. Information about the
lifetimes of commonly replaced parts could significantly reduce the
cost of unnecessary repairs, save the country's resources, and re-
duce energy consumption. Experiments must be conducted address-
ing this problem.
One area of public education would be the publication and dis-
semination of the lifetimes of expendable automotive components.
Discrepancies exist in the lifetimes of these products. For example,
a major manufacturer of spark plugs recommends replacement
every 10,000 miles. However, General Motors recommends replace-
ment every 22,500 miles on its :new cars.
From our studies we believe that a large percentage of spark
plugs, shock absorbers, and air filters are being replaced with many
miles of useful service still remaining. One would expect that the
averge life of a car would increase or the depreciation rate would
decrease in a diagnostic inspection program. The Auto Check period
of operation has not been long enough to determine if these factors
do exist.
The performance of the automotive repair process depends on
three factors: the mechanical condition of the vehicle and the
quality of the diagnostic inspection, the knowledge of the person
doing the repair, and the unconscious desire of the repairer to take
advantage of the consumer (avarice). NHTSA has been primarily
addressing the first factor, the mechanical condition of the car and
the diagnostic inspection. Of more importance to the consumer,
especially in terms of unnecessary and unsatisfactory repairs, are
the knowledge of the person doing the repair and the unconscious
desire of the repair shop to take advantage. Experiments must be
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conducted addressing this problem. Our studies have shown that 24
percent of all repairs are unnecessary. This amounts to 32 percent
of the total repair bill.
We have submitted proposals to NHTSA addressing these prob-
lems. To solve these problems we feel that additional inspections
are required and that the demonstration program be extended for a
minimum of 2 years to further investigate consumer benefits. Fol-
low-on inspections must include new models with their design
changes and innovations. The learning process for the repair indus-
try and the consumer must be allowed to continue until it stabilizes.
This is most critical to assure meaningful information for the
Congress.
[The following material was received for the record:]
LXECUTIVE SUMMARY
FINAL REPORT
ALABAMA MOTOR VEHICLE DIAGNOSTIC
INSPECTION DEMONSTRATION PROJECT /
"AUTO. CHECK" /
Prepared For
Department of Transportation
National Highway Traffic Safety Administration
Prepared By
Auto Check Staff
* ofthe
Center for Environmental and Energy Studies
THE UNIVERSITY OF ALABAMA IN HUNTSVILLE
P. 0. BOX 1247
HUNTSVILLE, ALABAMA 35807
-Contract Number DOT-HS-5-O1O56
October 1, 1976
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II. EXECUTIVE SUMMARY
A. Program Background and Objectives
The Alabama Motor Vehicle Diagnostic Inspection Demonstra-
tion Project, known locally as Auto Check, was established
by Cooperative Agreement DOT-HS-5-01056 dated October 29,
1974 under the provisions of Title III of the Motor Vehicle
Information and Cost Savings Act, Public Law 92-513 This
demonstration project was one of five such projects estab-
lished by the Department ofTransportation. The project
was administered by the Governor's Coordinator, Office
of Highway and Traffic Safety, (OHTS) and assigned to The
University of Alabama in Huntsville with technical support
provided by a team from the Chrysler Huntsville Electronics
Division (CHED).
B. Goals and Objectives
1. The primary goal in the overall project design was to
provide for effective accumulation of data to deter-
mine if a national diagnostic motor vehicle inspection
program would be cost effective in the sense that
public benefits would exceed the program costs. The
stated purpose was to obtain data in the following
seven areas:
o The relative costs and benefits of the project.
o The capability of the motor vehicle repair industry
to correct diagnosed deficiencies or malfunctions
and the cost of such repairs.
- o Vehicle-in-use standards and feasible reject levels.
o The efficiency of facility designs employed.
o The degree of standardization of diagnostic systems
and test equipment.
o The development of diagnostic testing equipment
* designed to maximize the interchangeability and
interface capability of test equipment and vehicle's.
o Vehicle designs which facilitate or hinder inspec-
tion and repair.
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2. Project Objectives
o To design and build an efficient diagnostic inspection
facility.
o To develop and implement a public awareness program
encompassing the project's benefits, purposes, and
goals.
o To devise and implement a data collection, recording,
and storage plan.
o To develop and implement a participant recruitment
and education program which would assist in meeting
project goals; such as, repair cost determination,
accumulation of maintenance and operational data
and periodic return inspection requirements.
o To develop and implement a participant counseling and
retention program.
o To develop and implement a project management informa-
tion system which included the entire inspection
record so that records could be maintained and
special studies could be performed.
o To develop and implement a quality control program.
o To coordinate with the Alabama Department of Consumer
Protection and Air Pollution Control Commission.
C. CoeTnunity Description
The city of Huntsville and Madison County comprise the third
largest metropolitan area in Alabama with a population just
under 200,000. The 1975 Madison County vehicle registration
list indicated that there were 90,500 passenger vehicles, of
which 48,500 were eligible for the Auto Check inspection.
There is no statewide Periodic Motor Vehicle Inspection (PMVI)
in Alabama. In January 1976, the state Tire Safety Law
went into effect. In October 1975, Redstone Arsenal required
that all vehicles obtaining permits to operate on the arsenal
had to pass a vehicle inspection.
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0. Work Accomplishment Summary
*The time of the grant (Cooperative Agreement) and the urgency
to start inspecting vehicles in, order to acquire sufficient
data dictated the use of a temporary inspection facility.
The first vehicle inspections occurred on February 28, 1975,
approximately 120 days after the grant award. The official
opening inspection day was on March 19, 1975.
The permanent facility, a one story brick structure, was com-
pleted in October 1975. The project maintained the quality and
quantity of data acquired during the transition period. The
vehicle inspection equipment was moved one lane at a time to
avoid any impact on production~
Auto Check perceived that diagnostic automobile inspections
- could be accomplished with personnel not trained in automobile
mechanics. Therefore, the project had a majority of students
as vehicle inspectors supervised by skilled automotive mechanics.
The initial training consisted of classroom and diagnostic
equipment training with subsequent training based on critical
areas determined through the project's .quality control program.
It was proven that this type of training can be utilized
to select personnel to work in a state directed. diagnostic
inspection program. This information on inspector qualifica-
tions is considered unique and valuable output of the Alabama
project.
The quality control plan had three major divisions: error
prevention, error detection, and data collection and analysis.
Daily audits functioned to verify that data ~enerated was
valid.
1. Vehicle Processing
The diagnostic and control automobile inspections were
identical; only the information transmitted to the partici-
pant was different.
The vehicle was left at the entrance of the facility.
Inspection of 16 subsystems covering over 100 separate
items was accomplished. -
2. Participant Counseling
The participants were divided equally into a diagnostic and
a control group for the demonstration of the value of diagnos-
tic information. Each participant was counseled about the
21-335 0 - 78 - 7
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inspection results. The diagnostic group received all
the inspection data. The control group received contlensed
(simplified) inspection data. This technique permitted the
creation of two levels of information transfer retaining
one level of inspection data from all vehicles for vise in
the project data bank.
Participants returning for an after-repair inspection
provided the counselor with. specific repair cost informa-
tion. The participant was counseled on the quality of
repairs as determined by the inspection.
3. Methods for Attraction and Retention of Participants
Alabama did not have a mandatory motor vehicle inspection
law. Therefore, Auto Check was dependent upon volunteer
public participation which was encouraged by mass media
advertising, personal contact, incentive programs, and
retention procedures.
Public response was gratifying in that approximately 28%
of the eligible vehicles in the area were inspected at
least once at Auto Check.
Retention practices were given much emphasis to encourage
participants to return for a second periodic inspection.
Methods were continually developed to retain more people
in the program. The most effective retention methods were
personalized letters and telephone calls.
E. Sumary of Results and Project Impact
1. Inspection Results
During the period of performance, Auto Check accomplished
24,748 inspections on 15,269 vehicles (28% of the 48,500
vehicles eligible). Second periodic inspections totaled
3,869 and third periodic inspections totaled 305. After-
repair inspections totaled 5,305.
After-repair inspection failure rates for the diagnostic
group were significantly lower than the corresponding
rates for the control group, indicating that a higher
quality of repair occurred when diagnostic information
was available. In addition, the after-repair inspection
failure rate decreased between the first and second
periodic inspection periods, implying that both the
repair industry and the public were learning how to
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use the diagnostic information more effectively. The
extent of this time related learning process has not been
fully ascertained.
2. Cost and Benefits
The cost of a diagnostic inspection has been estimated to
be $15.00 per inspection by a UAH economics professor
who assumed near optimum operating conditions (720 inspec-
tions per week).
Balancing these cost to the consumer are the following
observed or potential benefits of diagnostic inspection:
o Reduced overmaintenance of engine ignition systems
o Improved gas mileage
o Reduced cost of repairs
o Increased quality of repairs
o Improved tire life due to proper wheel alignment
o Improved vehicle safety with a corresponding reduction
in accident rates - over 85 percent of the vehicles
in this area have safety related defects.
3. Facility Efficiency
The Auto Check Facility design allowed a sustainable
vehicle inspection production rate of 76 vehicles per day
per lane (228 per day total). The maximum rate attained
was 92 vehicles per lane per day.
4. Vehicle-In-Use (VIU) Standards
Certain Vehicle-In-Use (VIU) standards were felt to be in
need of modification because:
o The brake system integrity test was too fatiguing
for the inspection personnel.
o The brake system dynamic tests should use a failure
criteria of 30 percent imbalance to avoid spurious
brake system rejections.
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o The precise Original Equipment Manufacturers (OEM)
specifications for wheel alignment were much too
strict for practical vehicle safety inspection. The
more tolerant Motor Vehicle Manufacturers Association
(MVMA) specifications were preferable.
o The road wheel shake test was not adequate to identify
all vehicles with unsafe steering linkages.
When the preceeding minor changes were made the VIU
standards, reject levels were quite satisfactory.
5. Vehicle Designs and Equipment Interface Compatability
Some minor vehicle design characteristics that positively
or negatively impacted the inspection process were noted.
The most significant design that hindered inspection were
the splash shields on disc brakes that made brake lining
inspection impossible.
6. Project Impact
o Repairs accomplished for diagnostic group participants
were more successful than for control groups. -
o Quality of repairs for both groups increased between
repetitive inspection cycles (six months apart).
o Cost of repairs decreased between repetitive cycle.
o Compatible working relationships developed between the
local repair industry and the project.
Repair prices, in most cases, appeared reasonable for
what was repaired but in many cases more items were
repaired than those which were found to be faulty. How-
ever, much of the `over repair" or additional repair
could be considered prudent.
7. Consumer Awareness and Automotive Maintenance Practices
o 28 percent of the available vehicles were enrolled
in the program.
o 80 percent of the participants found the inspection
very helpful.
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o A significant fraction of the participants would not
give the inspection form to the repair facility.
Data acquired shows that the public probably over-
maintains vehicles in the area of engine ignition system.
However, 83 percent of the vehicles inspected had their
carburetors adjusted to a richer idle mixture ratio than
the vehicle manufacturers recommended.
8. Special Studies
Eighteen special studies were performed to understand
facets of the program that were not anticipated at the
initiation of the program. Highlights of some of these
studies indicated that:
o Published repair industry brake cylinder repair
practices deviate critically from the recommendations
published by the automobile manufacturers.
o The number of items found to need repair on a partici-
pant's vehicle affected hisdecision to get the repairs
made and the probability of getting these faults
repaired properly.
o The most misunderstood areas of the vehicle on the
part of the participant were the engine and the brake
systems.
o The primary reasons for a participant not returning
were that he did not understand all that was required
of him or that the vehicle faults were so minor that
he felt that an after-repair diagnostic inspection
was unnecessary.
F. Recommended Program Improvements & Potential Future Applications
The recommendations or suggestions for similar future projects
may vary considerably depending on whether the future opera-
tion is to be an experimental demonstration program following
the original National Highway Traffic Safety Administration
(NHTSA) program guidelines or a state directed pilot diagnostic
* project. Therefore, information for both types of future
* projects is presented.
1. Program Feasibility
The feasibility of future motor vehicle diagnostic inspec-
tion projects was partially demonstrated by the Alabama
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project. There were many positive indications that
public diagnostic vehicle inspection was both desirable
and potentially cost-effective. This situation may be
briefly surii~arized as follows:
o Over.90% of the vehicles failed one or more items
on initial inspection.
o Over 35% of the vehicles failed critical safety items
inspected (tires, wheels, and brakes).
o Voluntary public part~ :ipation resulted in the enroll-
ment of 28% of the eligible vehicles.
o The local repair industry failed to male satisfactory
repairs in 16% of their attempts.
These results indicate that the motor vehicle population
was not maintained in good mechanical condition; there
was considerable public interest in diagnostic inspection;
and the repair industry needed to be monitored to improve
the quality of their work. If the diagnostic inspections
could save 25% of the money spent on unnecessary vehicle
repairs an annual average saving of $25 per automobile
would be achieved. The cost of a typical commercial inspec-
tion is $25. Since a state-directed mandatory inspection
should be less costly, the potential future cost-effective-
ness in repair/maintenance savings alone appears attractive.
Cost-benefit values for other categories such as extended
vehicle life aid improved trade-in value require more
time than was available to this project.
2. Program Implementation
If the subject future program were an extension of one
or more of the original NHTSA-managed demonstration
programs, the program should continue to be Federally
financed because the primary goal of such programs would
be information acquisition. The future program or
extension would continue to require consumer input from
the public as well as technical data. In order to secure
maximum participation, the inspection should continue
to be provided at no cost and be voluntary. The NHTSA
"control" group should be discontinued.
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If the future diagnostic inspection project were to
be a state directed operation intended for eventual
state-wide application, participation should be manda-
tory and costs assigned as part of the license fee.
As indicated earlier the inspection cost is anticipated
to be less than $25. `The actual amOunt will vary.
according to the extent of the inspection and the utiliza-
tion of the facility. Operation should be for more than'
40 hours per week including evenings and Saturdays.
In order forá. future program to be s~iccessful~ repair
of critical safety items such as wheels, tires, and brakes
should be mandatory but repair of the rest of inspected
items should be optional. Auto Check participants demon-
strated a marked preference to repair those vehicle
deficiencies that they felt were most important. This
approach recognizes a difference between safety and
optional consumer benefits.
3. Project Staffing
To continue an experimental demonstration project produc-
tive,.flexible and innovative staff members would be
needed. If a regular state mandatory inspection program
were planned, the concept of a scientific data acqui-
sition project would change to that of routine inspection.
Therefore, the project director post could be filled by a
person whose experience was in managing routine state
operations involving regular public interface, scheduling,
and office management. A person experienced in automotive
technology would be needed as a site supervisor, or, if
it were a small facility, as the project director. It
would be likely that the other positions could be filled
by proper selection of existing state job descriptions.
4. Equipment and Facility Design
The equipment selection and arrangement of the Alabama
project was proven satisfactory; high throughput capability
was demonstrated and all but minor bottlenecks at individual
stations were eliminated. .
If a state-directed mandatory inspection project were
planned, the equipment selection and arrangement would
depend on the space available (existing facilities) and
the items to be inspected. If it were assumed that anew
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facility would be built and similar inspections accomplish-
ed, the equipment used should be similar to that at Auto
Check.
5. Project/Participant Interface
For a follow-on type program, Alabama would continue
the proven methods of participant recruitment and inter-
face. Elimination of the `control" category and accepting
later model vehicles would improve the interface. Counselors
would provide "prescriptions" priortizing recommended repair
actions on a safety basis. If a state funded program were
planned, some counseling would be advisable. This should
be done by Certified General Mechanics, identified as
such to the public to gain their confidence in the inspec-
tion reports and subsequent advice.
6. Project/Repair-Industry Interface
In order to effectively continue an inspection demonstra-
tion type project, or a state directed project, the repair
industry interface must be improved. A free 10-hour
orientation course given at the project to repair mechanics
is recommended.
Service managers and shop owners should get project
reports showing areas of high repair failure and/or
disputed failure criteria. Some of these interface
problems could then be resolved by mutual agreement.
7. Participant/Repair-Industry Interface
The improved data transfer to the participant and the utili-
zation of prescription prioritizing recommended repair action
will provide confidence in the inspection results. It is
recommended that additional effort be placed on educating the
participant to transmit these inspection results to the
repair industry. Both the participant and the repair
industry should be urged to report any apparent problem
to the project. This effort, combined with the additional
education recommended for the repair industry, will result
in additional benefits to the consumer.
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G. Major Conclusions
1. A major requirement for the success of future diagnostic
type PMVI centers is recognition of the importance of
the interface between the diagnostic center and the
public. An information transfer system must be developed
that considers the public philosophy on the importance of
automotive repairs. If this were done, public confidence
in and use of diagnostic PMVI services would improve
and be more acceptable to the public.
2. There appear to be no major technical barriers to
functional implementation of diagnostic automobile
inspection for the general public.
3. The cost of some of the current types of diagnostic
equipment makes it impractical for general use in the
automobile repair industry. In addition, there are
maintenance and calibration problems.
4. Preliminary cost projections indicate that a similar
inspection to those now provided commercially at $25
can be provided at a lesser~cost, perhaps $15, in a
public inspection facility.
5. The optimum design of future PMVI facilities should
include consideration of these key features of the
Alabama project.
(a) A facility design that permits near-optimum use
of inspection equipment through proper manning
of inspection stations and minimization of bottle-
necks to vehicle throughput.
(b) The staffing and operational plan that uses a
combination of supervision, training, and quality
assurance to permit the effective use of inspectors
not trained in automobile mechanics.
(c) A computerized data bank and library of special
project studies thatprovide a comprehensive
insight of inspection statistics, participant
characteristics, and other information that would
be invaluable to diagnostic project design.
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UAH REPORT NUMBER 195
A COMPARISON OF THE ACCIDENT RATES
OF AUTO CHECK VEHICLES VERSUS
UN INSPECTED VEH I CLES
Prepared for
Department of Transportation
National Highway Traffic Safety Administration
Prepared by
Bernard J. Schroer
William F. Peyton
Auto Check Staff
Center for Environmental and Energy Studies*
The University of Alabama in Huntsville
P. 0. Box 12147
Huntsville, Alabama 35807
Contract No. DOT-HS-5-01O56 (Modification #14)
November 1, 1976
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EXECUTIVE SUMMARY
The accident rate of Huntsville vehicles inspected at the Alabama
automotive diagnostic inspection facility (Auto Check) was significantly
lower than the Huntsville vehicles not inspected at Auto Check. The
thirteen-month accident rates were:
Uninspected
Vehicles
%
Auto Check
Inspected
Vehicles
Percent
Reduction
Unadjusted
7.9145
Unadjusted
6.985
12
Adjusted for
Auto Check
Contamination
8.039
.
Adjusted for
sex and
age
6.839
.
15
.
-
Adjusted for
sex, age and
ZIP
7.067
12
The above adjustments indicate that the Auto Check sample had a
relatively higher percentage of drivers in the high accident prone sex!
age groups and a relatively lower percentage of drivers from the sections
of the city with higher accident rates than the uninspected sample.
A number of statistical tests were conducted to determine if the
Auto Check sample and the uninspected sample possessed similar character-
istics. These tests included comparisons of driver age, occupation, ZIP
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code, and vehicle age. The results of these tests are:
o No significant difference was found in the age
distributions of male and female drivers of inspected
vehicles involved in accidents and the age distributions
of male *and female drivers of uninspected vehicles
involved in accidents.
However, a significant difference was found in the
age distributions of the drivers of inspected vehicles
involved in accidents and the age distributions of
the drivers of these vehicles the year before being
inspected by Auto Check. This difference suggests
that either the principle driver of the inspected
vehicle changed after being inspected, such as the
husband now lettinci the wife drive the vehicle, or that
a large percentage of the Auto Check vehicles were
purchased just prior to being inspected.
o No significant difference was found in the occupations
of male and female drivers of the inspected vehicles
involved in -accidents and the occupations of male
and female drivers of the uninspected vehicles
involved in accidents.
o No significant difference was found in the contributing
circumstances surrounding the accidents of inspected
vehicles and the circumstances surrounding the accidents
of uninspected vehicles.
o No significant difference was found in the distribution
of accidents by vehicle year for the inspected and
uninspected vehicles involved in ~accidents.
o A significant difference was found in the distribution
of accidents by driver ZIP codes for the inspected
and uninspected vehicles involved in accidents.
o No significant difference was found in the comparison
of accident rates for the control and experimental
groups within the Auto Check program.
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105
in addition to the above statistical inferences, no difference was
noticed in the defects observed in the vehicle equipment at the time
of the accident for the inspect~d and uninspected vehicles.
A comparison of the Auto Check participant with the driver involved
in an accident indicates that the person bringing the car to Auto Check
for the first periodic inspection is probably not the principal driver.
There are several exceptions. if a single male or female brings the
car to Auto Check, he or she, respectively, is probably the principal
driver. if a married female brings the car to Auto Check, she also is
likely to be the principal driver, but not as likely as had she been single.
The national statistics indicate that males are involved in 71
percent of the accidents. The City of Huntsville statistics indicate
that males are involved in 66 percent of" the accidents. However, for
the Auto Check sample, males were involved in only 147 percent of the
accidents while for the uninspected sample males were involved in 56
percent of the accidents. An analysis of Auto Check vehicles involved
in accidents the year before being inspected by Auto Check indicated
that males were involved in 55 percent of the accidents. These results,
suggest that females may be the principal drivers of 1968 through 1973
vehicles inspected by Auto Check.
The accident rates for the various Huntsville ZIP codes indicate
that those areas typified by a higher education and income have lower
accident rates than the less educated. `poorer areas. In addition, many
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of those areas of higher education and income appear to have a greater
accident rate reduction after having their vehicles inspected which
suggests that the individuals in those areas were more willing or able
to have their vehicles repaired.
Within the 1968 through 1973 vehicle model years the data suggest
that older, uninspected vehicles are more likely to be involved in
an accident. However, for the inspected vehicles, the older vehicles
are less likely to be involved in an accident. Although no statistical
inferences were made, these data suggest a strong dependency of the
accident rate on vehicle mechanical condition.
An anomoly in the accident rate for the 1968 model year suggests
that there is likely to be a hierarchy in the age of vehicle driven
by each member of a household in multi-car families. The newest
vehicle may be driven by the male head-of-household while the second
newest vehicle may be driven by his wife. The oldest vehicle is
likely to be driven by his son or to be resold.
An unexpectedly high accident rate was observed for middle-aged
females. A review of accident rates for time of day, day of month
and month of year strongly indicates that this high accident rate
may be due to the large numbers of these middle-aged females that
are on the road after they have picked up their school children (The
local public transportation system transpdrts only a small percentage
of the school children.). A traffic survey performed during this
high accident rate period indicated that the middle-aged females are
an inordinately hi~gh percentage of the drivers during this critical
period. - -
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UAH REPORT NUMBER 197
AN EVALUATION OF VEHICLE REPAIR COSTS
FOR AUTO CHECK PARTICIPANTS
Prepared for
Department of Transportation
National Highway Traffic Safety Administration
Prepared by
Auto Check Staff
Center for Environmental and Energy Studies
The University of Alabama in Huntsville
P. 0. Box 12~47
Huntsville, Alabama 35807
Contract No. DOT-HS-5-O1O56
February 1, 1977
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EXECUTIVE SUMMARY
A total of 3,567 repair actions associated with the engine, brake,
alignment, suspension, and steering systems were analyzed from the data
collected by the Auto Check automotive diagnostic facility. These repair
actions represented $76,532 in repairs to 2,062 vehicles. Each repair
action was categorized as being a required repair based on the results
of the Auto Check inspection, a recommended repair, an optional repair,
or an unnecessary repair.
The most significant result of this study was the detection of a
substantial decrease in the rates and costs of unnecessary repairs
during the lifetime of the Auto Check program. This decrease may be
attributed to the local repair industry learning to adapt to the Auto
Check inspection process. During the lifetime of the program, the rate
of unnecessary brake repairs decreased from 32 percent to 22 percent.
The rate of unnecessary engine repairs decreased from 41 percent to
22 percent. Likewise, the amount of the participant's dollar spent
on unnecessary brake repairs decreased from 40 cents to 20 cents.
Also, the amount spent on unnecessary engine repairs decreased from
59 cents to 19 cents.
The following observations are averages for the entire lifetime of
the Auto Check project:
o 24 percent of all repair actions were unnecessary.
o 32 cents of every dollar was spent on unnecessary repairs.
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o At the system level, 36 percent of the suspension, 30
percent of the engine, 24 percent of the brake, and
9 percent of the alignment repair actions were unnecessary.
o By repair facility, 28 percent of tire dealer, 27
percent of service station, 26 percent of chain, 24
percent of car dealer, 24 percent of independent
garage, and 19 percent of owner repairs were unnecessary.
o At the system level, 39 cents of every dollar spent for
engine, 39 cents of every dollar spent for suspension,
31 cents of every dollar spent for brake, and 9 cents
of every dollar spent for alignment repairs were
unnecessary.
o By repair facility, 38 cents of every dollar spent at
service stations, 37 cents of every dollar at car dealers,
36 cents of every dollar at chains, 35 cents of every
dollar at tire dealers, 34 cents of every dollar at
independent garages, and 17 cents of every dollar the
owner spent repairing the vehicle himself were unnecessary.
o 33 cents of every dollar the control group spent.
for repairs and 31 cents of every dollar the diagnostic
group spent for repairs was unnecessary (not
statistically significant).
o The unnecessary repair rate was significantly higher
for female than male participants (27 versus 24 percent).
o Females also spent statistically more for unnecessary
repairs than males (38 versus 30 cents).
o The unnecessary repair rate was the same (24 percent)
for both the control and diagnostic groups.
The detailed statistical analyses of engine repairs indicated
that:
o Thirty-nine cents of the repair dollar for engine
repairs was unnecessary.
21-335 0 - 78 - 8
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110
o Uninformed females spent more on unnecessary engine
repairs than on legitimate repairs. ~lowever, informed
females had comparable unnecessary repair costs to
that for the informed males.
o Hales performing their own engine repairs had a
significant lower unnecessary repair rate than those
males who had their repairs made commercially (21
percent versus 314 percent).
o Both males and females in the diagnostic group had a
lower unnecessary repair rate than the control group.
However, this difference was not significant and can be
primarily attributed to the independent repair shops
having a much lower unnecessary repair rate for the
diagnostic group (30 percent versus 142 percent for the
control group).
o The females in the control group had a significantly
higher percentage of unnecessary repair in excess of
$140.00 as compared with the other groups. This suggests
that the uninformed female having the vehicle's engine
repaired is likely to have an excessive repair bill
since she is less able to interface with the repair
facility on an intelligent level. On the other hand, if
the female has information suggesting that she could
verify the repair shop's conclusion, she is not as
likely to have an excessive repair bill.
The detailed statistical analyses of brake repairs indicated
that:
o Females had a significantly higher rate of unnecessary
repairs than males (29 versus 23 percent).
o Tire dealers had a significantly higher rate of
unnecessary repairs than the other repair facilities
(38 versus 25 percent).
o Owners performing their own repairs had a significantly
lower rate of unnecessary repairs than the com~rcial
facilities (16 versus 25 percent). Also, 74 percent
more owners performed their own repairs when they were
given diagnostic information.
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Summary of Evaluation of Participant Interfaces
1. The early participant profile indicated that maximum
cooperation was obtained from qdddle-aged males
owning full-size AMC products. The minimum cooperation
was obtained from youthful drivers owning (driving)
sporty GM vehicles (Camero, etc.).
2. After the initiation of television advertising, a
shift in the participant profile occurred wherein
more youthful drivers entered the program.
~3. Telephone solicitation reminding participants to
return for a repair or second periodic inspection
had a 44 percent success rate for repair inspections
and a 53 percent success rate for second periodic
inspections. Because the telephone solicitations were
made after the effected participants had not responded
voluntarily or to mailed letters, those individuals
making appointments subsequent to the telephone call
can be considered to be the "hard cases."
4. The primary reasons why participants did not return
were:
a. They felt that they had to have all repairs made,
b. They had not kept up-to-date records of maintenance,
c. Only minor items that did not require diagnostic
equipment needed attention.
5. The 25 dollar repair reimbursement to those hard-to-get
vehicles with critical repairs was very successful; 80
percent of those offered the incentive accepting it.
Personal letters to owners who had, so far, resisted
project efforts to enroll them had a 10 percent response.
6. ~`articipant education in the form of a slide presentation
was good; greater than half of the participants attended.
A static presentation was ineffective.
7. A problem exists in informing the public as to the
- proper repair instructions regarding- the engine and
brake systems. One third of the participants having
one or the other of these systems at fault did not
understand what should be done. -
PAGENO="0114"
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The interviews conducted simulating the participant/repair
industry interface indicated that:
1. The more items that are found wrong with a vehicle,
the more likely that not all items will be repaired.
2. The more items that are found wrong with a vehicle,
the less likely that the participant will use the
Inspection Form to communicate with the repair
industry.
3. The more items that are found wrong with a vehicle,
the more likely that the participant will use his
memory of the counseling session in communicating
with the repair industry.
4. The above effects were quite noticeable when four or
more items were found faulty on the vehicle. Because
27 percent of the vehicles have four or more faults,
their owners generally had trouble communicating with
the repair industry and they were more likely to
have an inadequate or faulty repair performed than
those drivers of vehicles with fewer faults.
The participants were also interviewed about their beliefs
regarding the interval allowed between engine tune-ups. The
Auto Check participants probably overmaintain their vehicles
in this respect.
Regardless of the capability of the participants in their
communication with the repair industry, the repair industry
has shown a capability of learning .in interpreting the Inspection
Form. This learning was reflected by lower costs and better
repairs for the treatment group during the latter stages of
the program.
Mr. ECKHARDT. In each of the areas for which information was to
be provided to the Secretary of Transportation under section 302(b)
of this act, what studies could be done from the information
contained in your computer bank?
Dr. SCHROER. If you remember my testimony, I included nine
areas that we think could be addressed using our data bank.
Mr. ECKHARDT. Yes.
Dr. SCHROER. I would be more than happy to repeat these. We
think, for example, the vehicle outage rates should be computed by
a critical system by component, by mileage. Unsatisfactory repairs
should be looked at. Emissions of cars with catalytic converters
should be analyzed. We think additional studies should be done on
the repair cost data, especially looking to dividing the repair cost,
comparing repair cost of, let's say, those mechanics that are certi-
fied against those mechanics that are not certified.
Mr. ECKHARDT. I recall your listing of them now, but I would like~
to ask you this: How many of those that DOT requested from you is
DOT doing on its own?
Dr. SCHROER. I think probably the administrator of NHTSA could
address that more correctly than I can.
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113
Mr. ECKHARDT. Perhaps you wouldn't know, but I wondered how
many has it requested of you.
Dr. SCHROER. Based on my knowledge, NHTSA has done very
little analysis of the existing data.
Mr. ECKHARDT. DOT itself has contracted out an analysis which
draws much less specific conclusions than yours, especially as
regards consumer benefits in the area of repair costs and reduc-
tions. Comparing the costs of treatment group participants and
control group participants, this analysis yields basically indetermi-
nate results. Yet your study of unnecessary repairs shows a dra-
matic reduction in both groups.
Could you please comment on the different methods employed in
these two analyses?
Dr. SCHROER. Yes, Mr. Chairman, The method that we used for
abstracting the repair cost data I think was probably significantly
different from the method used by the NHTSA support contractor
did their analysis. We used a team approach consisting of three
individuals. The first individual was a senior parts man, who had
considerable experience in the parts industry. The second man was
a senior mechanic person who had considerable experience in the
automotive repair areas. The third man was an automotive engi-
neer. We feel that by taking this approach we were able to define
the unnecessary repairs in much finer detail.
Mr. ECKHARDT. The specific procedures you employed that al-
lowed you to distinguish unnecessary repairs in various categories
from necessary repairs, what is the difference there?
Dr. SCHROER. The procedure that we used to categorize the
repairs again consisted of setting up a committee of four individ-
uals, a senior parts man, a senior mechanic, an automotive engi-
neer, and the a representative from NHTSA.
What we attempted to do for each of the critical five systems was
to develop a matrix where we could identify, given a particular
failed item in Auto Check, what ëorresponding items were required
replacement, which of those items may be replaced by, let's say, a
prudent repair shop, which of those items were in the gray area
which some repair shop practices recommend replacement and
some do not, and in the fourth category were those items which
were definitely unnecessary repairs. An unnecessary repair were
those items based on our inspection process which did not fail the
inspection.
Mr. ECKHARDT. How does your project's capability to retrieve
information compare with other projects with respect to the infor-
mation which the FTC is requesting?
Dr. SCHROER. The Alabama project is the only project which from
the beginning developed its own computer data base for storing
information. During the project we used this data base primarily for
managing the actual operation of the facility. The benefit of having
the data in the computer, in addition to managing the project, is
that these data are available for additional analysis. Based on my
information, I think Alabama: is the only project that has the
information in the computer.
Mr. ECKHARDT. Thank you very much, sir. I think this has been
most important testimony for our hearing.
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114
Dr. SCHROER. You are welcome.
Mr. ECKHARDT. We will take a 3-minute break at this time.
[Brief recess.]
Mr. ECKHARDT. The subcommittee will resume hearings.
Mr. John N. Noetti.
STATEMENT OF JOHN N. NOETTL, DIRECrOR, MEMBERSHIP
SERVICES, AUTOMOBILE CLUB OF MISSOURI
Mr. NOETTL. My name is John Noettle. I am director of Member-
ship Services for the Automobile Club of Missouri and a member of
the National Motor Vehicle Safety Advisory Council. I want to
thank the committee for the opportunity to testify on titles II and
III of the Motor Vehicle Information and Cost Savings Act.
I have testified before the House and Senate subcommittees on
the Motor Vehicle Information and Cost Savings Act on many
previous occasions and have described in detail the operation of the
diagnostic clinics of the Automobile Club of Missouri, along with
our experience on handling many operation and maintenance
problems.
I will now only briefly describe the operation of the clinics but
will be happy to answer any questions. I would like to present some
facts that I feel are relevant to the cost, safety, environment, and
energy problems related to the automobile. Specifically, I would like
to state how inspections can play an important role in meeting
many of the future goals in these areas.
To provide motorists of our area with an unbiased appraisal of
the condition of their cars, the Automobile Club of Missouri opened
its first automobile diagnostic inspection clinic in the fall of 1967 in
St. Louis. It occupies 10,000 square feet and is equipped with the
latest equipment for static and dynamic analysis. The clinic in-
spects all types of automobiles. In addition to the main lane, a
customer may requet a special component check for such items as
the engine, brake system, exhaust systems, and so forth. The clinic
staff neither repairs nor recommends any repair facilities.
The success of the St. Louis clinic prompted the opening of a
second clinic in Kansas City in the fall of 1974. Both clinics operate
under identical procedures and provide identical inspection
services.
The clinic inspection operation consists of four major parts. In the
first, original inspection, the automobile is gone over in detail and
the components on the automobile are graded according to criteria
designed to measure whether or not the components are performing
correctly, will go out in a short time, or are presently defective.
These three measurements of the components are described on
inspection forms and checked off as being either in column A for all
right, B for borderline, or C for critical and in need of immediate
attention.
This part of the inspection takes anywhere from an hour to an
hour and a half.
The second part of the inspection systems consists of an analysis
of the inspection report and the preparation of detailed repair
instructions. The customer of the clinic is never instructed, for
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115
example, to obtain a tune-up. He is specifically told what plug wires
are bad, if any, to set the timing, replace the points, or, specifically,
what needs to be done to put his car in top operating condition. If
the customer so elects, he may be counseled on his needed repairs
in addition to the written repair instructions. The counseling ses-
sion is designed to further clarify in the customer's mind the exact
condition of his automobile. He is also instructed as to what to
insist upon when he takes his car to be repaired.
The third part of the system is, completely independent of the
clinic. The customer selects a repair facility and presents the
original inspection form and a copy of the written repair instruc-
tions. If the repair facility has any questions about the inspection,
he may call the clinic for clarification.
After the repairs are performed, the fourth part of the inspection
system permits the customer to return to the clinic and for $1.00
have all the items rechecked for which he has repair receipts. The
clinic determines whether the repairs were done at all and whether
or not they were done-properly. Should there be a discrepancy, the
clinic will offer to resolve the matter between the customer and the
repair facility.
Since opening the first inspection clinic in the fall of 1967, we
have performed inspections in one form or another on more than
120,000 automobiles.
If we included our state inspection facilities, that would be closer
to 150,000 automobiles.
Our Diagnostic Clinic inspection system, characterized by thor-
oughness and objectivity, provides a unique opportunity for the
development of a comprehensive: information system to make the
collection of the recorded diagnestic data available in computer
compatible form. A few years ago the club designed and imple-
mented a computerized data collection system known as Auto-
motive Inspection Data for Economic and Safety (AIDES). This
system is capable of collecting data on a continuous basis from both
of the clinics providing a bank of unbiased information on the
condition of new and used cars of the area. Since over 500 items are
inspected on each automobile going through Main Lane inspections
and since the clinics are inspecting a total of nearly 70 automobiles
a day, the system generates an enormous amount of data which can
be used to analyze defects by make and model, to compare defects
and performance characteristics: of different makes and models, to
analyze trends, to zero in on specific component failure problems, to
assist in determining whether or not recalls should be made, and to
assist in the quality control of the diagnostic clinic inspections.
The data generated by our diagnostic clinics, to my knowledge, is
the only data available anywhere collected on a continuous basis,
that represents an unbiased appraisal of the condition of new and
used cars operating on the streets and highways. This is before the
demonstration projects were started.
In addition to this, the clinic collects data on the quality of repair
work through its recheck system. The uses of such data are limited
only by the imagination of those people wishing to find out the
actual facts of condition of automobiles in operation and the quality
PAGENO="0118"
116
of repair work turned out by the repair shops servicing cars that
use the clinic inspection system.
In addition to the minimum standards required for the employees
of the diagnostic clinic and the general training program operated
continuously throughout their employment, we engage an indepen-
dent organization to check on the quality of inspections made in our
clinics. This quality control program consists of running test cars
through the clinic and reporting on the quality and consistency of
the inspections. After each quality control car is inspected, a meet-
ing is held with the clinic staff to discuss any items that may have
been missed in the inspection and any inconsistencies that may
appear to be developing between one inspection and another. In
addition, as I mentioned earlier, the data program assists in the
quality control of the inspection by enabling trends of the inspec-
tion results on each of the individual parts and components to be
analyzed.
Thus, a comprehensive system of inspecting automobiles, provid-
ing the motorist with an unbiased appraisal of the condition of his
car, analyzing the quality of the repair work performed on his car,
and collecting data has been in successful operation for many years.
In my opinion, automobile inspections provide the only practical
means of determining the condition of the entire fleet and in
assisting the individual motorist in getting his car repaired eco-
nomically and correctly. New car standards will cover only a
maximum of 8 to 10 percent of the fleet for any 1 year that they are
implemented.
Using microprocessor, minicomputer, and communication system
technology, an inspection system could be designed to act as a giant
servo-mechanism. This mechanism, designed as sensitive as technol-
ogy would allow, could feed back information on the condition of in-
use automobiles to the manufacturers, and where appropriate, to
the regulatory agencies for the purpose of correcting and improving
the performance and efficiency of automobile components and sys-
tems. At the same time, information from this servo-mechanism
could aid the motorist in his effort to economically maintain and
operate his car.
The Safety Panel Report of the Task Force Report on Motor
Vehicle Goals Beyond 1980 discusses ways to improve vehicle han-
dling response, vehicle braking performance, vehicle lighting, visi-
bility, fuel economy, and advanced mechanical concepts for improv-
ing safety. All of these concepts will have little effect if the
hardware is not maintained properly.
In 1972, in remarks at a session of the First International Con-
gress on Automotive Safety in San Francisco, I said "automotive
maintenance and repair is a well publicized nightmare of frustra-
tion for the motorist"-at best. This applies to new and used
automobiles alike. The average motorist drives his car until he feels
something is wrong. In most cases, he has no idea what is wrong
and has a very difficult time in communicating his thoughts to the
dealer or repair facility. If he hears a noise in the engine, that is
exactly what he says. He doesn't say that he hears ignition ping due
to incorrect timing or advance setting. If he feels he has trouble
with the front end, he doesn't explain the specific problem he may
PAGENO="0119"
117
be having with the pitman arm, relay rods, balijoints, tie rod ends
or idler arms. The same applies to brakes, starting problems,
transmission problems, and so forth. And what about the present on
board diagnostic systems, the oil indicators, brake lights, engine
temperature lights, and guages. The engine temperature light can
indicate the need for repair of: a $5 sending unit, a $10 thermostat,
an $8 fan belt, a $55 water pump, or the replacement of a head
gasket for approximately $120. I mention this only as an example of
the large variation in the cost of repairs for which the motorist
must rely entirely on the advice from the repair facility personnel.
Society, therefore, hass developed a transportation system that, in
its present state, does not allow the motorist to have any practical
means whereby we can make decisions regarding the economic and
safe operation of the system.
An inspection system fits into: the scheme of things today by
providing a practical means to improve-for the entire fleet-safety,
fuel economy, and emissions, while at the same time reducing the
operation and maintenance costs for the individual motorist.
It is generally believed that mechanical failure directly contrib-
utes to only a small percentage Of all automobile accidents. As far
as I know, there is no hard evidence to the contrary. We are talking
about a minimum of 6 or 7 percent to as high as 15 or 18 percent of
all automobile accidents-and there can be all kinds of arguments
about these percentages. However, inspections do more than correct
mechanical deficiencies. Inspections can change or perhaps affect
the attitude of the driver about the operation and maintenance of
his automobile. A study of insurance claims of our policy holders
showed that those who used our :Diagnostic Clinics regularly had (1)
lower accident frequency and (2) less severe accidents. The average
cost per claim per clinic user was 35 percent less than for the
nonuser. The total cost per policy paid out in claims was 46 percent
less for the clinic user. Now this could be the result of a variety of
factors. However, there is good: reason to believe that drivers who
are concerned about the operation and maintenance of their auto-
mobile are more careful drivers, and there is also good reason to
believe that drivers can be made aware of the operation and
maintenance of their automobile through diagnostic inspections.
The motorist today is frustrated about the operation and mainte-
nance of his automobile since all he really understands is that to
keep it running in good condition costs him an arm and a leg. He is
distrustful of the manufacturer, he is distrustful of the dealer who
sells him the car, of the people who repair his car, of the oil
companies that provide him the fuel to run his car, and he is very
distrustful of the government and regulatory agencies that keep
adding more gadgetry about which he understands little. This
distrust did not happen overnight. It was a result of inadequate
system to assist the motorist in the operation and maintenance of
his automobile and inadequate communication on the purposes of
safety and emission regulatipns.
I believe that a motorist who has confidence in the system of
operating and maintaining his automobile will be a safer driver
than one who is not. The automobile plays such a major portion in
every individual's life, that, a lack of understanding of how to
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118
operate and maintain it poses a real danger to the person operating
it as well as to others. If people do not maintain their brakes they
are; (1) probably not too concerned about the stopping characteris-
tics of their automobile and (2) unable to deal with an emergency
situation that requires quick stopping. The same would be true
concerning the steering and handling components of the automobile
as well as the tires, exhaust system, lights, wipers, et cetera.
Now we can't expect everyone to know a lot about the technical
procedures for maintaining their automobile. People don't have the
time or the interest to get into the specific details. They have to
trust the system that is available to them for obtaining this mainte-
nance, and the system has to offer an economical benefit to them
for using it.
Inspections with a good repair program not only makes the driver
aware of his automobile, puts the automobile in better operating
condition and saves him money in the process, but it also has other
byproducts. A well-tuned engine reduces emissions considerably. A
report sent to the Regional EPA Administrators states that some of
the more important conclusions are as follows: (1) deterioration
from cars on the road is greater than we had previously expected;
(2) inspection and maintenance programs will, in a cost effective
manner, reduce pollutents from in-use vehicles; (3) the short test,
which we have now developed, can readily identify high polluting
vehicles; and, (4) most of these vehicles can be repaired at a
reasonable cost. Incidentally, it would seem to me, that inspections
are the only practical way to get an idea of the emission problem-
if there is one-for the entire fleet. I understand that the prelimi-
nary results of the diagnostic demonstration projects carried out by
the Department of Transportation also indicate that inspections do
indeed pay off both from an economic and safety standpoint for the
motorist.
While inspections provide the only practical means to evaluate
deterioration of the automobile's safety and emission control compo-
nents, they could also play an important part in determining
whether or not safety and emission control components of cars
involved in accidents were damaged and, if they were, whether or
not they are repaired correctly. It seems inconsistent to me to
constantly impose new standards for new cars and do very little
followup on measuring their effectiveness, their deterioration rate,
and the repairability should they be damaged.
I feel that inspections also provide the only practical means of
improving fuel consumption of the entire fleet of automobiles. A
well-tuned engine will use less fuel than one that is not well-tuned.
Most of the reports I have seen put this efficiency increase at a
minimum of 8 to 10 percent and at a maximum of 25 to 30 percent.
There have been a few reports from suppliers of spark plugs and
other automobile components that put the percentage much higher.
An unbiased inspection system could readily determine the truth. I
believe that a 15 to 20 percent improvement in fuel efficiency of
well-tuned, well-maintained automobiles could be expected. In addi-
tion to saving fuel due to the engine operating within its design
specifications, the detection and repair of fuel system leaks that are
prevailant throughout the entire fuel systems would result in
PAGENO="0121"
119
additional fuel savings. What makes this so attractive is that a well-
designed inspection repair system can readily identify these prob-
lems on the entire fleet of automobiles. It also can get these
deficiencies corrected at a nominal cost, thereby making it
attractive to people of all income brackets.
The fuel efficiency that would result from a well-designed inspec-
tion system would only be one result. Others would be increased
safety, more economical operation, and maintenance of auto-
mobiles, and reduced air pollution.
I believe the technology is here. The introduction of
microprocessors can make automObile inspections available to ev-
eryone at a nominal cost. I think we cannot progress into the 1980's
in the areas of safety, pollution control, and efficient operation and
maintenance of automobiles without a system that enlists the
motorist's trust and provides inf9rmation back to manufacturers
and to the regulatory agencies for correcting malfunctions in the
automobile's components and systems-whether that malfunction
came from the original manufacturer or from lack of maintenance.
Our experience with a great many motorists of all income levels
and with all kinds of automobiles convinces me that the motorist
desperately wants a system that would assure them of economical
and safe operation and dependable maintenance of their
automobile.
The automobile is a product that has great effect on society after
it is sold. We cannot compare it to a mixer, or transistor radio, or
even a television set.
In one of the summaries of the Task Force Reports on Motor
Vehicle Safety Goals Beyond 1980, a statement was made that the
automobile is the fourth largest item on which Americans spend
their income-after food, housing and other essential goods and
services. For a very large segment of the population-people living
in apartments, people that own more than one automobile, or an
automobile and a recreational vehicle, or an automobile and a
truck, people that are high insurance risks, people that live in a
very low-cost housing, but need the automobile for transportation,
all of these people-the automobile may very well comprise the
largest expenditure next to food.
The automobile is a major expenditure for just about everybody.
For most Americans, it is the only transportation choice they have
if they are to get and keep their jobs. This gives society an
obligation to develop a system that will minimize domination and
frustration by this mode of transportation.
The regulatory agencies ought to look at the rulemaking process
for achieving the 1980 and beyond safety goals, with the aim of
administering sensible standar4s that would have a high potential
of payoff and that causes the least amount of frustration for the
motorist. Data systems for determining the effectiveness of stan-
dards can best be strengthened through inspection systems. Ineffec-
tive standards should be eliminated. The average motorist does not
understand safety and emission control devices on his automobile. If
these components deteriorate rapidly or become ineffective after his
car has been involved in a minor accident, he can rightfully believe
it constitutes one of the biggest ripoffs the government regulatory
PAGENO="0122"
120
agencies could perpetrate. However, if the standards are effective
in saving lives and reducing injury and improving the environment,
the motorist will support them as one of the greatest services the
regulatory agencies can perform.
The automobile provides the greatest degree of freedom for indi-
vidual transportation that has ever been known. If programs for the
1980's and beyond are designed in a sensible, straightforward man-
ner to benefit the user of the automobile, which is just about
everyone, so that the bad effects the automobile does have on
society through accidents, environmental damage, and wasting en-
ergy resources, can be eliminated or made negligible, the auto-
mobile will probably be re-labled as this centuries greatest blessing
to our society.
Mr. EcKHARDT. You have indicated, Mr. Noettl, that you have
gathered considerable data of importance. And, of course, this is
obviously important to your members, that is to drivers.
Mr. NOETTL. That is right.
Mr. ECKHARDT. Have you also supplied the information to DOT
where it might be useful to them for instance, unnecessary repair
data?
Mr. NOETTL. Yes, sir, we have supplied some data to the DOT
upon their request. Most of the data has been in the form of special
studies done under special task orders. If they are investigating a
certain possible defect, they ask us for data, that is what we find
concerning that defect. It has not been used on a continuous basis
for analysis.
Mr. ECKHARDT. I have in mind that one of the main purposes of
this act was in the area to which you seem to have given consider-
able attention, and I think the same thing is true of the Alabama
Project; that is unnecessary repair.
Mr. NOETTL. Yes.
Mr. ECKHARDT. We had said that some of the purposes of the
diagnostic projects were to study standardization of diagnostic sys-
tems and test equipment, the capability of the motor vehicle repair
industry to correct diagnosed deficiencies or malfunctions, the cost
of such repairs, the relative costs and benefits to the project, the
efficiency of facility designs employed, et cetera. Obviously, in other
words, we are concerned with just what you are collecting, that is a
question of how the automobile repair system in America is serving
people.
Mr. NOETrL. Right.
Mr. ECKHARDT. And has DOT asked you for anything along these
lines or do they just ask you questions respecting specific defects
that you run into in connection with your inspection?
Mr. NOErFL. Yes. Going on memory right now, I don't remember
being asked about the quality of repair work. We did do some
studies on our own. One of the figures we have publicized is that 40
percent of the repair work, according to the way we count, is done
unnecessarily.
Now, our inspection is extremely thorough, relative to many of
the private diagnostic clinics. If we count individual items that we
inspect on a car, it totals over 500.
We have what we feel is the latest equipment to perform these
inspections, and we use the dynamic machinery that may not be
PAGENO="0123"
121
used in a lot of other inspection processes. So, we are pretty critical,
and our figure, like I say, is 40 peráent of unnecessary repair work.
Mr. ECKHARDT. I thank you very much for your testimony, it has
been most useful and the project is of great interest to this
subcommittee.
Mr. NOETTL. Thank you.
Mr. ECKHARDT. Mr. Randall?
STATEMENT OF DONALD A. RANDALL, WASHINGTON COUNSEL,
AUTOMOTIVE SERVICE COUNCILS, INC.
Mr. RANDALL. Mr. Chairman, I am very pleased to be here, and
most appreciate of the endurance of the Chairman's ability to sit for
so long on a hearing so late in the afternoon.
Mr. ECKHARDT. I said to Dr. Schlesinger yesterday in a hearing in
which he and I, I think, were the only remaining persons, that if
this were to be an endurance contest, I would rather it be out
drinking beer. He said, "Well, you have control of that."
Mr. RANDALL. It certainly is a demonstration, I think, that the
consumers can take heart that the Congress and this new adminis-
tration are going to give some real attention, I think, to one of the
most important consumer pieces of legislation that has been en-
acted in the last several years and that is this Public Law 92-513.
I worked over on the Senate side-and I will try to summarize my
testimony so we don't belabor the committee and the audience
either. I worked over in the Senate during the time that this law
was being drafted as a result of the hearings that were conducted
over there for four years. I would like to focus initially on one point
which I think we seem to have overlooked here.
When the insurance people were testifying they were concerned
about title II as it was or might affect their rating apparatus or the
premiums.
Title II, as I recall, when we were working on that, had a far
wider objecjtive. It was to rate cars not only on their insurance
costs-that was just one incidental point-it was to rate cars on
their repairability, their cost to own and operate and insure.
In Sweden they have been doing that for 10 years now, and they
publish an annual report on each make and model car and I
furnished a copy to Mrs. Foldes earlier of the Swedish study, the
one initially done in 1969. It is available to the people of Sweden to
select cars based on real world performance data, not simply the*
insurance costs, not how it performs when it is involved in a
collision, but how that car performs on a day-to-day basis in terms
of cost to own and operate.
An interesting thing in Sweden, when they began publishing this,
the auto manufacturers reduced the price of their parts in many
cases by 25 percent in order to make their cars appear to have a
better rating in the system. It was that objective that as a staff
person I had in mind when I suggested that to Senator Philip Hart
at the time.
I think as a representative of the auto repair industry one tends
to fall into the category of being suspect once you put on a hat, and
go over on that side, but I do want to say we acknowledge and
PAGENO="0124"
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recognize that fraud does exist in the auto repair industry, as
indeed, it exists in almost every profession known to man, including
the legal profession.
It constitutes a terribly small part of the overall problem that
American motorists have with their cars. The California Bureau of
Auto Repairs in California, studied the issue and found that it
constituted less than 1/10 of 1 percent. But it really is a moot
question. The motorist who feels that he has been taken may not
understand the difference between the ineptness of the mechanic
who in good faith sold him the shock absorbers, but who did not
intend to defraud the purchaser at all. In fact, we sell quite a large
number of shock absorbers in this country based on being able to
push up and down on the car and decide does it spring too lightly or
does it bounce too often.
A young inexperienced mechanic pushing up and down on some
of the more luxurious cars might decide the shock absorbers need to
be replaced, when, in fact, they are supposed to ride in a spongy
fashion.
The Senate hearings had really several major findings. The first
one was roughly one-third of the repairs performed were
unsatisfactory, improper, or unnecessary, and those are quite differ-
ent things.
The amount of that loss to the public was estimated by Senator
Hart at the time to be somewhere between $8 billion and $10 billion
a year. That is when the after market parts business and service in
this country was about $30 billion to $33 billion a year.
* Today, that market is $45 billion. If we take the data that was
assembled from one of the diagnostic programs that DOT undertook
pursuant to Public Law 92-513 and we extrapolated the 24 percent
of unnecessary work and we tie that. to the existing market today,
then we could reasonably argue that would be $10.8 billion annu-
ally, in unnecessary repairs.
However, in fairness to the industry, I think it's important to
point out that the Alabama Project had some mitigating factors.
The small shops there knew their work might be reinspected, so
they applied a higher level of maintenance and service to those
vehicles than they might otherwise have done. Very much like
doctors tend to test and maybe even overtest when they suspect
that the patient they are treating is a lawyer and he might be
litiguous in terms of malpractice.
Three major findings in addition to the auto repair and mainte-
nance aspects of the Senate hearings were, No. 1, that vehicles do
indeed sustain a very substantial amount of damage at very low
speeds. Two, that used cars frequently had their odometers tipped.
It is known as tipping the clock in the industry, turned back to
artificially enhanced the value. And, three, that we were losing a
very large number of cars in the stolen market, which were stolen
and either stripped for their parts, or they were stolen and re-
registered in States that had lax registration requirements.
We estimate that approximately 1 million cars are stolen annu-
ally in the United States, and the insurance industry told me this
week that the cost for the nonrestored vehicles amounts to $450
million annually.
PAGENO="0125"
123
We do not have hard figures on the total amount of money that
the public loses through the odometers being tampered with. How-
ever, the Department of Justice and the Department of Transporta-
tion, in discussions between themselves, have indicated that they
believe the value to be $100 per 10,000 miles by which the odometer
is reduced. We change hands annually on 23 million to 25 million
used cars in this country. We don't know how many of all of those
have the clocks tipped, but we believe from a Department of
Transportation study that ~0 percent of the fleet cars, that is, that
are in major fleets and tiien sold as used cars, have the odometers
tampered with. If you apply the figure across the board, we think
that a reasonable estimate of loss to the public on odometers
through tampering would be in excess of $1 billion.
An interesting thing about the Department of Justice, and when I
talked to them about this hearing I had an informal statement from
one of the people there that he hoped that the Department of
Transportation would undertake the responsibility for enforcement
of the odometer provision, because the department, under this law,
had far greater authority than did the Department of Justice. In
fact that the Department of Transportation had authority to hire
investigators to go out and see that this title IV of the bill was
enforced. When one talks to the Department of Transportation, one
gets the impression that they thought that the Department of
Justice was handling it, and Justice tells me that they have some-
thing like 15 grand jury investigations underway, which is a rather
pale significance when one considers that 25 million units change
hands annually. The Department of Transportation to my knowl-
edge does not have one investigator in this whole area, and it yet
represents a billion dollar cost to the public, if not substantially
more than that.
The Senate hearings very clearly were oriented toward the eco-
nomic aspects of auto repairs, and the impact on the millions of car
owners. Safety and emissions were only two incidental parts of the
concern of that body during the investigation and the drafting of
the original bill.
The title of this bill itself should have been a clue to the
Department of Transportation that the Congress was in fact con-
cerned about information to the public. The intent was to evaluate
the feasibility of rating each make and model car according to the
repair characteristics, the crashworthiness, the cost to own, operate
and insure. It also should have :been obvious to the Department of
Transportation and the two adminsitrations which have in my
opinion misadministered the program over the past 5 years. The
cost saving aspect of the law was paramount, not safety and not
emissions, and I don't want to minimize the very beneficial effect
that the diagnostic centers could have had on safety and emissions,
had they been implemented with the spirit with which the Congress
enacted this law.
The Congress in enacting Public Law 92-513 clearly indicated that
it was cost savings and information that was to be the benefit
conveyed on the public.
Finally, I really would like to call attention to recent develop-
ments and urge that the Congress consider the various State and
PAGENO="0126"
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Federal statutes that have been enacted and the regulations which
affect not only production of new cars but the maintenance and
service of those in use.
This is Mr. Alexander, who has recently joined the National
Institute of Automotive Service Excellence which rates and certifies
technicians now for competency.
This is a list of six of the major Federal statutes that began in
1966. I call them euphemistically the FEMS, the Federal Motor
Vehicle Safety Standard in 1966; the Federal Motor Vehicle In Use
Safety Standards; the Federal Motor Vehicle Emission Control
Standards in 1970, the FMVECS; the Federal Motor Vehicle
Crashworthiness Standards in 1972, that is the FMVCWS; the
Federal Motor Vehicle Noise Abatement Standards enacted in 1970
and to become effective in 1976 through some time in the near
future, FMVNAS; and the Federal Motor Vehicle Fuel Conserva-
tion Standards, that was in 1976, the FMVFCS.
The FEMS have dramatically, together with creature comfort
gadgets that are demanded by consumers, made our vehicles ex-
traordinarily complex. The complexity of the vehicles themselves
gives us and the motorists of this country their major problem.
I believe that all of the objectives that the Congress had in
enacting those Federal standards can be met and enhanced, enforce-
ment monitoring and indeed the fulfillment of the statutes can be
largely facilitated by the motor vehicle diagnostic program that was
envisioned in title III. The importance of that program, Mr. Chair-
man, is that we have 134 million units today traveling our streets
and highways, 1 trillion 700 billion miles last year, and the direct
cost of that system was estimated by Hertz Corporation to be more
than $200 billion last year. I believe the figure was $238 billion and
most of those vehicles do not have any on board diagnostic
capabiity. Indeed, they are not even designed to easily facilitate
analysis, or to be diagnosed, and we don't foresee that the vehicle
population, until late in the 1980's, will begin to have on board
diagnostic capability, that those vehicles will substantially pene-
trate the vehicle population of this nation. Simply put, it will be
1990 before we see vehicles that have the ability to tell the owner or
the service technician what is wrong with the vehicle and needs to
be repaired, and then to indicate to him. Has it been repaired
correctly.
I would like to show you an example of a first generation type on
board diagnostic capabilit1. This is a very low cost connector. It is
called the General Motors Central Test Point Diagnostic Connector,
and they have started installing this on some of their large sized
cars, very easily accessible to the technician. It is a simple plug
which is hooked to vital points of the electrical system of the
automobile.
If one has that installation on the car, then one can take one of
the relatively simple, very low cost diagnostic tools.
The one I am holding in my right hand is called the ACA, the Air
Conditioning Analyzer. This is almost foolproof or idiot-proof, as it
is known in the industry. You plug it into this plug and follow a
very simple process, and you can analyze the entire electrical
PAGENO="0127"
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system of the air conditioning, and that is a very laborious and*
time-consuming process without this connector.
A second one, which I have here, is another idiot-proof device. If
is followed in sequence, each light comes on and it can check out
the entire electrical system of the automobile, including the wiring
under the dash, and the fuse box, which is a very useful thing. It is
a very efficient way of locating; electrical problems which are
increasingly becoming a major factor in repairs as we move into the
era of electronics on automobiles. In fact, the Seville Cadillac now
in its cost of production has one third of the cost involved in
electronics. This is a dramatic change in the auto industry.
Last is a device that has a probe which when inserted above the
flywheel can read absolute dead center timing, and it can show the
exact RPMs or revolutions per minute which enable the technician
to very easily reach over and tune, the automobile so that it is tuned
precisely right. Tuning is a very important part of not only the
satisfactory operation of the vehicle, but it means that if it is tuned
correctly, it will start when you try first thing in the morning. It
will idle smoothly when you get it in operation and it will stop
operating when you turn the key off and take the key out, unlike
very many cars which you have now which will not start, which idle
roughly, and won't stop when you take the key out.
Now that is a consumer item.
Mr. ECKHARDT. Mr. Randall, about how much does that equip-
ment cost?
Mr. RANDALL. These three, as I say, are somewhat first genera-
tion. The cost is slightly under $500, but the cost since I have gotten
these just 4 months ago has dropped to somewhere in the neighbor-
hood of $300 because of competition from the Japanese I under-
stand. That cost is coming down rather dramatically. It does demon-
strate that we can build in the diagnosis to our vehicles that is
necessary, and I commend General Motors for doing it, and I
understand Ford is moving in that direction and some of the others.
I am reminded of a fellow who once brought to me a device which
would indicate the condition of brakes on cars, and if one ignores
the brake after it wore down to a certain point, a light would come
on, and now we see those in cars today. If you waited a little bit
longer and ignored the light, it wore down a little bit further, it
would set off a buzzer that would buzz constantly. He said he was
trying to work out a way so that it would play through the
transistor radio if you ignored the first and the second one, con-
stantly play through the radiO "Nearer my God to thee."
I say that facetiously, but the point is that we do not have a
significant technologically accurate low cost means to analyze shock
absorbers on our car, and we buy over $600 million worth a year.
We don't have a means to quickly easily diagnose the condition of
brakes without having to pull a wheel on a car, but we could have,
and there are other areas in suspension, steering and other factors
which we could move into.
In conclusion, I would like to say that in my prepared statement,
if I may request that that be included in the record in full, that
there is a great need to salvage at least two of the remaining
diagnostic projects that are under the existing law. They can
21-335 0 - 78 -
PAGENO="0128"
126
provide a number of things, and I have outlined six major points,
but more importantly, I think is that there is an enormous need, an
urgency, for the Congress to renew its mandate to the Department
of Transportation and to the Environmental Protection Agency, and
tell those two agencies who have developed an enormous chasm
between them, in terms of vehicle inspection apparently, that the
Congress wishes for them to consider their joint responsibility and
to collaborate in any vehicle inspector program.
It is important that we not have an EPA inspection program and
a DOT inspection program. It is important that we look at all siiof
the Federal standards and areas, and tell the public and admit to
the public that our safety inspection programs in the past have
been Mickey Mouse. They have been a charade. They have been a
waste of their time and their money, but that does not mean that
effective, carefully developed and very carefully sold to the public
vehicle inspection will not return to the public a great deal.
In fact, on the last page of my statement, I pointed out from data
that I obtained from the Department of Transportation that a
nationwide system of 9,000 diagnostic lanes could be established for
a cost of about $1.4 billion, and operated at an annual cost of about
$935 million, and that that operation would create 100,000 direct
jobs, permanent jobs. It would create 50,000 immediate jobs for
construction of the facilities, and for employing people who produce
the equipment that would go into those facilities. So that if given
the mandate to do so, we could create 150,000 jobs, and it would not
necessarily involve the expenditure of Federal funds if the govern-
ment would mandate that the States undertake such inspection
facilities and not threaten to take their money away from them for
their highway funds but show them how it can be done through
private industry, franchised very much like the people in Holland
do, in the Netherlands, franchised to private industry, who through
their diligence and their efficiency can produce the inspection
facilities. Private industry would invest the money, given the assur-
ance that they had an ample time to amortize the investment, such
as a VA guarantee loan arrangement that the government itself
could undertake to guarantee, but not have to appropriate any
money. Then we could give the public at least $2 billion, probably
substantially more than $2 billion, a year in value returned from
this system.
We could find a lot of stolen cars and get them returned. We cou
find a lot of the cars that have never been taken in for the
warranty work from the manufacturer because they were recalled,
and we could get those back in and get them brought back into
compliance at the manufacturer's cost, a value which the public has
already paid for at the time they purchase their cars. Many other
values are available that the public could enjoy from a nationwide
diagnostic system.
It shouldn't be thrust upon the public or the States quickly. It has
to be a joint partnership between the Federal Government and the
States, with the public being sold on the idea because it is of benefit
to them in emission reductions, fuel conservation, longer life of
their vehicles, and all of the others that I mentioend earlier.
I am deeply grateful for the opportunity to be here, and I hope
that I can answer any questions that you may have.
PAGENO="0129"
127
[Mr. Randall's prepared statement follows:]
Nutomotive
ervice
C OUflCIIS~ Iflc. 188 Industrial Drive, Suite 112 Elmhurst, Illinois 60126 (312) 530-2330
PIRECT REPLY TO: Wo$hIlgtRN Off 66
DONALD A. RANDALL Woshi~gt6l CooroRiSAIIR 1201. 1000 co nonOol Ao'., Nw.
W6$hinglOl. D.C. 20036 Thi. 1202) 633-6696
DONALD A. RANDALL
TESTIFYING ON BEHALF OF
AUTOMOTIVE SERVICE COUNCILS, INC.,
BEFORE THE SUBCOMMITTEE ON CONSUMER PROTECTION & FINANCE,
INTERSTATE AND FOREIGN COMMERCE COMMITTEE,
UNITED STATES HOUSE OF REPRESENTATIVES
WASHINGTON, D.C.
I appreciate the opportunity of appearing before this committee,
and I hope that my testimony will provide some background and an over-
view of part of the legislative history and other developments that
concern this very important piece of legislation. -
From 1967 through 1973, I was staff counsel for the U. S. Senate
Judiciary Committee, Subcommittee on Antitrust and Monopoly, chaired
by the late Senator Philip A. Hart, one of the nations most eminent
consumer spokesmen. In 1972, working closely with the Senate Com-
merce Committee staff, we jointly drafted PL 92-513.
Beginning in 1968, the Subcommittee began what turned out to
be a four-year investigation of the auto repair industry. . The
investigation heard from dozens of witnesses and received over 4,000
pages of formal testimony. We collected over 60,000 exhibits and
interviewed several hundred ~`individuals who were not withesses in the
formal hearing. Testimony and evidence was received from every segment
- A merger of he Independent Garage Owners of Amenca (IGOAI and the Auto Body Association of America (ABAA)
PAGENO="0130"
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of the auto industry, from manufacturers to independent service
establishments. The exhibits include thousands of letters from
irate motorists. The printed record of those hearings are con-
tained in six volumes of the Auto Repair Industry investigation
by the United States Senate.
A careful reading of those hearings discloses a finding that
some fraud in the auto repair industry does exist as it does in
every profession. However, if one studies the record of the
committee and reviews information available in various consumer
protection agencies across the country, including the California
Bureau of Auto Repair, it can be reasonably established that fraud
constitutes a very small part of consumer complaints or problems
motorists experience with their automobiles and repairs to them.
According to the California Bureau of Auto Repairs, fraud constitutes
less than 1/10 of 1% of the cases that they have investigated.
However, where the semantic difference between outright fraud and
`overcharge' and service lies, is a moot point to many consumers
who suspect that `they've been had.'
Clearly, the Senate investigative hearings and others that
have been conducted since then by the Federal Trade Commission and the
Diagnostic Demonostration Projects of the Department of Transportation
in the various states show that the main problem with auto repairs
is complexity in vehicle design. The complexity built in to satisfy
a public sold on power, gadgets, external beauty and obsolescence
affects access maintainence and service; requires a high level of
knowledge and expertise and specialized tooling to correct deficien-
cies; and makes the naive and captive vehicle owners vulnerable to
any prescribed repair. The problem is not easily corrected. The
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buying public' s mood will not be easily : altered even with changing
energy priorities and rise in automotive costs. A]~sg~_it_ would be
too demanding to expect the average motorist to be knowledgeable about
repair needs and verbalize these facts with the repair shop personnel.
Therefore, within today's technology, the burden of responsibility
for proper and equitable repairs falls on the mechanics and auto-
motive technicians -- it is my opinion that these technicians are
unable to meet this challenge.
Now, if I may, I would like to turn to the Senate Investigation
Repair Industry. -- --
The Senate hearings disclosed fivejmajor areas where multi-
billion dollar economic losses occur in the public's use of the
private transportation system.
Foremost was the estimated loss of approximately 10 billion
dollars annually due to repairs that were either unnecessary, im-
proper or unsatisfactory to the vehicle owners. This was about
one-third of the total retail sales of parts and service in 1972
when that investigation ended. It now appears that the Department
of Transportation preliminary report from the diagnostic centers
tends to confirm that earlier estimate.
Subj active NHTSA evaluation by a group of master mechanics
reviewing the repair activities at one site (Alabama), considered
approximately 24 percent of the repairs unnecessary. Extrapolation
of this percentage to the na1~ional scene would imply an unnecessary
repair expense of 10.8 billion dollars to the American motorists. In
fairness to the repair industry, the repairs that may have beerr con-
strued as unnecessary at the site (Alabama), may have been done to
insure compliance with the re-inspection procedures conducted at the
diagnostic center. To insure compliance, the industry tends to take
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a conservative posture; much as a medical doctor with the fear
of malpractice, tests, possibly overtests patients during the
medical diagnostic mode. The auto repair industry, much like the
medical profession, tends to keep treating the symptoms until the
trouble goes away. Unfortunately, the auto repair industry has
not kept pace with the medical people in developments for accurate
diagnosis capability. There certainly are repairs that are performed
incorrectly, but however incorrect the repairs may have been, they
were probably needed. There is an abudnance of evidence showing
there are many very necessary safety related repairs which go un-
performed because the motorists either refuse to have the work
done or because they lack the confidence in the recommendation of
their service technician. On average, for brakes alone, the DOT
study shows that 36% of the cars failed the initial inspection~
That means they did not comply with the minimum Federal Motor Vehicle
In Use Safety Standards. Yet, these vehicles are permitted to operate
across state borders and into Washington D C and indeed on every
street and highway in this nation. They constitute a real hazard to
the motorists and pedestrians who have to use our streets and high-
ways. Given proper diagnosis, these repairs would be made and the
motorists could have real confidence in repairs recommended by these
diagnostic centers.
Three other major findings of the Senate hearings concerned
the enormous damage suffered by vehicles in very low speed crashes,
used cars which had the mileage reduced to enhance their value,
and the economic losses resulting from stolen vehicles. We have
approximately 1 million cars that are stolen annually and either
stripped for their `parts, or they are Fetitled in states which do
not have a formal title and registration requirement. The insurance
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industry estimates that the value of the stolen vehicles which
are not recovered and subsequently restored to their owners amounts
to more than $450 million annually. The Senate investigation also
disclosed a multi-million dollar economic loss to the public through
the sale of used cars which had odoneters rolled back. In this
tampering, the mileage indicator on the vehicles is reduced, arti-
fically inflating the value of the vehicle. Annually, there are
some 23 million to 25 million used cars which change owners. The
Department ~of Transportation has some s~udies which show that the
economic loss to the public is $100 in inflated value for each 10,000
miles by which the odometer is reduced. While no firm total economic
loss is available, the Department of Justice has indicated that about
60% of used fleet vehicles have their odometers rolled back. I
estimate the total economic loss to the public on all used cars
is over 1 billion dollars annually.
Finally, losses due to unsatisfactory, incorrect and unnecessary
repairs to fragil--easily damaged cars;would point to an economic
loss to the public of over $1 billion annually.
All of the foregoing factors formed `the basis ,for the primary
intent of Congress in PL 92-513 -- addressing the economic impact
of vehicle ownership. The Senate hearings were oriented toward the
economic aspects of auto repairs and the impact on the millions of
car owners. Safety and emissions were only two incidental parts of
the concern of the Congress and were very peripheral to the ultimate
adoption of PL 92-513.
There was in 1972, as there is 1977, a broad consumer unrest and
concern about the cost of their auto repairs and the general costs
óf owning and operating their private motor vehicles. I believe
it was this fundamental cost of ownership that was the objective
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132
Congress had in mind when it provided for information to the public
through the Motor Vehicle Information and Cost Savings Act, The
Title itself should have been a clue to the Department of Transpor-
tation that the Congress was in fact concerned about information to
the public. The intent was to evaluate the feasibility of rating each
make and model car according to the repair characteristics, the crash
worthiness and the cost to own, operate and insure. It also should
have been obvious to the Department of Transportation and the two
Administrations which have, in my opinion, misadministered the program
over these past five years, that the cost savings aspect of the law
was paramount, not safety and not emissions~ I do not wish to mini-
mize the fact that these diagnostic centers could have had a profound
beneficial effect upon safety and emission reductions, noise abate-
rrant and fuel conservation. However, the Congress in enacting PL 92-513
clearly indicated that it was cost savings and information that the
act was to convey as a benefit to the American motorist. Safety and
emissions were already covered under other laws.
Finally, recent developments urgently require that Congress'
attention now be focused on government regulations and standards
affecting the production and servicing of new motor vehicles. These
bég~n - in 1966. I would like to briefly describe them. These laws
and administration of them interact and interrelate to the basic
planning guide and pilot study program objectives which PL 92-5l3,.and
especially Title 3 as amended, was designed to facilitate. They are
listed below:
1. Federal Motor Vehicle Safety Standards - FMVSS (1966)
new cars
2. Federal Motor Vehicle In Use Standards - FMVUSS (1967)
used cars
3. Federal Motor Vehicle Emission Control Standards-FMVECS (1970)
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133
4. Federal Motor Vehicle Crash Worthiness Standards - PL 92-513
FMVCWS (1972) -- The Motor Vehicle Information and
Cost Savings Act
Title I - Bumper Standards
Titl~ II - Rating Each Make and Model
Title III - Diagnostic Centers
Title IV - Odometer Tampering
5. Federal Vehicle Noise Abatement Standards - FMVNAS (1970)
6. Federal Motor Vehicle Fuel Conservation Standards - FMVPCS
(1976)
All of these caine about as Congress moved to enact legislation
aimed at forcing the automobile manufacturers, domestic and foreign,
and the entire automotive parts and service industry to produce
and service vehicles which are less abusive or offensive to our
environment and our people. These laws have required that vehicles
consume less energy and as a result less of our other natural
resources such as rubber, copper, lead, steel, etc. This body of
public law may be said to be directed toward requiring the production
and use of ethical vehicles -- those that are safe, environmentally
compatible and socially acceptable within the bounds of our nation's
economic requirements.
To summarize, then, the Motor Vehicle Information and Cost
Savings Act, as it has been amended, and in particular the 1976
amendments, were designed to provide a self-policing and enforcement
mechanism which would address many areas of public concern, both of
the Federal and State Governments. In a word, this law is the "key-
stone" to the six areas of federal standards. It was certainly aimed
at the widespread consumer discontent and concern about the auto-
mobile, their costs and their repairability.
Fundamental questions were propounded by the Congress in
directing DOT to undertake these projects. First of which was to study
the technical capability of the existing state of the art in diagnos-
PAGENO="0136"
134
tic equipment. Next was the capability and willingness of private
industry to meet the future requirements for low cost diagnostic
equipment. This equipment would need to address the problems of
theee vehicles during the interim years, 1977 through 2000. It is
during this period that vehicle designs and the entire vehicle popu-
lation will not readily accomodate diagnosing. Simply put, complex
vehicles that exist today, and most of those that will be produced
through about year 1984 will not have on-board diagnostic capability.
They will simply be operating in ~the real world with the motorists
depending upon the skill level of the technicians to analyse and
perform the needed repairs. The Motor Vehicle Information and Cost
Savings Act was designed to address the interim problems so that we
could develop the kinds of low cost equipment needed to facilitate
this diagnostic capability on the véhicles during the era of 1977
through 2000. Toward the end of this century, we will see a sub-
stantial number of vehicles with on board diagnostic capability.
Those vehicles will themselves have indicators which will tell the.
operator or the service technician what needs to be fixed and if
it has been fixed correctly. But, keep in mind these will not con-
stitute a major part of our vehicle population until after 1990!
In my opinion, the diagnostic equipment available today is not
adequate to properly, conveniently, quickly, and at low cost be
connected to these non-diagnosable vehicles. Therefore, if answers
to unneeded and unsatisfactory repairs are found, we must accomodate
this lack of on-board technology with improved off-the-vehicle
diagnostic equipment. I have with me today an example. This is the
General Motors' Central Test Point Diagnostic Connector. It is a very
low-cost item that GM has been installing on some of their large-size
vehicles. This connector would enable the average mechanic through
PAGENO="0137"
PAGENO="0138"
PAGENO="0139"
137
2. Projects would be able to provide vehicle owners with
critical information -- keep and repair or trade or junk
their vehicles.
3. Two years of data, log books~ and basic information has
already been collected. This can be built upon to give
us sound quantative data to assess the real benefits to
the public in energy conservation, air pollution, noise
abatement, safety and operating costs reduction which may
come from unbiased diagnostic inspections.
4. None of the projects turned their attention to the newer
catalytic converters and other newer emission control
equipped cars. We have a 50,000 mile or five (5) years
mandatory warranty for which the public must pay in advance.
Yet, we have no technically reliable or convenient means for
the public to have their vehicles checked to see if they
are functioning as designed. We know from EPA studies and
the November 1976 report to the Regional Administration of
EPA that our controlled vehicles are deteriorating more
rapidly than previously expected.
The Congress had determined to assess a huge cost for
those emission systems on the public and yet the average
motorists, indeed most car owners have no means of deter-
mining if these cars are operating in compliance with the
Federal Motor Vehicle Emission Control Standards -- or
even if they are safe. I am afraid that most motorists --
absent mandatory inspection and maintenance -- will not
particularly care if their cars are in compliance or not.
The evidence clearly shows that many motorists dismantle
and disable their emission devices. One third neglect the
PAGENO="0140"
PAGENO="0141"
139
Where the states or counties operate the inspection
facilities, they can benefit.
In conclusion, the Motor Vehicle Information and Cost Savings
Act should be reconstituted because it was torpetoed during the
last five years. It was swept aside because it was a consumer bill.
The mandate to the Department of Transportation should be clearly
renewed -- with urgency if we are to meet the needs of our motorists
during the interim period 1980-2000. The scope and objectives should
be enlarged. The budget should be significantly increased with the
objective of ultimately establishing a nationwide systom of unbiased
independent diagnostic centers which could offer to the American
motorists billions of dollars in annual benefits in return for the
comparatively small investment that private industry -- not the govern-
merit -- could make. I am suggesting that legislation be drafted which
would authorize the states that install diagnostic inspection facili-
ties to franchise the task of operating these facilities to private
industry. In return, they could be guaranteed that a reasonable
period for amortization of ten years would be underwritten by a
government insurance program -- similar in concept to VA home insurance.
In this way, if the states mandate inspections, private industry would
put up the capitol to establish the inspection facilities and the
Federal Government would guarantee that they could be operated during
a period sufficient to amortize them for a reasonable time. Thus,
we can achieve the objectives which I have outlined in my statment
without the expenditure of huge sums of federal tax money and with
the efficiencies and benefits that normally accrue through private
industry's dilligence and enterprise. The benefactors would be
the public, both economically and in emission reductions, and in fuel
conservation, and in noise abatement, and finally in safety.
PAGENO="0142"
140
A nationwide system of diagnostic motor vehicle in-
spe~btion which would include all six of the Federal Motor
Vehicle Standards and provide the motorist with an accurate
unbiased list of needed and optional repairs can he initially
established at a cost of approximately $1.4 billion dollars.
This would provide for about 9,000 very sophisticated high
volume diagnostic lanes. These facilities would create
100,000 permanent new jobs and at an annual operating cost
estimated to be $972 million. Construction and manufacture
of the inspection equipment would create an additional
50,000 indirect jobs.
The annual benefits to the public would be in excess
of $2 billion through fuel conservation, extended life
cycles for their vehicles, less breakdown and resultant con-
surner loss of transportation and working hours, reductions
on pollution, significant reduction in unnecessary,unsatis-
factory and improper repairs and identification and return
of stolen vehicles. These facilities can also provide
value to the public by identifying vehicles which should
be recalled and repaired at the manufacturers costs due to
safety and emission control defects.
Mr. ECKHARDT. Mr. Randall, in addition to the jobs that would be
created for those engaged in inspection centers, I assume it would
also create jobs with respect to needed repairs.
Mr. RANDALL. Mr. Chairman, it would. In fact, you have had two
witnesses here so testifying.
In my prepared statement I indicate that there is a lack of
confidence, the American public questions the technician's recom-
mendations when he tells them that they need brakes replaced.
Indeed, one of the officials in the Department of Transportation
who was told that he should have his brakes fixed refused to do so
until he finally ground the brakes down to the drums, and he had to
replace the drums on all of his wheels.
If we have that kind of apathy toward a serious matter such as
brakes, and one-third of the cars operating on our streets and
highways have very seriously defective brakes, then what I am
saying is that the diagnostic centers would give the public confi-
dence to undertake the repairs that are recommended. It would not
mean that we would get more repairs necessarily, but we would
shift from the unnecessary and needless repairs to those that are
genuinely needed, and we would not be wasting a rather substantial
amount.
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141
Mr. ECKHARDT. But even if we spent a net of more money for
repairs, and those repairs were the kind of repairs that, for in-
stance, save gasoline--
Mr. RANDALL. Yes.
Mr. ECKHARDT. We would still come out very much on the high
side of the balance, would we not?
Mr. RANDALL. The evidence clearly shows that tune-ups and
adjustments after inspection just for emissions returns to the aver-
age owner more than he spends on the tune-up in 1 year.
Mr. ECKHARDT. In all then, society would be paying more for jobs
and less for oil?
Mr. RANDALL. That is correct.
Mr. ECKHARDT. This would not seem inappropriate as a program
which is an adjunct, so to speak, to the total energy program of the
country, as I see it.
Mr. RANDALL. There would be a direct benefit to it, although I
think that the benefit in terms of fuel reduction is somewhere on
the order of 2 percent. Some very recent studies that I have had
access to show that it is about 2 percent improvement, but the other
part of that is that these jobs would be, unlike the public works bill
that just cleared the Congress, I believe it was yesterday, $4 bilion
to create 200,000 jobs.
You can create 150,000 jobs here at a very substantial savings in
terms of Federal investment.
Mr. ECKHARDT. There is another line of questioning I would like
to go into.
I know that you were most active, as much as any other person,
in formulating the basic policy of this act, indeed in drafting much
of it. I am concerned about its major purpose. I have the feeling
that there has been some misapprehension on the part of the
Department of Transportation as to its purpose.
I notice in title III, and I am: reading and omitting irrelevant
material:
"Each project shall provide the secretary information and data
relating to"-and then skipping-"the capability of the motor vehi-
cle repair industry to correct diagnosed deficiencies or malfunctions
and the cost of such repairs."
I noted in your testimony that you said that in the hearings the
Senate found some 30 percent of repairs to be unnecessary. It is an
interesting fact that the Alabama inspection operation has come to
about the same conclusion, 30 percent of the amount paid for repair
I believe they found was for unnecessary repairs.
It would seem to me, in reading the language, that the project
shall provide the secretary-information and data relating to the
capability of the motor vehicle repair industry to correct diagnosed
deficiencies or malfunctions and the costs of such repairs-would
include information concerning these unnecessary repairs, the very
type of thing that has been found in the Alabama project and
possibly also in the other projects that we heard reported on today.
Would you feel that that would be within the purpose of the act?
Mr. RANDALL. Absolutely. I think that that was one of the
foremost interests that we anticipated as staff people at the time,
getting answers to from the Department of Transportation in June
21-335 0 - 78 - 10
PAGENO="0144"
142
1977. The timing on this, Mr. Chairman, was very important,
because we recognize from the studies that we were going to have
this interim period of vehicles that were not diagnosable from 1970
through 1984 to 1990, and we knew that we were going to have to
address the issue of repairability as one of the major consumer
problems.
We also knew that fuel was going to become critically short,
because the antitrust committee had spent 2~ years previous to the
beginning of this investigation studying the petroleum industry. We
forecast the shortage and in the initial draft of the bill. It even had
a provision in title II to rate each make and model car according to
its fuel consumption, and that was stricken in committee, you may
recall.
Mr. ECKHARDT. Since each of these projects is of course a kind of
test tube to get really meaningful data, there should be someplace
where this data is received and analyzed and further used, and I
would assume that under the act that would be the Department of
Transportation.
Mr. RANDALL. I have very serious reservations about the scope of
the tasks that were designated to be done. I think that the depart-
ment very clearly ignored the consumer aspect. They very clearly
ignored the economic thrust. That was the paramount thing that
this bill was designed to accomplish.
We already had a safety law. We already have an emission
control law. When this bill was enacted it was reaching into the
economic considerations in the tens of thousands of complaints that
the Federal Trade Commission and members of the Congress were
getting about auto repairs, and warranties in particular, and it was
addressed to that aspect.
I cannot prejudge what the National Highway Traffic Safety
Administration will testify to. I only know as a private citizen and a
person of interest and a representative of a group of repair shops
who are concerned about both their industry and their customers
that the data and information that I have received thus far indi-
cates to me that the last 5 years and the more than $18 million that
was spent on this project did not accomplish those things that were
the primary interest of the Congress when we drew it up. I did try
in my formal statement to enumerate what questions we were
trying to promulgate.
Mr. ECKHARDT. I note here that the Chairman of the Federal
Trade Commission seems to be of the same view that you are, and I
must say that I agree with you.
I was an author on the House side, and I felt that the major
thrust of title III was to look into the question of the cost of repair,
and whether or not repair was being done efficiently for the public.
The Chairman writes to the Secretary of DOT asking the follow-
ing. He says:
"Analysis of this data and further collection of data could reveal,
for example,"-he is asking for the diagnostic records-"the extent
of consumer economic loss resulting from unnecessary repairs of
particular components of different types of repair outlets, the
extent to which the performance of unnecessary repairs varies from
shop to shop, whether the incidence of unnecessary repair and the
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143
quality and costs of repairs differ significantly between shops that
employ mechanics certified by voluntary certification programs and
those that do not, the effect of flat rate and other mechanic
compensation systems on the quality of repair work, and the inci-
dence of unnecessary repairs, and whether, and the extent to which,
the incidence of unnecessary repairs may be reduced when consum-
ers have access to diagnostic centers which specify in detail what
repair work needs to be done."
Now that would seem to me to be a request entirely within the
intent of the provision respecting diagnostic clinics, as I see it..
Mr. RANDALL. I could not agree more.
Mr. ECKHARDT. However, I note that the Secretary of Transporta-
tion replied, and incidentally I do not mean to criticize the present
Secretary because, being new, he may be without the information. I
suspect that he may be on something of a spot when he is asked for
information that he does not have. In any event, he says:
"A final report is being prepared at this time, and will be
available in June. While this report will contain much of the
information you requested, I must point out that it will not meet all
your needs. The projects were designed to gather specific informa-
tion stated in the enabling legislation, and therefore do not include
certain areas of your interest."
Well, I would have thought that the enabling legislation covered
precisely what the Chairman was asking for.
Mr. RANDALL. It absolutely did in my opinon.
Mr. ECKHARDT. Now of course it may well be that the Secretary of
Transportation just does not have, it, because he obviously could not
bring it together within a matter Of a few months. But from what I
have heard from the Alabama project, they have it.
Mr. RANDALL. At least the beginning of it.
Mr. ECKHARDT. I note to my great regret that in the next
paragraph the Secretary of the Department of Transportation says:
"These projects completed their first phase of operation on June
30, 1976. Three of them have been extended until September 30,
1977. However, no additional analysis is planned by the Depart-
ment. The staff has been reassigned to other projects and all
programmed funds have been expended."
Now it strikes me that such activity is in the teeth of the
congressional policy stated in the act.
Mr. RANDALL. Mr. Chairman, it has just been blatently obvious to
me, both when I was a staff member for the Senate Judiciary and in
my private capacity in my visits to the Department of Transporta-
tion, that this act has been torpedoed from its inception. I can say
the fact it was torpedoed is fairly obvious when one looks at the
position assignments and the job descriptions and titles given to the
people there, and the number of people assigned to the task and to
supervision of it, and the constant eroding of even the slightest
vestage of earlier interest as we reached in the 1976 era. Had it not
been, Mr. Chairman, for your amendment that you supported in the
full committee in 1976 to amend, this act to create a new special
project including fuel and conservation of fuel and emissions, the
entire section would have been abolished except for a housekeeping
group over there, and I am convinced of that.
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144
While I do not have first hand information about it, I was told at
one point, in fact on the day following the day that this law was
signed by President Nixon, that when he signed it into law, present
were Presidential assistants and some people from the Department
of Transportation, and he indicated to them that he did not want
anymore of these-expletive deleted-consumer bills before him,
and given that kind of mandate, the Department of Transportation
proceeded to send this thing to what I presume was the then
considered to be Lower Slobovia, which was down at Buzzards
Point.
Mr. ECKHARDT. He didn't have a bill before him then; he had an
act, and he had the mandate of the Constitution that he should
faithfully execute the laws, but considering the impoundment oper-
ations, I suppose this was entirely consonant with the program of
discretionarily implementing or not implementing the laws passed
by Congress.
I am in hopes, though, that in this administration we may have a
more faithful observance of the constitutional mandate to faithfully
execute the laws.
Mr. RANDALL. I viewed it in retrospect as being one of those
things that he did from his heart for the consumers.
Mr. ECKHARDT. I suppose we still have a good deal that we could
gain out of these programs with maybe a short extension and with a
revitalized activity on the part of the Department of Transporta-
tion, because we have heard today that much of the type of
information we were interested in in title III is at the present time
available within the Alabama project, if it were simply asked for by
the Department of Transportation and analyzed.
Of course, it isn't as good and extensive as it might have been for
all the other projects which had been funded. The Alabama project
apparently ran itself. It didn't get much aid from DOT, except from
the original grants, and then it got a considerable amount of State
funds from universities, as I understand it.
Mr. RANDALL. The major deficiency, of course, Mr. Chairman, is
vehicles that examined were not the controlled, complex vehicles
we have now with the emission control devices and new electronic
equipment on them. So the tests didn't get into the era that is going
to give us our greatest problem, and that is the more complex
vehicles.
Mr. EcKHARDT. I suppose what that program really showed us
most is already evident in this hearing, and that is that there is a
need for inspection and an inspection can reduce unnecessary
repairs.
Mr. RANDALL. Not just safety though, it has to be the combinatin
of emissions, safety, noise, the whole gamut all across the board.
Then you get a very cost effective program.
Mr. ECKHARDT. Surely.
Thank you very much, Mr. Randall, for your very competent and
able testimony. I know there is no one who knows more about this
act or more of its possibilities than you.
Mr. RANDALL. Thank you, Mr. Chairman.
Mr. ECKHARDT. The subcommittee is adjourned until Monday at
2:30 o'clock.
[Whereupon, at 6:05 p.m. the subcommittee adjourned to recon-
vene at the call of the Chair.]
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MOTOR VEHICLE INFORMATION AND COST
SAVINGS ACT OF 1972-OVERSIGHT
MONDAY, MAY 9, 1977
HOUSE OF REPRESENTATIVES,
SUBCOMMITTEE ON CONSUMER PROTECTION AND FINANCE,
COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE,
Washington, D.C.
The subcommittee met, pursuant to notice, at 2:30 p.m., in room
2237, Rayburn House Office Building, Hon. Bob Eckhardt, chair-
man, presiding.
Mr. ECKHARDT. The Committee on Consumer Protection and
Finance will resume its oversight hearings respecting the Motor
Vehicle Information and Cost Savings Act.
The subcommittee is particularly honored to have the distin-
guished new Administrator of the National Highway Traffic Safety
Administration, Ms. Joan B. Claybrook.
We are delighted to have you this afternoon, and you may
proceed in the manner in which you see fit.
STATEMENT OF JOAN B. CLAYBROOK, ADMINISTRATOR, NA-
TIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION, DE-
PARTMENT OF TRANSPORTATION, ACCOMPANIED BY HOWARD
J. DUGOFF, ASSOCIATE ADMINISTRATOR FOR RESEARCH AND
DEVELOPMENT, AND FRANK A. BERNDT, ACTING CHIEF
COUNSEL
Ms.. CLAYBROOK. I am pleased to appear before this subcommittee
today in response to your invitation to Secretary Adams, to discuss
the Department of Transportation's efforts to implement the Motor
Vehicle Information and Cost Savings Act. With me today are Mr.
Howard Dugoff, Associate Administrator for Research and Develop-
ment, and Mr. Frank Berndt, our Acting Chief Counsel.
I would like to address each title of the Cost Savings Act sepa-
rately and answer the specific questions raised by the chairman's
April 21, 1977, letter to Secretary Adams. This letter did not list
title V, Improving Automotive Efficiency, which is the title estab-
lishing the automotive . fuel efficiency program. Secretary Adams
testified on title V before the Subcommittee on Energy and Power
on April 25 and, unless you have specific questions, I will not speak
to it today.
(145)
PAGENO="0148"
146
TITLE I-BUMPER STANDARDS
Since the agency's last testimony before this committee in 1975,
the damageability bumper standard has been issued, to take effect
in two stages on September 1, 1978, and September 1, 1979. The first
phase specifies conformity with the existing safety bumper Stan-
dard No. 215, and requires that there be no breakage or release of
fasteners or joints and no cosmetic damage to the exterior surfaces
of the vehicle other than the bumper face bar and its attachment to
the vehicle. The second phase prohibits significant damage to the
bumper face bar and attachment as well. Just before he left office,
my predecessor, John Snow, proposed to delay the September 1979
requirements for 1 more year.
You asked why it has taken so long since the 1972 enactment of
the Cost Savings Act to have these standards go into effect. I am
told that a large part of the delay had to do with developing damage
criteria for the standard that wou.ld reduce the costs of low-speed
bumper impacts. The requirements had to be strict enough to
prevent unnecessary damage, but not so strict as to unnecessarily
restrict possible bumper designs. Advances in bumper technology
occurred as the agency went through the rulemaking process. Re-
sponding to these advances apparently caused some delay, but the
staff believes we have a better standard as a result.
Under the act, the department must stipulate performance re-
quirements for bumpers, but cannot stipulate features of design
such as bumper geometry, structural configuration, or materials.
Experience with the safety bumper standard has shown that manu-
facturers are capable of designing bumpers which minimize weight
and cost penalties. New designs and materials have been developed
which offer substantial confidence that the bumper standard will
achieve the goals of title I, particularly given the pressure on
manufacturers to reduce vehicle weight which derives from the title
V fuel efficiency requirements.
John Snow's proposal to delay the second phase of the standard
for 1 year in response to manufacturer petitions was related to the
effects of the fuel economy standards under title V. The fuel
economy standards are causing manufacturers to make widespread
changes in their vehicles, and it appeared that making the bumper
standard effective in 1980 would allow the manufacturers to make a
more cost effective transition. We are in rulemaking now on the
proposal and so I do not want to express my views on the issues
contained in it at this time. Apart from those issues, all other
petitions for reconsideration of the final rule were resolved in a
decision issued last week. That decision denied all but very minor
requests for change in the requirements.
You also asked about differences between the existing safety
bumper Standard No. 215 and the upcoming damageability bumper
standard for 1979 and later models. Standard No. 215 prohibits
damage to safety systems such a headlamps and brakes, and re-
quires integrity of other vehicle systems so that the vehicle does not
become dangerous to operate. The impact tests in the new
damageability standard are identical to the safety standard in
number, type, and location, but there are additional prohibitions on
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damage to vehicle exterior surfaces, including the bumpef itself.
One of the major differences we anticipate is in the technology that
will be used to meet the new standard. Soft face, aluminum, and
high-strength steel are all vying for use in the new designs.
Once the standard becomes effective, we will be carefully evaluat-
ing the specific design solutions selected by manufacturers to satisfy
the requirements. To the extent that these solutions fall short of
optimum technology, it may, of course, be necessary to amend the
standard to assure that consumers receive the greatest possible
economic benefit.
I would like to stop at this time and show a short film showing
work the agency has been doing on bumpers. Mr. Dugoff will
narrate.
Mr. DUGOFF. As you will see, this film illustrates some of our
ongoing R&D which relates to bumper performance. There is no
question as to the technical feasibility of bumpers which substan-
tially exceed the requirements of our pending standard. The real
questions about bumpers are practical ones: how much will they
cost, how much will they weigh, can they be integrated effectively
into a vehicle design which satisfies the various other societal goals
for the automobile-fuel economy, safety, and emissions.
The car you are about to see is one of NHTSA's integrated
research vehicles. These vehicles are helping us explore the tradeoff
questions which are fundamental to our safety, fuel economy, and
damageability rulemaking.
The damageability protection offered by the front of this research
automobile is being evaluated in a variety of ways.
First, we see a head-on collision with a rigid obstacle at 8 miles
per hour. The energy level for this crash was more than twice that
which present-day 5-MPH bumpers can withstand.
A common accident on our street is a low-speed rear-end collision
by a following car. This simulation of a 12-MPH rear-end accident
resulted in no permanent damage to either vehicle.
A slow-motion view of this impact shows that the entire front
deforms, then snaps back without damage.
The front end consists of a toUgh urethane plastic skin which
covers an energy-absorbing foam. The weight is only 31 pounds-
about half the weight of a conventional bumper which meets today's
FMVSS No. 215 bumper standard.
We believe these bumpers are practical and mass producible, and
our preliminary estimates of the incremental cost to the consumer
are very encouraging-somewhere less than about $30 for both
front and rear protection.
One of the major tradeoffs we have to look at in bumper design is
that between damageability and pedestrian protection.
Each year 8,000 pedestrians, 25 percent of them children, die
after contact with the front of moving automobiles. Approximately
100,000 are injured. The film shows, in slow motion, a driver's eye
view of this awful experience.
NHTSA has conducted a number of~ tests with pedestrian dum-
mies to evaluate ways of reducing the lethality of the front of
automobiles.
The best countermeasure which has been tested to date is the
damage-resistant bumper of the research safety vehicle.
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Test results show that the shape and softness of this RSV bumper
significantly reduce the severity of body responses for both child
and adult dummies.
This is a comparison of dummies being impacted by the experi-
mental bumper and a conventional bumper.
As a generality, the impact with this experimental bumper sys-
tem is approximately equivalent to an impact with a present-day
vehicle traveling at some 5 to 10 miles per hour slower.
These films are intended to give you some insight into the type of
studies that we are conducting in order to balance damageability
requirements with other goals-safety, fuel economy, emissions,
cost, damageability, consumer protection and information.
TITLE Il-AUTOMOBILE CONSUMER INFORMATION STUDY
Ms. CLAYBROOK. title II was enacted in the belief that consumers
would understand and act on meaningful comparative ratings of
automobiles in three areas: crashworthiness, damage susceptibility,
and ease of diagnosis and repair of mechanical and electrical
systems. I share this belief and I strongly believe that comparative
ratings of crashworthiness particularly would be increasingly valu-
able as the percentage of smaller automobiles increases. I would
like to pursue the purposes of title II vigorously, taking a pragmatic,
results-oriented approach to see if we can provide meaningful
ratings to the vehicle-buying public in the shortest time practical.
During my several weeks as administrator, I have attempted to
evaluate the government's progress in carrying out title II. I have
concluded that the Department has not pursued the program with
sufficient diligence or enthusiasm since the passage of the act in
1972. Approximately $2.7 million has been spent to date with no
useful results to the consumer. The fiscal 1978 budget, which was
prepared before I joined the agency, has no appropriations for this
title, and the manpower allowance has been cut from 10 to 5. At
present, two of these positions are filled.
Notwithstanding the absence of progress in title II consumer
information rulemaking, the agency has done a great deal of work
during the last 10 years which is relevant to accomplishing the
purposes of the title. For example, major rulemaking activities have
produced standards to protect occupants in a crash, such as collaps-
ible steering assemblies, door strength, roof crush resistance, and
interior impact protection. In addition, for the last 8 years the
agency has been actively involved in a rulemaking to improve
occupant restraint systems during which it has acquired a vast
amount of knowledge about crash survivability. In support of this
rulemaking, the agency has engaged in extensive research activities
in which vehicle structures, fuel system integrity, and test dummy
performance have been evaluated.
The key task assigned NHTSA under title II is to design a
program for development of comparative crash survivability and
damageability ratings of new vehicles. The agency should be able
within a few years to accomplish this task largely by building on
the extensive body of related knowledge. Indeed, the agency has
already developed basic comparative crash survivability informa-
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tion and has developed some important test criteria for vehicle
damageability.
In 1976, the agency completed testing of six 1975 compact auto-
mobiles for the purpose of selecting a vehicle to be used as a test
bed for advanced technology restraint systems. The tests were
barrier crash tests conducted at impact speeds of 45 miles per
hour-a speed far in excess of that at which survival could be
expected using current production, restraint systems. The criterion
for selection in this case was how~ much survival distance was left
after the crash. Survival distance is a measure of the margin which
is available to the restraint system in protecting the occupant.
Ratings of these vehicles, based on the restraint survival distance
criterion, are shown in the attached table.
The NHTSA routinely conducts crash tests of new cars to deter-
mine compliance with motor vehicle safety standards. In these
tests, an automobile is crashed into a rigid barrier at 30 miles per
hour. The agency recently measured the response of safety belted
test dummies in such compliance tests as a basis for comparison
with the dynamic crash test requirements of the passive restraint
option in the occupant crash protection standard.
In this test series, nine cars produced useful comparative data. In
the VW Rabbit, the Pontiac Sunbird, and the Chevrolet Vega, the
head injury criterion was exceeded because the shoulder belts
allowed the dummy's head to collide with the steering wheel of the
car. The agency also measured the loading of the safety belts,
because our research has shown that if the belt loading exceeds
1,500 pounds, it can cause chest injuries. Of the nine cars tested, the
Chevrolet Nova and Vega, and the Pontiac Sunbird produced belt
loadings in excess of 1,500 pounds.
As a cautionary note, let me stress that many questions about
instrumentation and measurement criteria for comparative ratings
were not explicitly considered in this testing because it was address-
ing other factors than consumer ratings.
Whereas the precise scope and timing are yet to be worked out,
NHTSA will be seeking to develop the following elements of a
meaningful comparative crash survivability information program:
1. An analytical scheme outlining the parameters of the system
would have to be designed.
2. Specific test requirements would have to be prepared and
demonstrated.
3. Testing designed to challenge the measurement requiremenmts
to determine if they are appropriate would have to be performed.
4. A test protocol would have to be formulated by which each
manufacturer would test most or all of its products to develop
ratings.
5. Effective means would have to be developed to transmit the
rating information to the consumer in a way that makes it possible
to use the data in purchasing decisions.
The information probably would have to be disseminated by the
agency as well as by the manufacturer with the vehicle. It is clear
that such a task will take several years to perform adequately.
I am also hopeful about the potential for developing useful
consumer information on damageability, diagnosis and repair under
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title II. There are several other ongoing activities which might be
able to provide appropriate damageability and repair information.
Within the insurance industry, damageability ratings are develop-
ing, although they do not separate driver differences and historical
effects from the vehicle's damageability characteristics. In the auto-
mobile maintenance industry, various manuals are routinely pub-
lished that estimate the amount of time required to carry out
maintenance operations by vehicle make and model. These, com-
bined with maintenance schedules of the manufacturer, perhaps
could form the basis in a rough way for estimating the comparative
cost of normal maintenance on new cars.
Mr. ECKHARDT. Perhaps it would be best for us to take a short
break right now. We will be back in about 10 minutes.
[Brief recess.]
Mr. ECKHARDT. Ms. Claybrook, you were about to start your film.
Ms. CLAYBROOK. Yes. Mr. Dugoff wjll narrate.
Mr. DUGOFF. This next filmclip illustrates some of the research
we have done in support of safety standards development which, as
Ms. Claybrook has pointed out, has direct relevance to the job of
establishing comparative crashworthiness ratings. First we will look
at some footage of the compliance tests in which measurements
were made of the forces on belted dummies.
The clip shows barrier crash tests at 30 miles per hour. The cars
are shown in the order of protection afforded to belted occupants.
The best car was the full-size Chevrolet.
A slow-motion replay of this test shows the violent motion of the
driver and passenger dummies.
Instrumentation was placed on the dummies and on the shoulder
belt. The vehicle's crashworthiness was rated based on its ability to
minimize the force levels on the chest and to prevent or mitigate
head impact.
The ratings of the remaining vehicles are as follows:
AMC Gremlin - 2
Ford Pinto - 3
VW Dasher - 4
Chevrolet Chevette - 5
VW Rabbit - 6
Chevrolet Nova-and these are getting into worse and worse
treatment of the dummy.
Pontiac Sunbird - 8
Chevrolet Vega .- 9
Each of the last four vehicles failed to provide acceptable levels of
protection under the test conditions shown here.
Next we see a slow-motion replay showing the inadequate protec-
tion of the Pontiac Sunbird.
Next, note the driver head strike in the VW Rabbit.
The final shot in this sequence is a 3O-miles-per-hour barrier test
of a 1977 Toyota pickup.
NHTSA will be continuing these crashworthiness assessments
which we hope will provide a basis both for improved safety
standards and for consumer information ratings.
NHTSA has been particularly concerned with the safety of small-
car occupants.
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This film shows barrier crash tests of four small cars at 40 miles
per hour. Here we are assessing the structure of production small
cars. We concluded that even these small cars have the potential for
40-MPH crash protection.
We are also evaluating various methods of improving the protec-
tion which can be built into small cars.
Let us examine improvements for the Vega. You will remember
the Vega scored lowest on our crashworthiness rating scale.
The belt system in a standard Vega is quite comfortable-even
though most Americans do not use it. The dash provides 4 to 5
inches of knee room for the average size occupant.
This Vega is equipped with an air cushion restraint system. Knee
padding has been introduced, but ample knee clearance remains.
The steering column, steering wheel, and air bag for this system
were adapted from standard GM parts by application of some recent
technology developments.
This test demonstrated that the driver was protected at a speed of
32 miles per hour, and the speed could have been faster. Injury
measurements were extremely low.
This is the same steering column air bag system that was sold in
luxury-sized GM cars between 1973 and 1976.
For comparison we will now look at the performance of the
standard Vega with the belt system with which it is currently
equipped. There is a big differenàe.
In this series of tests we are evaluating the structure of 3,000-
pound cars at 45 miles per hour. First is the Volvo. Here is a Mazda
RX-4. An Audi 100LS, a Capri 2-this is in order of decreasing
performance-an AMC pacer and a Chrysler Simca.
All of these cars have the potential for 45-MPH protection. We
selected the Volvo for further testing.
In these tests, the green Volvos are equipped with advanced air
bags. The orange Volvos are equipped with advanced belt systems.
Closing speeds for these crashes are up to 90 miles per hour.
In all tests shown, the advanced air bag provided adequate
occupant protection.
Let us view a slow-motion replay of the air bag system in a 90-
MPH closing velocity test. Injury measures for both the driver and
passenger were below the standard criteria.
Next, let us view an advanced belt system in an identical test.
Although dummy forces were higher than with the air bag, they
again passed the standard 208 requirements.
The advanced air bag even protects the out-of-position 6-year-old
child at 45 MPH, as shown in this test.
This is a condition that a lot of people worry about for air bag
protection. In this test the dummy passed with flying colors.
We believe that these tests illustrate some significant advances
which we have made in developing technology on which consumer
protection and information standards could be based. We intend to
continue to work diligently to focus this kind of work towards the
development of ratings in order to inform the consumer of his
choices in the marketplace as well as to stimulate the evolution of
technology which is beneficial to the consumer interests.
Ms. CLAYBROOK. To continue my statement:
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TITLE Ill-DIAGNOSTIC INSPECTION DEMONSTRATION PROJECTS
The 1972 legislation directed the initiation of 5 to 10 diagnostic
inspection demonstration projects by January 1, 1974, to be con-
ducted or supervised by the States which would undertake periodic
safety and emissions inspections, including followup inspections
after a defect is found and inspections upon transfer of a vehicle or
its involvement in an accident. The inspections were required to
provide specific technical diagnoses, data relating to vehicle-in-use
standards, vehicle designs that facilitate or hinder inspection and
repair, standardization of diagnostic systems and test equipment,
the motor vehicle repair industry's capability and cost structure for
the correction of malfunctions, the efficiency and cost-effectiveness
of facility designs, and recommendations as to feasible reject levels
for diagnostic projects.
Five projects were funded, in Alabama, Tennessee, Arizona,
Puerto Rico, and Washington, D.C., with the participation of 66,000
automobile owners and a total of 125,000 inspections by June 1976,
the initially established completion date for the projects. Three
projects have been given continuing funding until September 1,
1977, from the remainder of the original funding. The projects
produced evidence that diagnostic inspection would be beneficial to
the consumer, and such inspection resulted in needed owner repairs
of safety critical components, lower emissions, improved gas mile-
age, and generally lower overall repair and maintenance costs.
Analysis of data from the first, second, and third periodic inspec-
tions show a statistically significant improvement in the condition
of the vehicle safety and emission systems when compared with the
first inspection as a baseline. A 5 percent improvement in fuel
economy after tuneup was found in relation to a representative
sample of fuel consumption data provided under day-to-day driving
conditions for all vehicles.
I do not believe the department carried out this title of the law
with enthusiasm, but rather narrowed the scope of the mandate as
much a possible. A lack of coordination with the Federal Trade
Commission at an early date-there was coordination subse-
quently-is apparent in the failure to develop important informa-
tion about the probability of fraudulent repair following diagnosis.
Defect information in agency files was not given to vehicle owners
who passed through the inspection lanes. Nor was the inspection
information used to supplement pending defect investigations.
There apparently was no attempt to use the title III experience in
the inspection lanes as the basis for developing comparative ratings
under title II on the eae of diagnosis and repair. I can only conclude
that these funds could have been far better spent.
The special diagnostic inspection program was added to title III
by the Motor Vehicle and School Bus Safety Amendments of 1974,
and was substantially revised in July 1976. The special project
builds on the extensive field experience with the earlier projects.
The budget request for seven positions in titles III and IV is now
being considered by the House and Senate Appropriations
Committees.
The 1974 mandate was to assist in the rapid development and
evaluation of advanced inspection and diagnostic equipment suit-
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able for high-volume inspection stations, and to evaluate repair
characteristics of motor vehicles in a way to facilitate such evalua-
tions by small garages. In the 1976 amendments, the project was
focused specifically on research, development, and evaluation of
such equipment for assessing safety, noise, emissions, and fuel
efficiency aspects of the vehicle. Also, the amendments require the
Secretary to evaluate existing diagnostic analysis and test equip-
ment available for use in small garages and to report to Congress by
July 13, 1978, as to the scope of research and development neces-
sary to make such equipment compatible with state motor vehicle
inspection and diagnostic equipment. The report must include as-
sessment of the extent to which private industry can supply small
garages with low-cost test equipment to monitor compliance with
federal safety, noise, and emissions standards.
The basic contract which will evaluate state-of-the-art inspection
and diagnostic equipment, capabilities of repair shops and diagnos-
tic centers, and problems of new automotive technology, is about to
be awarded. The results of the first contract will be used to develop
high-volume vehicle inspection and diagnostic equipment tech-
niques that are compatible with~ the simpler equipment that is
available to small garages. The agency appears to be on schedule to
provide you with the 2-year report on the compatibility of existing
diagnostgic equipment in small garages with that in high-volume
inspection centers. The report also will cover the extent to which
low-cost equipment is available to monitor compliance with Federal
safety, noise, and emissions standards.
The projects completed to date with government funding tell us
there is a real problem in keeping cars properly adjusted. There is a
potential for savings to consumers if they choose to have diagnostic
tests performed in the future similar to those conducted by the
government projects. The five original demonstration projects
showed that the cost of a tuneup following diagnosis is generally
paid for in fuel savings. This type of savings is important to the
individual consumer and to the nation as a whole.
A well-conceived diagnostic program has the potential for reduc-
ing the lifetime operating costs of an automobile, something con-
sumers often do not fully consider in the initial purchase of their
car. Independent diagnosis can help to avoid the unnecessary re-
pairs that we all hear about, and it can pinpoint needed repairs
that have a great payoff in safety, emissions control, and fuel
efficiency.
TITLE IV-ODOMETERS
In the last Congress the department sought amendments to title
IV to authorize an effective odometer fraud enforcement program.
Through the efforts of your committee and the Senate committee,
these amendments were enacted on July 14, 1976, and provide both
civil and criminal penalties for odOmeter violations. To this point,
the new enforcement authority has not had a fair test, but we are
encouraged by the success of initial actions brought by United
States attorneys. In the most reáent of these cases, the United
States Attorney for Minnesota has obtained indictments against 10
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individuals alleging a widespread scheme of odometer fraud involv-
ing 120 separate instances since July 1976. The state attorneys
general have also made use of the authority conferred on them
under title IV to bring actions for injunctive relief and restitution.
Actions have begun in four States under this provision of the act.
The last administration proposed three permanent positions for
fiscal year 1978 to begin the department's enforcement activities
under title IV. We will not be certain whether that is enough or
whether any large permanent staff is necessary until we have had
an opportunity to assess the States' efforts in this area.
We are unable at this date to determine whether the amend-
ments have affected the practice of odometer spinning. The indus-
try and trade publications and associations have done a good job of
publicizing the new penalities, but no one has accurate information
on whether the practice has diminished. At the moment, the De-
partment of Justice and the United States attorneys have approxi-
mately 16 investigations in progress. We expect to gain a good deal
of information from the discovery and grand jury proceedings
associated with these investigations. At the same time, we are
improving the odometer disclosure statement required in each mo-
tor vehicle transaction to eliminate ambiguities that have impaired
its usefulness.
Mr. Chairman, this completes my prepared statement. My associ-
ates and I would be pleased to answer whatever questions you may
have.
[The following attachments were received for the record:]
SEAT BELT PERFORMANCE IN 30 MPH BARRIER TESTS
FMVSS No. 208 1,500 Lb. Shoulder
Vehicle Make and Model Req'm'nts Exceeded Belt Load Exceeded
Chevrolet Impala No (64%*) No (80%*)*
AMC Gremlin No (78%) No (89%)
Ford Pinto Pony No (84%) No (91%)
VW Dasher No (88%) No (95%)
Chevrolet Chevette No (92%) No (99%)
VW Rabbit Yes (143%) No (85%)
Chevrolet Nova No (99.7%) Yes (114%)
Pontiac Sunbird Yes (144%) Yes (121%)
Chevrolet Vega Yes (140%) Yes (128%)
* % of allowable head injury critera (hic less than or equal to 1,000) chest injury
criteria were met in all tests
** % of 1,500 lb. shoulder belt load
RATING OF SELECTED 1975 COMPACT CARS BASED UPON RESTRAINT SURVIVAL DISTANCE
Restraint Survival
Vehicle Distance-Inches
Volvo 244 10.5
Mazda RX-4 7.0
Audi 100-LS 5.4
Capri II 2.6
AMC Pacer 1.4
Chrysler Simca 0.5
Mr. ECKHARDT. Ms. Claybrook, the committee wishes to thank
you for presenting a very complete statement and also punctuating
it with film illustrations. I think this has been a very excellent way
to present the points.
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I am concerned about the proposed delay of the bumper standard
that your predecessor, Mr. Snow, :commenced. I would like to know
whether you intend to conduct a hearing before taking action on
the petition concerning delay, because the relevant section of title I
states that:
"All rules establishing, amending or revoking a bumper standard
under this title shall be issued pursuant to section 553 of title V of
the U.S. Code, except that the sectetary shall give interested per-
sons an opportunity for oral presentation of data, views or
arguments."
Ms. CLAYBROOK. As I understand, the statute requires a public
hearing.
Mr. ECKHARDT. That is section 102 (e)(1)?
Ms. CLAYBROOK. Right.
Mr. ECKHARDT. No hearing has yet been held, though?
Ms. CLAYBROOK. No, it has not.
Mr. ECKHARDT. Of course, as a result of the consideration of this
petition, you may reevaluate the question of whether or not to put
into effect the delay?
Ms. CLAYBROOK. That is correct.
Mr. ECKHARDT. I suppose a lot that I have to say here on the
question may have to do with water that has already gone under
the bridge with respect to what the agency has done about imple-
menting this act.
I really do not mean to go into great detail on that because I
think you have already stated here that, with respect to the
implementation of titles I, II, and III, the agency has operated
without an over amount of zealousness in accomplishing the con-
gressional objective.
Ms. CLAYBR00K. I am not sure I said that as to title I but I
certainly did as to titles II and III.
Mr. ECKHARDT. I would add, from what we have already heard in
this hearing, that it does appear that at the very least the agency
gave an extremely high level of credibility to the arguments by the
industry that more damage resistant automobile bumpers may not
be a cost effective means of reducing damageability.
We have seen automobiles, as a matter of fact I even drove in one
back in 1972 as I recall, before the passage of the act, that met the
standards at that time. Yet there was a 1974 DOT study and a
number of auto-maker studies as to the costs and benefits of
damage-resistant bumpers. They presented an apparently difficult
question.
We received a document for the record earlier critical of those
studies on grounds that they inappropriately only evaluated the
heavy bumper designs chosen by the manufacturers to comply with
the existing and proposed standards.
I think you have stated in your own testimony, and the films that
you have shown indicate, that we do not necessarily envisage heavy
bumpers.
Ms. CLAYBROOK. No, I do not think it is a necessity at all. We set
standards of performance, not standards of design, however.
Mr. ECKHARDT. Surely.
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Ms. CLAYBROOK. One of the ways of undermining the standards
that we set is to meet them in the most inefficient way. The early in
response to the standards of standard 215 was met in a most
inefficient way. I think there have been a lot of improvements since
that time.
Mr. ECKHARDT. I think there is sometimes a tendency also to meet
in very literal ways the performance standard compliance tests, so
that although the design passes the tests the overall performance
may be unimproved or even lowered. After all, the tests must be to
a certain extent arbitrary.
One would think that if the automobile manufacturers were
acting in good faith they would be willing to put a little bit more
into the design that meets practical objectives. As a matter of fact,
it seems to me from your films here that there can be built into the
question of repairability the question of reducing injury to pedestri-
ans which might not be actually called for by an existing standard,
but the difference in cost might be so slight as to create a tremen-
dously valuable social advantage.
Ms. CLAYBROOK. Also, we do have authority under the Vehicle
Safety Act of course to issue standards for pedestrian protection,
and the agency has not done so to date. It is a tough standard to
write. It has never gotten the kind of visibility and priority that I
think it deserves.
One of the problems that we face is really to put those various
issues together in the issuance of a bumper standard. However, I
would point out, Mr. Eckhardt, that the Cost Savings Act does put a
lot more priority on cost assessment than does the Vehicle Safety
Act, in terms of the responsibilities on the administrator to consider
those issues, and certainly one of the big problems in the bumper
area is that we do not have very much information on the actual
cost savings to owners.
There are a lot of folks with small damage to their bumpers who
would just as soon leave it that way. So you cannot say that because
a bumper costs X dollars, if it gets a small dent in it you cannot
presume that a person is going to go out to replace that bumper.
You know, a 5-miles-an-hour collision puts in some cases a rela-
tively small dent into some bumpers, and when people talk about
having to spend their money, they may not want to spend it on that
particular bumper.
Mr. ECKHARDT. That is right. Of course, your first standards have
to do not with the cost of the bumper but actually to how the
bumper protects the rest of the car.
Ms. CLAYBROOK. That is right.
Mr. ECKHARDT. We saw on films the other day that the bumper
seemed actually designed to cause injury itself to the lower part of
the front fenders. That struck me as a rather peculiar method of
design, unless of course--
Ms. CLAYBROOK. Is this 1977 model cars? Or is it 1976?
Mr. ECKHARDT. Yes.
Ms. CLAYBROOK. One of the problems when you set standards is if
the standard emphasizes one aspect the industry designs to meet
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that aspect. Then other elements are deemphasized or are not taken
into consideration because they do not have to meet the standard.
Mr. ECKHARDT. Of course what they obviously were designing
these bumpers for is to prevent injury to any of the safety mecha-
nisms of the car, but they were apparently absolutely oblivious to
the cost of repairs. We saw enormous cosmetic damage to the car.
And of course cosmetics is not like smearing rouge on one's face, the
damage costs a good deal more.
But it really does surprise me how slowly both industry and the
agency have proceeded under title I. The bill was designed largely
as a cost-saving measure, but that is a very objective test, and we
can carefully measure and analyze the way in which the design of
the bumper has affected the cost of repair. We cannot always so
easily measure the question of how the design of the bumper has
reduced injury. So what we were attempting to do is that which is
available and obtainable and I do not think that there is anything
in conflict between lessening cost pf repair and making the bumper
also consonant with safety, is there? Or do you feel there is?
Mr. DUGOFF. It is a challenge but the film we looked at a while
ago demonstrates quite convincingly that both purposes can be
achieved simultaneously.
Mr. ECKHARDT. What do you think about this? Does the congres-
sional mandate to perform cost-benefit analysis need further
clarification?
Ms. CLAYBROOK. Do you mean in this statute?
Mr. ECKHARDT. Yes.
You might just be thinking about that? That is the second bell. I
will be right back.
[Brief recess.]
Mr. ECKHARDT. I think my pending question was, does the con-
gressional mandate to perform cost-benefit analysis need
clarification.?
I might add in that connection that I gathered from your testi-
mony that there might be something in between a bumper standard
that purported to protect everything but the bumper and a bumper
standard that would be 100 percent perfect with respect to no
damage.
For instance, I can conceive of a situation in which there might
be some slight cosmetic-I am using that term again-damage to
the bumper itself that would still not be of great enough signifi-
cance to offset certain other advantages that might exist with
respect to that bumper.
Ms. CLAYBROOK. Yes, I think that is true.
Mr. ECKHARDT. I would be particularly concerned if such a minor
proposition delayed the effective date of the standard, but I do not
think we statutorily tie you into a rigid mold in that respect, do we?
Ms. CLAYBROOK. No.
Mr. ECKHARDT. Do you feel that you have enough flexibility with
respect to the statute to accomplish the desirable objectives of the
act?
Ms. CLAYBROOK. I think so. As to costs, it says the costs of
implementing the standard and the benefits obtainable as a result
of implementation of the sthndard and, when you measure the
21-335 0 - 78 - 11
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benefit, one of the considerations is, will the cost of repair be less as
a result of this standard?
Another consideration is, will there not be the necessity for
repair after the standard's implementation where there would have
been that necessity before?
One of the unknown factors is the extent to which consumers are
going to feel constrained or not feel constrained to replace their
bumpers when there is a small amount of damage. In other words,
there may be a very large savings because where they see a small
amount of truly cosmetic damage, they may say, I am not going to
replace that bumper. Then you may have a rather large saving.
Mr. ECKHARDT. I note that consumers are becoming more and
more unwilling, with increased costs, to do that. You see more cars
driving around with their bodies caved in than you did a few years
ago.
Ms. CLAYBROOK. It is a matter of priority, how you want to spend
your money, I would think.
Mr. ECKHARDT. I would like to talk about title II
Now, let's assume again that much water has passed under the
bridge and there is nothing we can do to change what occurred in
the past on title II.
However, I understand from previous testimony that certain
private insurance operations and certain private groups have ob-
tained some information along the lines provided in title II. As a
matter of fact, the insurance industry seems to think that that is an
adequate way to obtain information to evaluate it under title II
Ms. CLAYBROOK. What is an adequate way?
Mr. EcKHARDT. To do it through the industry examining the
question of the effect of repairability on insurance costs, et cetera.
But it strikes me that there might be other interests involved
concerning the public that the industry or those motivated to
examine the matter separately would not have.
Do you have a view on that point?
Ms. CLAYBROOK. In the 3~ weeks that I have been in office I have
not had a chance to develop a position on that. My only attempt in
preparation for these hearings was to try to query the experts in
the agency to find out why action has not occurred under this title
and whether or not there is a presumption that it is feasible.
In my view of the three issues in title II, the one that I think is
most important is crash survivability. I think the damageability is
less important. I think the health and safety issue is always
primary and if the agency were to take any action under title II,
first I should think it would take it under the crash survivability
portion. Indeed, if the industry is able to develop this information
itself, it seems to me a waste of federal funds for the agency to do it.
Mr. ECKHARDT. It does seem to me though that it is necessary for
the agency to receive and analyze the information which has been
obtained through private sources. To what extent does the agency
have personnel to do that at the present. time? What staff is
assigned to title II at the present time?
Ms. CLAYBROOK. I testified that there are two individuals assigned
to title II at this moment. As I understand it, one is on sick leave
and one is on loan to another office.
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Mr. ECKHARDT. I wonder what is planned with respect to that
situation? The sick leave person I, guess can eventually come back,
and presumably the one on loan might be reassigned, but that does
not seem to give much prospect of even analyzing available informa-
tion, say, from the industry.
Ms. CLAYBROOK. No, that is right.
I do want to point out that the industry has only recently in the
last couple of years really developed this information and it was
really unbelievable they did not do this themselves. But they have
now, I think under the auspices of the Insurance Institute for
Highway Safety and insurance related organizations, begun to de-
velop this information but we have not looked at it in any level of
detail. We have looked at it briefly recently, but beyond that we
have not done any analysis that 1 know of.
Is that correct?
Mr. DUGOFF. It is a value judgment. There are individuals on our
staff who consider that it has been analyzed adequately.
I think it is fair to say that the new administration intends to
take a much harder look at this, along with each of the matters
under titles II and III which we have characterized as having been
pursued in the past with less than the degree of diligence that we
see as appropriate.
Mr. ECKHARDT. Now there are several questions that you would
need to look into there. One is what kind of standards would give a
fair comparative consideration of various makes and models. Has
anything been done along those lines either by the agency or by the
industry?
Ms. CLAYBROOK. Well, you are concentrating on damageability
standards and I do not think the agency has done much work at all
in that area.
On crash survivability we have a much larger body of knowledge.
That is point one.
Point two is that the agency did in the late sixties issue three
consumer safety regulations under the vehicle safety statute. So they
do have some experience with what is involved in writing this kind
of regulation for comparative testing and the getting of that infor-
mation from the automobile manufacturers.
The way they did it under those earlier consumer safety regula-
tions was to write a testing regulation and require the submission of
the data to the agency by the early part of the model year. That
information then came in and was organized in a booklet published
and distributed through dealers and through the agency itself.
Mr. DUGOFF. Mr. Chairman, the fundamental problem that we
have with the insurance-derived data is that the industry is not
motivated as are we to discriminate between the differences that
are intrinsically associated with the different cars as opposed to the
differences associated with the different populations of people who
buy those cars.
It can be argued that certain models of automobiles are pur-
chased by a class of driver who is intrinsically more disposed to
take risks. From the standpoint of the industry, just as long as it
knows what body of buyers are buying the car and what the damage
done by the cars with those drivers is, that is fine. But we need to
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know separately the effect of the design characteristics of the
automobile as opposed to the typical characteristics of the people
who buy them.
So we have to be able to sort out those two effects. The insurance
data do not give us the handle on how to do that.
Mr. ECKHARDT. This subcommittee has had a good deal of exper-
ience with the industry in several different areas, including no-
fault.
Mr. DUGOFF. Right.
Mr. ECKHARDT. It has been my observation that the industry is
very, very concerned about that kind of injury that is not predict-
able. They would like to bring predictability into the picture.
They are not necessarily advantaged by reducing the ultimate
cost. As a matter of fact, to a certain extent the more completely
society is insured, even if that insurance is relatively costly, this is
no skin off the insurance industry's nose.
Now that is what troubles me about a failure to consider the
question of repairability. In the area of bodily injury, the cost is an
unmanageable cost and the industry never knows what the extent
of their risk may be. Naturally, they want to bring that within
manageable levels. But what currently concerns me is whether any
business, or anyone responding to a business interest is very much
concerned about the cost of repair.
The crash parts industry is perfectly happy with very high costs.
And as long as the costs are predictable the insursance industry is
not terribly unhappy about them. I do not see why they should be,
put it that way. The only people that are really unhappy are the
consumers.
Ms. CLAYBROOK. Yes. They are going to pass costs along and they
end up ultimately in the consumers' laps.
Mr. ECKHARDT. Of course, if we are in a habit of spending a very
large part of the total pay on automobiles, why that is a very happy
situation for the automobile manufacturers, the parts manufactur-
ers, the insurance industry, the oil industry, and everyone else. But
it seems to me that it is our burden to try to reduce that cost.
Now I do not for a moment mean to imply that the question of
personal injury is not the major concern for most people, but the
question that I have in my mind is whether or not the second
concern, cost of repair, is going to be paid much attention to unless
government does it.
Ms. CLAYBROOK. I think the answer is probably not.
It certainly isn't within the mandate of title II and the obligations
of this agency. I pointed out that I felt that the crash survivability
data was probably the most important and should be given first
priority. That is not to say that the others shouldn't be attended to.
One of the real disappointments to me was in looking over the
information under the title III diagnostic work where they were
very intimately involved in repairs and the cost repair, repairability
and so on. From what I can tell-and I am subject to correction
because I have only had a chance to look at it very briefly-I don't
think the groundwork was laid in the title III work for developing
repairability and consumer regulations and that is really too bad.
Mr. ECKHARDT. Let's stick with title III for a moment because I do
want to talk about title III.
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Ms. CLAYBROOK. As to title III, there were funds spent doing a lot
of work that, had it been organized in a slightly different fashion,
might have been used to lay the groundwork for issuing regulations
on repairability without the agency having to do a great deal of
additional research and preparation in order to prepare those
regulations.
Mr. ECKHARDT. It seemed to me in the testimony the other day
that a great deal more could have been accomplished under title III
had there been a plan to coordinate information from the various
projects paid for under the grants, had there then been some means
by which information was colleôted and coordinated in order to
draw detailed conclusions from it. 1 have not seen much of that type
of thing done in the planning of title III.
Ms. CLAYBROOK. Well, I think that is true. There are some
conclusions that can be drawn but I don't think it was correlated
enough. Also within the agency, as I point out in my testimony, it
was an unfortunate fact that we have an office that is investigating
defect problems and yet those problems were not made part and
parcel of the diagnoses of 66,000 automobiles. nor was the informa-
tion taken from those 66,000 car inspection and turned back to the
Defect Office for evaluation in furtherance of their investigations. It
really is most unfortunate.
Mr. ECKHARDT. This entire program under title III is at present,
planned to be ended within a relatively short time.
Ms. CLAYBROOK. That is right. There is a special follow-on or
additional project that came in more recent amendments, but that
is right, September 1977 is the end point for the remaining three
diagnostic activities.
Mr. ECKHARDT. From the testimony we got from the people in the
Alabama project, that seems to me to have been a very effective
project even if the information thus garnered is simply thrown
away. It has been valuable it seems to me by virtue of the fact that
it has curbed unnecessary repair; the very investigation itself has
generated certain consumer savings, as I would draw.
Ms. CLAYBROOK. Well, I don't disagree with you but you have to
ask the question whether or not that would warrant such a pro-
gram again or a continuation of it. It is pretty expensive to the
Federal Government to put on these projects. It seems to me that
their purpose was to look for solutions of a more generic nature
rather than just helping the people in that particular area of
Alabama.
Mr. ECKHARDT. I agree with that, but I rather gathered that even
the information presently garnered had not been fully reported and
fully obtained by DOT. I don't think some of the results have even
been asked for by DOT with respect to that project.
Ms. CLAYBROOK. Well, I don't know the answer to that. I asked
that question and was told that, by and large, the information that
was discovered during the course of the different diagnostic inspec-
tions was put into the computer and is available. Although some of
it was not put in the computer, it wasn't felt to be terribly
important and there wasn't the kind of money to do that analysis.
So there is the raw data, if you will, and there is also the computer
data.
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Mr. ECKHARDT. The FTC was asking for information from that
project as I understand.
Ms. CLAYBROOK. I must say I am a little frustrated about this FTC
business because I have been told over and over again the FTC
wants information. I have asked the staff if they have given the
FTC what they wanted and they told me they have given them
everything they have.
Mr. ECKHARDT. But the question is: Have they gotten it from the
project files?
Ms. CLAYBROOK. They can have anything that they want. They
have been given access to the computer tapes, to the raw files, to
the final reports, to the draft final reports. But what the FTC wants
from our agency as I understand it is an analysis of data. That costs
a lot of money and there is no money there to do that analysis and
it is also very specifically geared to a specific proceeding that they
are involved in on repair fraud.
Now, it is my view that this project probably, if it had in its
initiation, included certain additional pieces of information to be
developed-for example, the names of the different repair sta-
tions, whether they had mechanics who were trained, whether or
not they used flat rate manuals, and so on-if that information
had been put in the computer and had been asked for at an early
date,. it probably would have been useful to the Federal Trade
Commission's analysis. But it wasn't and it wasn't done. To go back
and redo all of that is astronomically expensive and to do some of
the analysis of the existing computer data is quite expensive. The
Federal Trade Commission is most welcome to any information, any
data, anything there is that exists to take and do with it what it
wants.
Mr. ECKHARDT. Well, now the act says each project shall provide
to the Secretary information and data relating to the development
of diagnostic testing equipment designed to maximize the inter-
changeability and interface capabilities and so forth and ~goes on to
say "the capability of the motor vehicle repair industry to correct
diagnosed deficiencies or malfunctions and the costs of such
repairs."
Now the Federal Trade Commission asks DOT for analysis of this
data and further collection of data-it says "Analysis of this data
and further collection of this data could reveal, for example, the
extent of consumer economic loss resulting from unnecessary re-
pairs particularly components of different types of repair outlets."
Now the Alabama people said that was one of their specific
observations and the Alabama project staff told our staff that
almost all of this information exists in their project.
Ms. CLAYBROOK. In raw form?
Mr. ECKHARDT. Including repair receipts.
Ms. CLAYBROOK. In raw form or in computer data?
Mr. ECKHARDT. Well, they say it would not take much effort to
analyze this from the information they have got and they said that
they would be willing to lend their program to other projects to
analyze their data.
Ms. CLAYBROOK. Well, as I understand it, this agency several
months ago introduced the Alabama people to the Federal Trade
Commission people. So I don't know what the problem is.
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Mr. ECKHARDT. Is there not data in the other projects as well?
Ms. CLAYBROOK. They can have the--
Mr. ECKHARDT. The thing of it is it is only your agency that can
reach these projects to which you would make grants directly.
Ms. CLAYBROOK. What do you mean can reach them?
Mr. ECKHARDT. I mean the Federal Trade Commission can hardly
command.
Ms. CLAYBROOK. They can have it and they have been offered it.
They can have the computer tapes and the raw data; they can have
the contractor reports; they can have anything in the whole world
that they want. I don't know what it is that they are asking for.
Mr. ECKHARDT. The DOT will not do the analysis of the
information?
Ms. CLAYBROOK. No, that costs money. We would have to get a
contractor to do that. If the Federal Trade Commission wants to pay
for it, we will get it done.
Mr. ECKHARDT. As I read it, the Act requires you to do that and
DOT has simply refused to abide by the congressional mandate.
Ms. CLAYBROOK. Where does the act require it?
Mr. ECKHARDT. FTC does not require it.
Ms. CLAYBROOK. Where does the act require us to do that?
Mr. ECKHARDT. Each project shall provide to the Secretary, and
this is section 302 of (b)(5), information and data relating to the
development of diagnostic testing equipment designed to maximize
the interchangeability and interface capability of test equipment.
Then it goes on to say; "The capability of motor vehicle repair
industry to correct diagnosed deflciencies or malfunctions and the
cost of such repairs, the relative costs and benefits of the project,
the efficiency of facility design, recommendations as to feasible
reject levels which may be employed in any such project and such
information and data as the Secretary may require."
Now is it the DOT's position that all you do is get in raw data and
say anybody who wants this raw data may take it and analyze it for
themselves?
Ms. CLAYBROOK. No.
Mr. ECKHARDT. As I read this is a mandate by Congress that you
get this information for some purpose.
Ms. CLAYBROOK. As I understand it, we have done that and
submitted all those reports to this committee and we have also
submitted all those reports to the Federal Trade Commission. As I
understand further, that is not what the Federal Trade Commission
is after. What they are after is information about the different
repair stations and the characteristics of the repair stations and
whether or not there was actual fraud committed between what the
diagnostic unit said should be done to the car and what the repair
facility actually did to the car, which characteristic of repair fa-
cility-
Mr. ECKHARDT. I understand they want something more than raw
data. They want an analysis but they don't necessarily want an
analysis of fraud. That is their business.
Ms. CLAYBROOK. Right.
Mr. ECKHARDT. But if the information is to be gathered together
under a mandate of the act, the Federal Trade Commission simply.
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wants an analysis of this data and further collection of data which
might reveal--
Ms. CLAYBROOK. What is the further collection of data? Because
the project is just about over. If they are going to require further
collection of data, that is what I think is the core of this issue. As I
understand it, these projects phase out in 3 months; they have been
structured for 2 years and certain data has been required to be
collected during the course of these projects.
Now the Federal Trade Commission comes in and says they want
different data to be collected, that caused--
Mr. ECKHARDT. Let's cut out that further collection of data and
just say: Suppose the Federal Trade Commission wants you to get
the data that has been collected by these various projects and wants
you to present them with that data in some kind of organized way.
As we understand it the Alabama project is able to present this in a
digested form, not just as raw data.
Ms. CLAYBROOK. I understand that is--
Mr. ECKHARDT. That is not a bunch of receipts.
Ms. CLAYBROOK. That has been done and given to this subcommit-
tee and given to the Federal Trade Commission.
Mr. ECKHARDT. How about the other projects?
Ms. CLAYBROOK. As to all of them, as far as I know.
Mr. ECKHARDT. I think only the Alabama project.
Ms. CLAYBROOK. I see. As to the other projects, apparently there
wasn't the same kind of similar in-depth study. The money avail-
able for these projects was used, Mr. Chairman, and a decision was
made and I do not know why, that the Alabama one would be done
in more depth than the others. So an analysis has not been done as
to the other four diagnostic facilities. There is no money available
as far as I know, for us to do that at this time.
Mr. ECKHARDT. So the other projects merely collected data but did
not analyze them.
Ms. CLAYBROOK. That is correct.
Mr. FOSTER. A little bit in perspective, sir, if I may. Each project
conforms with the specific requirements of the act, to gather infor-
mation and data. This specific information was gathered at each
project by system and by type of repair station, dealer, specialty
house-Midas, Amoco, this kind of thing-down to a small garage. We
had five categories of garages. We have that from each project. This has
been given to--
Mr. ECKHARDT. So this is uniform with respect to Alabama and
the other projects.
Mr. FOSTER. Yes, sir.
Mr. ECKHARDT. But Alabama has analyzed--
Mr. FOSTER. Alabama had a unique capability at the university
there. They offered a program to make an in-depth analysis and we
went along with it. We have been very pleased to read it. We have
provided that information to FTC.
Mr. ECKHARDT. What our staff has obtained from the Alabama
project is a statement to the effect that they not only have supplied
their own data and have analyzed it, but that they have also
programmed that data for computer analysis and, assuming the
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same raw data is available in other areas, they are capable of using
their computer analysis with respect to the other projects.
Ms. CLABYROOK. How much would it cost? Did they tell you?
Mr. ECKHARDT. We could find but. But I think you ought to find
that out. Does Congress have to investigate on whether or not the
DOT is performing its duty under an act of Congress?
Ms. CLAYBROOK. No. You said they could do it, I just wonder how
much it would cost.
Mr. ECKHARDT. Would your agency find that out? Find out within
the mandate of our order---
Ms. CLAYBR00K. Yes.
Mr. ECKHARDT. I think merely collecting data and having within
one's reach in a period of months the capability of putting that data
together, and merely contending that the agency is not under the
mandate of Congress to do it---
Ms. CLAYBROOK. I didn't say it wasn't under the mandate of
Congress to do it.
Mr. ECKHARDT. I know, but I think that is what Secretary Adams
said in his response to this letter to the agency.
Ms. CLAYBROOK. I would be delighted to do that. I think if the
Federal Trade Commission wants some unique analysis of this, I
think the Federal Trade Commission ought to pay for it.
Mr. ECKHARDT. I think that is true too, unless it is required under
the act. As I read the Act it is required under the act.
Ms. CLAYBROOK. As I have said the prior administration read this
act literally. The section 5 that you read to me talks about informa-
tion and data and the gathering of information and data, and it
does not talk about the drawing of conclusions, as I read this section
very quickly now. But there is nO reason that the agency cannot do
that. The problem that we now face is that the money that was
appropriated has been spent and I presume that the work that the
Alabama folks are talking about costs a good bit of money. I don't
have any idea. I don't want to speculate on what that cost may be,
but the fact is we don't have the money to do it right now as far as I
understand it. Maybe the most efficient way is for the Federal
Trade Commission and ourselves to split the cOst of doing a further
analysis or some analysis at all of the other four diagnostic
activities.
Mr. ECKHARDT. Well, as I understand your present situation, you
have an authorization which may or may not be completely appro-
priate. I would hope that we might help you come closer to the
point of getting your total authorization appropriated if we felt that
the agency would utilize such money in making these long studies,
which have cost a great deal of money, and as I think you have said,
the money has not been altogether well spent. But it would seem to
me most desirable that we make the most of them now. Collection
of the data was a highly expensive project and to simply get raw
data and let it go down the drain at this stage, it seems to me,
would be a terrible waste of Federal money.
Ms. CLAYBROOK. I do not disagree with that.
Mr. ECKHARDT. We might use Alabama's facilities to complete a
project which unfortunately has not been completed as I see it
under the mandate of the Act.
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Ms. CLAYBROOK. The oniy question I have is whether or not the
authorizations in section 321 by year can be used in this fiscal year,
but we will check that and get back to you. Although the authoriza-
tions in section 321 are by year, the sums appropriated under that
section are available until expended and therefore can be used in
this fiscal year. However, no contract funds were appropriated for
title III activities in fiscal year 1977, and none are included in the
fiscal year 1978 budget request now before Congress. With respect
to previously appropriated funds, there is an uncommitted balance
of only $12.5 thousand which would be insufficient to finance the
additional data analyses contemplated by the FTC.
Mr. ECKHARDT. I believe it is by year.
Mr. DUGOFF. Mr. Chairman, one important distinction. We will
certainly examine the facts here and make a determination if there
are any additional analyses which we deem to be appropriate to
properly discharge our responsibilities under the act, and we will
make the strongest efforts to make the appropriate arrangements to
do them.
However, to the extent the Federal Trade Commission's interest
is characterizing the performance of individual commercial estab-
lishment, we do not see it within the purview of our responsibility
under the act We will make as comprehensive and precise analyses
as we can of the generic classes of repair establishments, but I do
not believe we can construe our responsibilities under the act as
extending to making assessments of the propriety of the actions of
individual commercial establishments.
Mr. ECKHARDT. I do not think that is mandated under the act, nor
do I think that is the objective of the Federal Trade Commission. It
is not looking toward unfair deceptive practices but rather to
examine the whole question of whether unfair and deceptive prac-
tices are being perpetrated whether or not a rule might be made in
this area.
Ms. CLAYBROOK. I think they wanted to do it, though, by different
characteristics of repair facilities than we originally selected. In
other words, they were interested in whether or not the repair
facilities had use of a flat rate manual, trained mechanics, as to
whether or not they appeared to be involved in some fraudulent
activities. The only way you can gather that information is to see
how many different times they repair a certain car and whether or
not they did commit fraud and the other characteristics; not to go
after them for deceptive practice but rather to do some character-
ization of what your generic rules should cover.
Mr. ECKHARDT. I suppose statistics would show about 30 percent
of repairs are unnecessary repairs and would undoubtedly embrace
these practices and come to the conclusion that 30 percent of the
repairs are unnecessary, and have some further examination made
as to why they considered them unnecessary.
It would seem to me that would be most helpful to the Federal
Trade Commission with respect, for instance, to formulating a rule.
I do not know precisely what rule they would formulate, but we on
this committee have established a very due process-oriented
proceure for such rulemaking.
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If money were appropriated, is a period of time between now and
September 30 sufficient to do the study?
In other words, I understand you coqid extend the project without
legislative mandate-or could you? Actually, I am surprised that we
do limit that title to September 30, so if you need more time we
would have to give you more time statutorily.
Ms. CLAYBROOK. There are two different issues: One, whether or
not to extend those particular three projects and continue to collect
data, maybe even change what they do collect. Another issue is the
analysis of the data you already have.
Mr. ECKHARDT. I am not sure you would need statutory authority
because the project would in effect be completed and if you were
doing anything further it would not be a part of the project but an
an analysis by the agency itself, which I presume you could contract
out under existing authority.
Ms. CLAYBROOK. I do not think there is any question we can do
that, but I doubt we could do it in this fiscal year which ends
October 1.
Mr. ECKHARDT. Since the authorization I think is until expended,
you would not be limited in that respect.
Ms. CLAYBROOK. We will only be limited in appropriations to that
now being considered.
Mr. ECKHARDT. It does seem a pity to let data which has been
developed go without its full use. If there is any way this subcom-
mittee or the committee or any of its members might aid in
obtaining funds for that purpose, it would seem to me that would
maximize the use of the projects. Such a considerable amount of
money has already been spent for the projects themselves.
Much of the questioning here and much of the discussion which
has perhaps called for maximizing the agency's effectiveness I am
afraid has stemmed from previous action over which you had no
control. We look forward to cooperating and working with you
closely, and thank you very much for your testimony.
Ms. CLAYBROOK. Thank you.
Mr. Chairman, I have several submissions for the record in
response to your letter, items that were not covered by my written
testimony, and also a piece of information that comes from the
Norweigan bumper manufacturer who makes great claims about his
capabilities of supplying a bumper that meets our 1980 proposal at
10 miles rather than 5 miles, at a relatively small cost and of a
relatively light weight.
Mr. ECKHARDT. Without objection, it will be inserted in the record
at this point.
[The information referred to follows:]
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NORWEGIAN 10 MPH BUMPER SYSTEM
Raufoss, a major Norwegian bumper manufacturer that supplies
bumper systems to Volvo, Audi, Rover, Saab, and Porsche,
submitted information on a bumper system it has developed
which is capable of meeting the second phase requirements
of Part 581 at 10 mph (the second phase requirements prohibit
any damage to the vehicle, except dents to the bumper not
exceeding 3/8 inch and bumper set not exceeding 3/4 inch).
The Raufoss system, including bumper bar and shock absorbers,
is made of high strength and corrosion resistant aluminum.
It is capable of being adapted to all passenger cars.
The cost of the entire Raufoss bumper system is less than $60.
This compares to a cost figure quoted by Houdaille Industries
(a major domestic bumper manufacturer) of $163 for its high
strength steel system that is capable of meeting the second
phase of Part 581 at 5 mph. The cost of current model bumpers,
according to agency information, is $287.
The Raufoss bumper system's weight depends upon the weight of
the particular vehicle to which it is attached. For a 4,000
pound vehicle, the weight of the entire bumper system would
be 65 pounds. The total weight of Houdaille's high strength
steel 5 mph system would be 102 pounds. The weight of current
model bumper systems, according to agency information, is
268 pounds.
A major difference between the Raufoss 5 mph system and its
10 mph system is that the 10 mph system allows for greater
stroke. Due to the increased stroke, the system would require
4 to 8 inches more space in the longitudinal direction. This
might result in an increase in car length. However, Raufoss
makes the statement that it needn't.
The shock absorbers in the Raufoss system are equipped with a
device that limits maximum energy absorber force to a predeter-
mined level. In collisions at speeds greater than 10 mph the
absorber will have full function and reduce the speed of the
car to a lower level. Thus, the bumper system is capable of
effectively reducing damage to cars at speeds above 10 mph.
PAGENO="0171"
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-4
C
4
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172
PAGENO="0175"
CA~
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174
~
HEAD OFFICE 2831 RASFOSS. 1408'/AY-TELEPHOSE: 051-91 500-TELEPEINTER: 1144400- CAOLE ADDRESS: FADRIEKENE. RAUFOS
US Department of Transportation
National Highway Traffic Safety Administration
Washington, DC 20590
USA.
L
°~`~ TWT/GFu O3IEAUFOS~N00~y. April 27th5 1977
4/
Att.: Karen Dyson, Room 5219.
Subject, 10mph No-damage Bumper System.
With reference to our meeting on March 7, l977~ I hereby enclose
.1. drawings and description on our 10 mph bumper system.
Our indicative price for such a system is N.kr. 300,- per bumper,
shock absorbers and rubber mouldings inclusive.
I look forward to your comments on ourproposal.
Yours sincerely
per A/S RAUFOSS AMMUNISJONSFABRIKKER
Motor Vehic Par Division
Sales Manager.
.1. Ends. -
- AMMUNITION . METAL SEMIS - REPETITION WORE
DR. 108.4 ALUMINIUM DUILDINO CONSTRUOTI0Ns - TOOLS
PAGENO="0177"
175
The lEkm/h CiDmph~ no d~mege
bumper systems
AMMUNISJONSFABRIKKER
Head office : 2831 Raufoss Norway
Telephone : (061) 91500
Cable address : Fabrikkene, Raufoss
Teleprinter : 11444 ra n
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General background
Most damages to cars occur at low speeds and more
than 60% are located to the front end.
Figure 1 shows how the accumulated damage costs
increase rapidly with increasing speed in the lower
speed region. The beneficial effects of a bumper pro-
tection system increase correspondingly very rapidly
with increasing protection level.
The 10 mph bumper system developed by
A/S Raufoss Ammunisjonsfabrikker has the
following advantages:
1. Extremely low weight.
2. Very low cost increase compared to a 8 km/h
bumper system.
3. Low forces exerted to the tar.
4. Velocity sensitive hydraulic energy absorbers with
built in maximum force limitation have full function
at speeds higher than 16 km/h.
5. Made from guaranteed high strengh and corrosion
resistant aluminium.
6. Can be adapted to all passenger cars.
System weight and space requirements:
The use of aluminium in both bumper bar and energy
absorbers make the 16 km/h protection system ex-
tremely light.
The system gives `no damage-protection at a weight
less than present 8 km/h bumper systems in steel.
Due to longer energy absorber stroke the system re-
quires 100 - 200 mm more space in the longitudinal
direction of the car than common 8 km/h bumper
systems, but the total length of the car must not
necessarily be increased.
The relationship between bumper system weight and
weight of car is shown in fig~ure2.
Accumulated
Damage
Weight of
bumper system in kg.
34
32
30
28
26
24
22
20
18
16
14
12
10
176
Figure 1.
Speed
800 1000 1200 1400 1600 1800 2000
Figure 2.
Weight of car in kg.
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The bumper bar can be shaped with a large degree of
freedom according to the wishes of the customer and
is usually made with long rounded corners of styling
and cost reasons and to give the car the best protection
at corner collisions.
Hydraulic energy absorbers.
The kinetic energy of the car is taken up by high
efficient hydraulic energy absorbers patented by A/S
Raufoss Ammunisjonsfabrikker.
High efficiency and automatic reset without mechani-
cal springs are obtained by the use of a compressible
elastomeric media.
The weight of each absorber is only 2,0 kgfor a car
weighing 1500 kg.
The energy absorbers are mounted with a pin at both
ends and is given sideway support t~y a rubber cushion.
The relationship between weight of car, forces and
absorber stroke at 16 km/h protection is shown in
177
AMMUNISJONSFABRIKKER
Bumper bar:
Theweightof the bar is mainly determined by the
force that can be exerted onto the front structure of
the car.
The absorbers are equiped with a device that limits I
the maximum absorber force to a predetermined level.
At collisionsat higher speeds than 16 km/h the absor-
bers will havea full function and reduce the speed of
the car to a lower level. The bumper system does there-
fore have a considerable beheficial effect in reducing
damages to the car at speeds above the nominal design
speed.
70
60
40
30
20
10
Energy absorber
force in kN.
aooek~~.
I8co
i5~
saoo
100 120 140 160 180 200 220 MM
Figure 3 Energy absorber stroke in tim
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The energy absorbtion at different speeds is shown in
Typical force - strokecurvesat various speeds are shown
infJ~u~e_~
40
30
20
10
Typical force - stroke curves for a large car.
178
Km/h
Materials and surface treatment.
The bumper bar and energy absorbers are made from
guaranteed high strength and corrosion resistant alu-
minium with a minimum tensile strenght of ~o 2 =
36 kp/mm2 and °`02 = 60 kp/mm2 respective1~j.
All components can be delivered with the desired sur-
face treatment, ground, polished, anodised bright or
natural, or passivated as a basis for later painting.
Kinetic
Energy
2 4 6 8 10 12 14 16 18 20 22 24
Figure 4
Figure 5 Absorber stroke in mm
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179
AUTOMOBILE COMPONENTS AND SYSTEMS
RELATING TO SAFETY AND EMISSIONS
Part 570, Vehicle In Use Inspection Stand~rds (Title 49, Code of
Federal Regulations) contains the Department's criteria for Periodic
Motor Vehicle Inspection (PMVI).
These Standards address the brakes, steering system, suspension
system, tires and wheels. These are~the systems which vehicle safety
research has repeatedly shown to be the most critical tb reducing the
number of accidents that occur. A listing of the Standards addressed
in Part 570 is presented below:
o Brakes
570. 5(a) Brake failure indicator
570. 5(b) Brake system integrity
570. 5(c) Brake pedal reserve
570. 5(d) Service brake performance
570. 5(e) Brake hoses and assemblies
570. 5(f) Disc and drum condition
570. 5(g) Friction materials
570. 5(h) Structural and mechanical parts
570. 6 Brake power unit
o Steering Systems
570. 7(a) System play
570. 7(b) Linkage play
570. 7(c) Free turning
570. 7(d) Alignment
570. 7(e) Power steering system
o Suspension System
570. 8(a) Suspension condition
570. 8(b) Shock absorber condition
o Tires
570. 9(a) Tire tread depth
570. 9(b) Tire type
570. 9(c) General condition
570. 9(d) Damage
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* Wheel Assemblies
570. 10(a) Wheel integrity
570. 10(b) Deformation
`570. 10(c) Mounting
The Title III diagnostic (treatment group) inspections performed by each
of the five demonstration projects included all of the Part 570 items.
The nondiagnostic (control group) inspections performed at Chattanooga,
Tenn., and Washington, D. C., did not include a wheel pull inspection of
the brakes, and thus did not address Part 570(f), (g), and (h). Per-
formance of a wheel pull inspection was not a local statutory requirement
in those jurisdictions.
All of the projects also performed inspecti9ns of additional safety-related
items not addressed by the Federal VIU standard. These varied some-
what among the projects, and included headlamp function and aim, other
lamps and reflectors, seatbelts, body condition, glazing condition,
exhaust system, fuel system, underhood and electrical items.
Emis sions
In consultation with the EPA, the Department issued Part 590, Motor
Vehicle Emission Inspections, of Chapter V, Title 49, Code of Federal
Regulations. This regulation established the emission inspection criteria
to be employed by the demonstration projects, for motor vehicles through
the 1973 model year. The regulation established exhaust outlet emission
concentration crit~ria for no-load conditions at engine idle and at 2250
rpm, and for loaded-mode inspection at idle and a two-phase driving cycle.
Vehicle model years 1974 and newer are being inspected to new criteria
developed by EPA and NI-ITSA.
The Department issued no standards concerning specific emission-related
components and systems. The Guidelines for State Proposals suggested
that the projects consider inspection of the PCV valve, air filter, idle
speed, sparkplug firing voltage, available coil voltage, coil/condenser
oscillations, ignition point operation and dwell, ignition timing and varia-
tion, vacuum advance condition, mechanical advance condition, dynamic
cyclinder balance, and manifold vacuum condition. A typical diagnostic
inspection procedure for emissions was also included.
None of the projects inspected all of the items suggested, and there was
some variation among the projects. Most of the projects inspected the
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PCV valve, idle speed, spark plug firing voltage, available coil voltage,
ignition point dwell, ignition timing variation, and dynamic cylinder
balance. Inspections of the battery and charging system were also
frequently performed.
Those projects which conducted loaded-mode emission inspections used
the results in a "truth chart" matrix to further identify carburetion or
ignition problems as the probable source of the high emissions.
The information provided by the "truth chart" as to the probable cause
assisted the repair community in providing adequate repairs at reasonable
cost. During the first inspection cycle the rate of faulty emission repairs
was about 25 percent for both the diagnostic and control groups. During
the second cycle, however, the diagnostic group had a faulty emissions
repair rate of only 11. 5 percent, whichwas nearly 30 percent less than
the 16. 3 percent rate obtained by the control group. The diagnostic
group's average emission repair cost c~f $23.80 was also slightly lower
than that of the control group. Correcting the emission outages also
improved fuel economy an average of 5 percent.
The three extended projects have not altered their basic emission inspection
procedures, except for minor revisions of the engine analyzers to accom-
modate newer vehicles with high energy or other electronic ignition systems.
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DISCUSSION OF CONTRACT STUDIES FOR TITLE II
(1) Development of rating methods.
General Electric
Final rpt. March l976--$949,822
The GE study investigated two basic approaches to rating
automobiles for crashworthiness, damage susceptibility, and
ease of diagnosis and repair. Statistically valid differences
were registered between various models based on their accident
damage and injury histories, as found in insurance files,
state accident records, and NHTSA files. The magnitudes of
the differen~es measured by this "historical' approach were
small, and the disadvantages of this approach are several.
The contractor pointed out that ratings would not be avail-
able on a timely basis for the first purchaser, data on
small volume models takes too long to accumulate, and driver
characteristics affect the data. Statistically valid data
on maintainability were limited to comparison of manufacturers'
recommended maintenance schedules.
The other basic approach is "predictive", using mathe-
matical modeling and carefully chosen crash tests to stimulate
the accident environment to which it is expected the automobile
will be exposed. The predictive approach can produce data
on automobiles by the time they are introduced, including
newly introduced models which have no accident history and
small volume models which would take a long period to collect
statistically valid accident data. However, the contractor
noted that considerable refinement of math models and crash
test measurement techniques is required, before reliance
could be placed on this method. Predictive maintainability
techniques were not developed.
The contractor recommended more development of the two
methods. -
(2) Experimental crash testing to support predictive ratings.
Calspam Dynamic Sciences
Final rpt. Nov. l976--$376,284 Final rpt. April l976--$422,l43
To support the predictive method of rating automobiles
for crashworthiness and damageability characteristics, crash
testing as undertaken by Calspan and Dynamic Sciences in
separate contracts. Representative models of the same body
size and configuration were employed in barrier and car-to-
car ci~ashes that were designed to simulate as many accident
configurations as possible. Instrumented test dummies were
used to assess crashworthiness characteristics, restrained
by the seat belt system provided in the automobiles. One
contractor developed some of the mathematical simulations of
accidents that would be used in the predictive approach to
complement the crash testing.
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(3) Evaluation of Title II's effect on consumer's choice
of automobile.
Booz, Allen, and Hamilton
Not yet final--$467,l49
Booz, Allen, and Hamilton conducted research in auto-
mobile consumer decisions that would indicate how the choice
of an automobile is affected by comparative information on
crashworthiness, damageability, and maintainability, and how
best to present title II data to consumers to affect their
choice of automobiles. A literature search, a consumer
buying factors survey, and in-depth group interviews were
employed.
It was found that consumers have a high level of interest
in title II information~ Crashworthiness was most important, -
followed by maintenance costs. namageability had little or
no interest, presumably because consumers assume that their
insurance will pay the costs of repair above the deductible,
and that the choice of a more damage-resistant automobile
would not lower their insurance premiums. Consumers also
indicated that they would put much more reliance on govern-
ment ratings than those of the manufacturer.
(4) Evaluation of Title II's effect on nation's economy.
A.D. Little Center for the Environment and Man
Final brief ing Final rpt. June l975--$l09,l71
June l975--$88,757
Two separate approaches were taken to measure the
anticipated socioeconomic impact of title ii information on
consumers, automobile manufacturers, the automotive repair
and insurance industries, the national economy and society
as a whole. Mathematical modeling of new car sales,
accidents, and car operations was conducted by the Center
for the Environment and Nan. The accident model attempted to
compare the number of occupants suffering fatal or serious
injuries with and without title II information (and its
effects on purchases). The other studies estimated the
changed car-buying behavior, and~ its impact on total gasoline
consumption cost, crash repair costs, insurance cost and
routine maintenance and repair cost. The study concluded
that title II information would have little effect on the
choice of automobile. Only car manufacturers would be
expected to act on the information by improving the crash-
worthiness of small cars.
The second approach was to conduct panel discussions by
experts to assess, by group consensus method, expected sales
impacts of various hypothetical title II results. Estimates
were made of the effects oh gasoline and raw materials usage,
dealer profit margins, costs of repair and insurance, and
the rate of serious injuries and~ fatalities. It was the
judgement of the panels that consumers would be influenced
more by crashworthiness information than data on damage-~~
ability or ease of diagnosis and repair. The panels
estimated market share shifts of~ 2.3 percent at the most in
the 1976 model vehicles analysed, estimating market shifts
both toward and away from given makes and models.
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TflTE III
~DIOR VEHICLE DIAGNOSTIC INSPBCTION
DE~EHSTBATION PRQ3ECIS
The Diagnostic Inspection Deionstration Projects were mandated by
Title III of the ~ktor Vehicle Information aral Cost Savings Act. The
Act required the Secretary of Transportation to make grants and provide
technical assistance to the States in order to conduct not less than
five nor more than ten demonstration projects. Each project conducted
periodic metor vehicle safety inspections pursuant to criteria established
by the Secretary by regulation. flaission inspections were alsp conducted
pursuant to criteria established by the Secretary in consultation with
the ?drninistrator of the Environmental Protection Agency.
The Diagnostic Inspection Demonstration Projects were conducted in
Alabama, Tennessee, Arizona, Puerto Rico, and Washington, D.C., and
involved ?ederal and State agencies, universities and private
industry, as well as 66,000 volunteer participants in the largest
effort of its kind. For the period ending June 30, 19761 over 125,000
irispections had been conducted. In general, the program results dealing
with costs and benefits are positive. There is much evidence to support
the assertion that the concept of diagnostic inspection will benefit
consumers by providing than information and data on the condition of
vehicles, which if used properly, will result in greater safety, lower
emissions, improved gas mileage, and generally lower overall repair and
maintenance costs. Furtherrrore, the benefits for the consumer can be
significantly greater by innroving comaunication between the consumer,
the inspection facility, and the repair industry. Since the consumer
and the repair industry play key roles in the effective use of diagnostic
information iirprov~Tent in this critical cairrunication link is essential.
Findings bathe Questions asked by the Act --
1. Costs & Benefits. Analysis of the failure rate data frau the~
first, second and third periodic inspections siw a statistically
significant improvement in the condition of the vehicle safety and
emission systete when compared with the first inspection as a baseline.
Duissions Benefits. Program results supported the assertion that
specific diagnostic information on the condition of the engine helps
bath the rrotorist and the repair industry to properly and economically
correct emission control system. Analysis shov a 6-percent cost savings
for tune-ups and carburetor wurk for the group with diagnostic information.
Societal benefits in the form of cleaner air may be estjmated in terms
of reduced BC and CO emissions. For the 1968-1973 nodel year vehicles
in the program, the improverents in CO emissions at idle ranged from
11-54%, and BC from 18-59%.
Puel Econany. A 5-percent improvement in fuel economy after tune-up
was determined from a representative sample of fuel consumption data
provided under day-to-day driving conditions for all vehicles. A standard
EPA fuel economy test conducted for NHTSA in Phoenix, Arizona, before
and after minirraim cost emission repairs shoved up to 5.3% improvement in
BPG.
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Repair and Maintenance Cost. Potential cost-benefits of diagnostic
information to the consumer were statistically significant for tune-ups
and carburetor work. However, in other areas only a marginal savings
may be attributed to diagnostic inspection. The true value of diagrostic
inspection seans to be masked by dependence on the consumer and repair
industry to effectively use diagnostic information, the possible reliance
of the repair industry on the "flat-rate" manual, and the short duration
of the program.
The net cost savings achieved as a result of diagnostic inspection
should exceed at least* slightly the diagriontic center operating cost. It
was concluded that a typical inspection facility can inspect about 50 cars
per day per lane for about $14 per car (1976 dollars).
The quality of the repairs are value received by the diagnostic group
was greater than that of the control group.
2. Capability of Repair Industry to Correct Diagnosed Deficiencies
and the Cost of Such Repairs. The basic, approach was to ccrnpare re-
inspection failure rates after repairs. The reinspection failure rate
is a direct numerical measure of the industry' s inability to perform
an adequate repair. The average vehicle reinspection failure rates for
the diagnostic treathent group are 20.7 percent for the first cycle
inspection and 19.7 percent for the second periodic inspection. The
control group, without diagnostic information, showed an average failure
rate of 31.8 percent or 54 percent higher failure rate.
3. Vehicle-In-Use Standards and Feasible Reject Levels. The VIU
standards placed cinphasis on the five safety critical systems mast
frequently identified as causal or contributing factors to rrotor vehicle
accidents. The five systems are brakes, suspension, steering, tires and
wheels. The initial reject levels were particularly high, about 90 percent,
in states without PM~TI. There was a progressive improvement in the
conditions of the safety and emission systems at subsequent inspections.
Over 50 percent drop was achieved in the failure rates over the program
duration of 14-16 rronths.
4. The Efficiency of Facility Designs Maplcyed. Each of the five
projects wii~èncouraged to independently develop its facility(ies) and to
select its equipment. Growing out of this independent effort, the projects
evolved three basic diagnostic centers:
~ Single - lift lane (D.C.)
e Duplex - lift lane (Alabama) and
e Lane - bay combination (Tennessee)
The mast efficient design appears to be the duplex-lift lane.
However, the flexibility and cost effectiveness of the lane-bay cathination
is particularly premising for states without PM~1I where initial reject
levels may be relatively high.
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5. ~The Degree of Standardization of Diagnostic Syst~ns and Test
Equipment. One of the objectives of Title III was to gauge the level
of standardization of methodology and equipment. Given the design and
operational latitudes, the States did achieve a degree of standardization.
All followed the guidelines prepared by NHTSA and conducted diagnostic
inspections in accordance with Federally established VItJ Inspection
Standards and cx~nbined local criteria as required.
With the exception of the wheel aligranent tester, which enjoys a
virtual IronopDly, the multitude of diagnostic instrumentation and
analyzers available fran ozitnercial sources of fered a high degree of
standardization. The equipment is expensive ($73,000 per lane) and
requires high volume utilization to permit profitable amartization.
6~ Interchangeabili~y and Interface Capability of Test Equipment
and Vehicles. Relatively few cases of interchange/interface problsuis were
reported by the projects. The wheel alignment equipment encountered
difficulties with the width of several cars and failed to keep wheel in
contact with the equipment rollers. On these occasions, either the
vehicle design or the diagnostic equipment did not have the flexibility
to cope with the vehicle size or unique features. Lifts were not
canpatible with all vehicles makes, some vehicle makes tended to roll out
of test wells during brake inspection and same micrareters used for brake
measurements hindered expeditious diagnosis.
7. Vehicle Designs which Facilitate or Hinder Inspection and Repair.
Although there are a number of instances of poor vehicle designs that
hinder inspection and repair, e.g., brake asseiblies that require wheel
removal to inspect and repair, the mast canton problem encountered was
poor accessibility. This problem will became increasingly mare serious
as the vehicle size shrinks under pressure for greater fuel econany.
The trend toward increasinq canplexity, with addition of accessories
also teed to catpound the problem.
Special Studies. In addition to the EPA fuel economy study previously
cited, the Title III program funded studies on repair practices,
safety condition of vehicles involved in accidents and a study on the
attitudes and demographic make-up of motor vehicle owners and participants
in the diagnostic inspection projects.
Based on the survey and on unsolicited testinonials, consumer
reaction to the diagnostic inspection program has been positive. The
concept of an independent, objective, diagnostic inspection, having no
vested interest in the repair process, was well' received by bmth the
consumer and, interestingly, the repair industry as wall -- 93 percent
of program participants surveyed said they ~ould rejoin the program
if offered again, and 63 percent of representative national sample of
vehicle owners responded that they ~ould be willing to pay $10 or mare
for diagnostic service.
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Present Project Staffing, Funding, and Activities.
District of
Alabama Coluithia - Tennessee
State Project Staff 30 19 26
¶[~tal Federal Funds $2,993,475 $1,308,995 $2,978,182
Activities
The three projects are in full operation conducting diagnostic inspections
under the extension provisions of PL 94-364. The associated data being
collected consists of information on the condition of the safety and
- ~nissions subsystems of the vehicles. Trained counselors then give
this information to the vehicle owners. If repairs are called for,
the owners take their vehicles to the repair facilities of their
choice, discuss the desired repairs with the repairman, have the
repair facilities provide, the repair services, and return the vehicles
to the diagnostic inspection facilities for reinspections. The project
determines the adequacy of the repairs and records the repair cost
information.
The project extensions are designef to gain additional life-cycle
data on the older vehicles and to get information on the inspection
and repair of the newer vehicles that were not included in the earlier
effort.
Mr. ECKHARDT. Next is Deputy Assistant Administrator for Mo-
bile Source and Noise Enforcement, Dr. Shutler.
Doctor, you may proceed in the manner you see fit.
STATEMENT OF NORMAN D. SHUTLER, Ph. D., DEPUTY ASSISTANT
ADMINISTRATOR FOR MOBILE SOURCE AND NOISE ENFORCE-
MENT, ENVIRONMENTAL PROTECTION AGENCY
Dr. SHUTLER. We appreciate the invitation to appear before you to
discuss two subjects: (1) the history and results of consultation
between EPA and NHTSA on the diagnostic inspection projects
required by the Motor Vehicle Information and Cost Savings Act,
and (2) an analysis and evaluation of the usefulness of diagnostic
inspections as a means of ensuring compliance with emission
standards.
The Secretary of Transportation wrote to the Administrator of
EPA in August 1973 requesting EPA's assistance in providing data
and information on which to base regulations for the inspections.
Since then there has been considerable correspondence and infor-
mal communication between NHTSA and the staff of EPA's Office
of Mobile Source Air Pollution Control in Ann Arbor, Michigan. At
the request of NHTSA, EPA recommended the two types of emis-
sion inspection procedures which were used in the program. In our
terminology these tests are short tests because they are much
PAGENO="0190"
188
shorter and simpler to administer than the Federal test procedure
used by EPA to determine compliance by automobile manufacturers
with new car emission and fuel economy standards. We recom-
mended an idle test, which is the simplest and least expensive
shorter test available, or alternatively, a loaded mode test which
measures emissions while the car is in gear with its drive wheels
turning on a dynamometer. Many believe that the loaded test offers
some additional diagnostic capability over the idle test. These two
tests are representative of the tests available for use and which are
being used in various locations around the country today.
EPA also provided advice as to the pass-fail emission levels for
these tests that could be expected to be exceeded by 20 percent to 30
percent of the vehicles in different age groups. In addition, in order
to obtain fuel economy measurements on vehicles participating in
the diagnostic inspections, EPA cooperated through an interagency
agreement with NHTSA to provide for use of an EPA contractor
who was already testing cars for EPA in Arizona using the more
sophisticated Federal test procedure. It was from these measure-
ments that estimates of the fuel economy and emissions impacts of
the diagnostic and maintenance procedures were drawn.
With respect to the usefulness of diagnostic inspections in emis-
sions control, their potential has been recognized for some time. The
Clean Air Act Amendments of 1970 required that state implementa-
tion plans-plans developed by the States, or upon their failure to
do so, by EPA to attain health related ambient air quality stan-
dards-contain provisions for inspection and maintenance (TIM) of
automobiles where necessary. As a result there are some 25 urban
areas in 18 States plus the District of Columbia which have TIM
provisions in their plans. Further, more recent air quality data
indicate that there are additional States which contain urban areas
for which TIM will probably be required to meet the health related
ambient air standards. However, as a result of State and public
resistance, there are only four mandatory programs now in oper-
ation and another five programs in various stages of demonstration.
EPA is convinced of the need for TIM programs to help attain
ambient air standards in polluted urban areas and to help the
American public achieve the full benefits of the new car emission
controls for which they are paying. Data obtained over the last
several years consistently tell the same story. New motor vehicles
are failing to meet standards when in actual use. For example,
more than 60 percent of the 1975 vehicles tested exceeded one or
more of the emission standards during the first year on the road.
The cars are supposed to meet all standards for 5 years or 50,000
miles. The principal reason the vehicles fail to meet standards
appears to be lack of proper maintenance or improper adjustment
of the vehicles. Hence, we see TIM as a vital component of the
national effort to achieve effective control of mobile source
emissions.
In November of last year, EPA released a staff paper entitled,
"The Need For and Benefits of Inspection/Maintenance of In-Use
Motor Vehicles." A copy of that paper is attached to my statement
[see p. 190]. The paper draws on laboratory studies of the potential
benefits of TiM, on actual field data from ongoing TIM programs,
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and on EPA surveillance data from in-use vehicles. The results of
the DOT demonstration projects were not included in this paper
because of timing, but the fuel economy and emissions results of
those projects are consistent with and supportive of the results of
the other studies on which the paper is based.
The paper contains four principal conclusions which are answers
jo questions that have impeded the progress of State implementa-
tion of JIM programs. One conclusion is that deterioration from
ars on the road is greater than we had previously expected. State
esistance to JIM programs has, in part, been based on EPA's own
ublished assumptions that the emission reduction benefits of JIM
would only be needed in most urban areas for a matter of 2 or 3
years before the emissions rductions realized as a result of the new
car emission standards would enable achievement of ambient air
standards. More recent information indicates that vehicles which do
not undergo periodic effective maintenance will not come close to
meeting the emission standards over their useful life as had pre-
viously been assumed.
The second conclusion is that JIM will be cost effective in reduc-
ing pollutants from in-use vehicles. As a result of our earlier overly
optimnistic projections of the lasting benefits of the new car stan-
dards without effective maintenance and our failure to recognize
the probable benefits of JIM in reducing the long-term emissions
performance deterioration of in-use vbehicles, conclusions had been
drawn that J/M was simply not a cost effective way of reducing
emissions. More recent information has improved our estimates of
J/M's cost effectiveness so that it now compares extremely favor-
ably to further reductions in new car emission standards and to
other stratagies for controlling mobile source related pollutants. We
believe that an J/M program that has been in place for several
years with effective mechanic training and fairly stringent pas-fail
criteria can yield emission reduction benefits up to 40 percent to 50
percent for hydrocarbons and carbon monoxide.
The third conclusion is that the short tests which must be uised
in J/M can readily identify high polluting vehnicles. Arguments in
the past that short tests cannot correlate with the full Federal test
and that the short tests would not be effective on catalyst-equipped
cars have been disproved by the accumulation of more recent data,
at least as far as vehicles of current design are concerned.
The fourth conclusion is that most of the vehicles can be repaired
at a reasonable cost. Concerns over the cost impact on the public of
having vehicles repaired to reasonable emission performance have
of course engendered public resistance to J/M programs. However,
results from ongoing JIM programs and the DOT projects indicate
that average repair costs will nm in the $15 to $30 range. In
addition, EPA will soon propose regulations to implement the
performance warranty under the Clean Air Act which will protect
the owner of~ a properly maintained vehicle from emissions repair
costs for a portion of the vehicle's life. And finally, the consistently
demonstrated fuel economy benefits of JIM will offset a substantial
portion of the costs.
Under the Clean Air Act, it is the responsibility of the States to
implement JIM programs where they are necessary. However, we
21-335 0 - 78 - 13
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190
believe the Federal Government can provide seed money to encour-
age the States to set up these programs.
At this point we are hopeful that, armed with the additional
information we have acquired over the last several years demon-
strating the need for, feasibility of, and benefits of JIM, and assisted
by the use of Federal seed money, we will be able to persuade many
more States to implement JIM programs in the near future.
Thank you, Mr. Chairman. I would be happy to respond to any
questions you might have.
[Attachment to Dr. Shutler's prepared statement follows:]
THE NEED FOR AND BENEFITS OF INSPECTION
AND MAINTENANCE OF IN USE MOTOR VEHICLES
SUMMARY
This review of available data indicates that the Federal motor
vehicle control program is not reducing emissions from in-use cars
as rapidly as expected. Improper adjustments and a lack of proper
maintenance seem to be major reasons for the shortfall. The latest
technology with catalytic converters seems as sensitive as older cars
to proper maintenance and adjustment, although the results in
California with catalysts and air pumps are more encouraging. The
ability of short tests to identify high polluters is established and
the service industry seems capable of repairing failed cars at
reasonable cost. Costs of repairing catalyst cars are still somewhat
of a question although initial indications are that required repairs
will be similar to those on non-catalyst cars. Deterioration of vehicle
emission levels following I/N is still subject to some dispute but a
best estimate indicates that I/M will slow down the long term rate of
emission control degradation. I/M is an effective and cost effective
means of bringing cars into compliance with standards and early results
from New Jersey's I/M program are encouraging.
Michael P. Walsh
Mobile Source Enforcement Division
November 9~,. 1976
PAGENO="0193"
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Inspection/Maintenance (r/M) programs are intended to identify cars
which need remedial maintenance or adjustment and require repair on these
cars. Also by providing a general Incentive for owners to maintain their
vehicles It is intended to bring about an overall improvement in fleet
maintenance and reduced emissions. They are an Integral part of the
Federal motor vehicle control strategy.~ As illustrated In FIgure 1, other
key elements of this strategy include certification, assembly line testing
and recall. Initially, prototype vehicles are certified by EPA. Certification
confirms that the cars are designed so as to be capable of meeting standards.
Assembly line testing of production cars is conducted to assure that vehicles,
as manufactured, meet standards. In.~use surveillance is carried out to
assure that properly maintained vehicles continue to meet standards for
five years or 50,000 miles; engine families found out of compliance are
subject to recall. These are the three major elements of the Federal
Motor Vehicle Control Program (FMVCP), and their execution is solely a
Federal responsibility. However, compliance with standards Is ultimately
dependent upon the vehicles being maintained and adjusted correctly.
Inspection/Maintenance Is Intended to address this final step) to `close
the circle'. I/M is primarily a state responsibility with Federal support
i.n the forms of technical assistance and Federally prescribed warranties
against equipment and performance defects. t/M programs will provide
Incentives to vehicle owners to get the maintenance done, incentives
to the service industry to do the maintenance properly and Incentives to
the manufacturer to make vehIcles more serviceable. Through the- recall
and warranty elements of the Federal Motor Vehicle Control Program (FMVCP),
there will be ample incentive to the manufacturer to design vehicles which
if properly maintained can meet the standards.
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192
I/H has a prominent role in many of the most important components of
the Federal Motor Vehicle Control Program. To the extent that
I/M identifies, relatively rapidly, vehicles which may be out of
compliance it can feed this information back to the recall and assembly
line test programs thereby allowing EPA to focus investigations and test
orders on these vehicles. It is key to the warranty program by which
individuals can identify equipment defects and it is a legal requisite
for the warranty against performance defects which are detected by a
Federally prescribed short inspection test. It is also the major
ingredient in the federal anti-tampering program, as the threat of I/H
failure is considered a strong deterrent to tampering. Without inspection/
maintenance, all of these programs are significantly weakened.
* The need for and benefits of inspection/maintenance has been the
subject of intense controversy since the motor vehicle was identified
as a major air pollution source in the United States. It began when it
1 2*
was established that emissions were related to vehicle adjustment,
and was intensified when manufacturers opted for modified adjustments on
vehicles as the major thrust of their initial emission control techniques.3
As early as 1964, a study had been performed which showed initial emission
reductions on the order of 30% for hydrocarbons and 15% for carbon monoxide
were possible by means of a smog tune-up.4 This initial reduction has
subsequently been verified many times (see Figure 2) and even greater
initial benefits have been demonstrated.5'6 -
Unfortunately, much of the debate over 1/14 has taken place without the
benefitof sufficient data to resolve other questions such as
deterioration of cars without I/H, adequacy of short tests to identify
high Polluting cars (especially if they areequipped with catalysts), the
* numbers refer to references at end of Daoer.
PAGENO="0195"
193
ability of the service industry to repair high polluting cars and their
deterioration subsequent to repair. In the absence of data, the debate
continued. Advocates of I/M argue that the benefits of emission control
depend upon proper maintenance and that tIM programs are both effective
and cost-effective means of assuring proper maintenance.7 Moreover, they
continue without programs of this type, much of the potential benefit of
the Federal Motor Vehicle Control Program will be lost,8
On the other hand, opponents of inspection/maintenance have argued
that the FMVCP can solve the emissions problem without I/M as newer tech!,
nologies much less sensitive to maintenance are placed on cars~'9 In the
recent past, many people were pointing to the catalytic converter as such
a maintenance insensitive technology,10 Opponents have also argued that
there is no good short test which correlates with the full Federal Test
Procedure (FTP), and that therefore the benefits and cost~effectiveness of
I/M will be quite poor.10'11 In addition, it has been argued that consumers,
the owners of motor vehicles, will be thrown into the hands of an inadequate
service industry and that I/M is just a means of passing the buck from the
automobile manufacturers to individual consumers, thus shifting the burden
for cleaning up the motor vehicle air~ pollution problem from those respon-
sible for it)2
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194
The purpose of this paper is to review the available data to see
what this data reveals about the technical concerns which go to the
heart of the need for and benefits of inspection/maintenance. Particular
focus will be on deterioration of in-use vehicles with and without
inspection/maintenance, the ability of short tests to identify cars which
need remedial maintenance, the ability of the service industry to repair
high polluting cars and the costs and cost-effectiveness of I/N.
THE NEED FOR I/H
To the extent that cars in use meet standards throughout their
useful lives without the existence of I/H programs there is no need for
I/H programs. Conversely, to theextent that vehicles fail to meet
standards there is a need for additional strategies to lower emission.
levels. I/M,of course,is one s~ch option.
Figure 3 compares CO and HC exhaust emission levels based on data
collected during 1975 as part of the FY 74 emission factor program13'14'15
with those most.recently- ~ubTished by~EPA;16.For carbon monoxide, the
measured results are consistently higher than the estimates while for
HC the differences are insignificant except for 1975 cars. Based on these
new data, as well as data collected from previous emission factor programs,
new estimates of emission deterioration have been projected17'18 and these
are contrasted with the earlier estimates in Figures 4 and 5. These figures
show emission estimates normalized according to their respeTëtiVi~tandards and
PAGENO="0197"
195
indicate that previous estimates of 1975 model year emissions were
optimistic, especially for carbon monoxide. In summary, the previous
predictions that average emissions would initially meet standards and
continue to do so for six or seven years for carbon monoxide, and two
or three years for hydrocarbons have been found overly optimistic.
Estimates based on the data now indicate that carbon monoxide emissions
are initially higher than had been estimated, exceeding standards on the
average in the first year, and are projected to deteriorate rapidly in
subsequent years. For hydrocarbons, initial emissions are slightly higher
than estimated and are projected to exceed the standard on average after
about one year. The relationship of emissions for pre-1975 model year
cars to their appropriate standards as~ a function of time is similar to
the relationship for 1975 models.
The first question that comes to mind is why do vehicles in use emit
at such high levels? The studies summarized in Figures 6 and 7 indicate
that the major reason is a lack of proper maintenance and/or proper adjustment
on in-use vehicles. More specifically, for 1973 model year vehicles with
approximately 15,000 accumulated miles,~two different studies were carried
out. One focused on vehicles maintained according to manufacturers'
instructions and which were carefully tuned-up prior to testing. The other
focused on vehicles tested without- special preparation, i.e., vehicles in their
normal state of maintenance.20 As the figures illustrate, carbon monoxide and
hydrocarbon levels for the normally maintained cars are substantially gre~ter
PAGENO="0198"
196
than for those maintained and tuned according to manufacturers' specifications.
For 1975 vehicles, parallel studies have not been done, except for normally
maintained cars at an average of about 8000 miles.21 The normally maintained
cars were subdivided according to idle adjustment into "properly adjusted"
and"improperly adjusted" subclasses.22 These data indicate that the sensitivity
to idle adjustment may be even greater for 1975 models than it had been in
earlier model years, and again the impact is most significant for carbon
monoxide.
Recent data have also been collected on 1975 cars in California23'24
and these data, surmiiarized in Figure 8, show that California cars are
considerably cleaner than 49 state' cars, relative to their respective standards,
although at least some of the data indicates that they are dirtier, than
expected. The reason for the relative cleanliness of the California vehicles
is somewhat speculative.25 The California assembly line test program may be
responsible; the mild climate may lead to less tampering than in other areas;
the state's certified repair facilities may result in better vehicle
maintenance; thetechnology which places much greater emphasis on air pumps
may be more forgiving of maladjustments or less likely to receive them because
of better driveability; the Title 13 Program which requires dealers to properly
set cars following maintenance may keep emission levels low; the tradition
which has been established over many years in California of controlling emissions
from cars, though difficult to quantify, may have the greatest impact of all.
Analysis by the California Air Resources Board however, indicates that
considerable tampering is going on, perhaps affecting as many as 15 - 20% of
1975 MY cars.24 Carefully screened 49 state cars have shown as much as 20
-25% tampering on 1975 cars after only one year.26 Since EPA studies have
PAGENO="0199"
197
shown that tampering increases with vehicle age,27'28 this raises questions
about the long term effectiveness of the California and 49 state vehicle
emission controls. A particular question for all of these vehicles is,
what will happen to the emission controls after 50,000 miles? The
Federal tools of recall and warranties are applicable only for 5 years
or 50,000 miles,whichever is less. I/Mis the only compliance t~chnique
ihich provides for the periodic evaluation of whether vehicles in use
continue to control emissions throughout their life.
Although many questions remain, two firm conlusions can be drawn. First,
with the possible exception of California, it is clear the Federal Motor
Vehicle.Control Program (FMVCP) is not fully achieving its goal of bringing
cars in actual use into compliance with standards. Second, the lack of
proper vehicle maintenance and, particularly for 1975 models, improper
vehicle adjustment seem to be primary r~asons for the shortfall. Recognizing
the problem, attention must be focused on the questions of whether I/M can
identify the high polluting vehicles, whether such vehicles can be repaired,
the costs of such repairs and, in general, the overall emission reduction.
ABILITY OF SHORT TEST TO IDENTIFY HIGH POLLUTERS
How well can I/M do its job? The fir~st question in this regard is how
well can an I/M short test identify high polluting vehicles? The full
Federal Test Procedure (FTP) of course, is the best true measure of a
vehicle's pollution characteristics but this is too expensive and time
consuming to be considered for a large scale I/M program. Several short
tests (idle, key mode, Federal three mode among others) which are better
suited to I/M have been investigated in terms of their ability to predict
FTP emission levels in a consistent reliable manner but the results have
PAGENO="0200"
198
not been too encouraging.53 However the results have been very encouraging
in terms of being able to predict whether a car would pass or fail the
standard on the FTP. In effect, though the short tests have not demon-
strated the ability to predict the absolute FTP result with any high degree
of confidence, they have shown that they can discriminate with high confi-
dence between clean and dirty cars. For example, based on data collected
in the FY 74 emission factor program, a recent EPA study29 selected cut~~
points for the idle test which give approximately the same rate of errors
of comission (cars failing the short test but which would pass the full
federal test procedure) as the federal test procedure Itself would give
i.e., 5% of the total population.30'31'32 Vehicles were then screened ac-
cording to these cutpoints with results as shown in Figure 9. These data
suggest that the idle test is capable of segregating low polluting cars
from high polluting cars.
PAGENO="0201"
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GETTING CARS REPAIRED
Once the polluters are identified, it is up to the service industry
to repair the cars. Questions have been raised about the ability of the
service industry to do these repairs as well as the cost of repairs.
Figure 10 shows the types of repairs required to pass the Portland I/N
-program and Figure 11 shows the associated costs for vehicles tested by
the Portland, Oregon, New Jersey and Arizona I/M programs through early
l976.~~ These data show that the types of repairs that are needed to pass
an I/M program are mainly carburetor adjustments and tune-ups, repairs
that are within the capabilities of the service industry today. Less than
10% of the failing vehicles in Oregon required repairs costing more than
$50.00; in Arizona, this percentage was up to 14% while in New Jersey it
was 22%. The costs of repairs is reasonable in each case. Over 70% of the
repairs in Oregon cost less than $10.00 and the average is under $20.00.
In New Jersey, 55~ of the repairs cost less than $25.00 and the average
is under $35.00. In Arizona 66% of the repairs cost less than $25,00 and
the average is about $25.00. The present average I/N associated repair
cost is below the average cost generally experienced for a tune up.35
Higher repair costs are reasonably expected in New Jersey, since the less
stringent standards applicable there will concentrate failures in the cars
with more serious problems.
Since virtually all the repair and cost data are based on results with
pre 1975 cars, major questions remain~ regarding the ability of the service
industry to repair catalyst cars and the associated costs of suCh repairs.
Recall testing carried out on certain catalyst equipped 1975 models indi-
cates that repairs similar to those listed in Figure 10 were
PAGENO="0202"
200
sufficient to restore these cars to a degree necessary to pass the idle
test with concomitant FTP emission reductions; However, these results
are preliminary and somewhat speculative with regard to other engine
families.36 Better data should be available in the relatively near
future from the EPA restorative maintenance study which is currently
in progress. * -
The New Jersey program has also demonstrated that the service industry
can change in response to an I/ft program. During the first year of the
voluntary program in New Jersey, after failing vehicles were fixed,
on retest, their failure rate was still consistently above 40%. However,
within two to three months after the program became mandatory, the failure
rate on retest fell to approximately 18%. This strongly indicated that a
mechaniqs learning process was taking place.37 Mechanics now had to fix
the vehicles properly because owner's had an independent check on the
quality of repair. Training programs were developed by private industry
in order to address the needs of the service industry. In particular, the
EXXON Corporation provided a training program for most of its own service
stations to be sure that work done by those stations would not result in
complaints.38 At this time, some stations in New Jersey advertise that
they will guarantee their repairs and that the work that they do will
assure passing the inspection/maintenance program.
DETERIORATION WITH I/M -
Far and away the most important and controversial technical issues
regarding I/N effectiveness focus on deterioration, both during the
PAGENO="0203"
201
year between inspections on failed cars which are repaired and the long.
term deterioration of an I/M fleet compared to deterioration which wourd
have occurred on that same fleet in the absence of an I/M program, In the
first case, the benefits over the course of a year are substantially less
if the failing cars once repaired, deteriorate back to their previous level
in 2-3 months compared to 12-15 months. Not only is the absolute emission
level to which these vehicles rise important, and the time it takes them to
rise to it, but the shape of the deterioration curve can be quite sig~.
nificant. For example, as illustrated in Figure 13, the end of year emission
level could be reached by three different shapes of deterioration rates:
(1) A very rapid initial deterioration (possibly due to
tampering) with a gradual leveling off,
(2) A linear deterioration throughout the year,
(3) A very slow deterioration for most of the year with a
rapid climb at the end.
Traditionally, EPA has assumed a~ linear deterioration rate back to
the level which would exist without I/M, thereby concluding that the
annual benefits of I/M are about one-half the initial reductions.39
To date, only one study has been carried out which measured emissions
from the same group of cars over a full year period,40 These tests were
conducted during 1975 by Olson Laboratories for the California Air Resources
Board on four similar groups of 1968 through 1974 model year vehicles,
systematically selected to represent the proportions of these vehicles in
the January 1975 California vehicle population. Only two groups, an I/N
21-335 0 - 78 - 14
PAGENO="0204"
202
group and a control group were used in the analysis which is illustrated
in Figures 13 and 14. Figures 13 and 14 show emission levels mormalized
to initial test levels. Results are illustrated for all vehicles which
completed the program on one hand and for selected vehicles with deteriora..
tion rates less than 400% on the other, Each vehicle in theI/M group was
initially subjected to an idle test with approximately 41% failing, and
those which failed were given adjustments and repairs only sufficient to
pass the idle test limits. Vehicles were tested according to the 1972
FTP as received, and (idle test failures only) after repair and at 1, 3,
6, 9 and 12 months. The control group was tested at the start and end of
the year. Although this study is not definitive,41 all analyses have
concluded that the previous EPA deterioration estimates with I/M are too
high.
When the data from all cars which have completed the years testing are
used, it appears that the I/M fleet deterioration rate is greaterthan
the control (non I/M fleet) deterioration rate. This deterioration how-
ever is not sufficient to bring these cars back to non-I/M levels within
the one year time frame. Moreover it has also been pointed out that
the control fleet deterioration rate is unusually high for HC, and that
if more normal deterioration were observed the I/M fleet deterioration
could have reached, the level of the non-I/M fleet by year~s end.42 This
analysis led to the conclusion that the overall effectiveness of I/M in a
program's first year is approximately 70% of the immediate reduction
following repair at the start of the year,42'52
PAGENO="0205"
203
* A~second:an~1~ys.ish~focused on apparent discrepancies in the
data, the most extreme of which went from 4.88 grams per mile HC at
the 9 month test point to 110.07 grams per mile at the `12 month test
point. If data points are screened from both the I/M and non I/M fleets
according to a criteria of eliminating all cars with deterioration rates
greater than 400%, the I/M fleet is reduced from 109 to 105 cars and
the non I/M fleet from 91 to 86. The I/M fleet in this case deteriorates
at about the same rate as the non I/M fleet and for HG does not even
return to its pre I/M level in the course of a year. For GO, the fleet
does deteriorate to the pre-I/M level 6ut not to the non I/M control fleet
level.
A third approach has been even more subjective, focusing on a
theoretical comparison of possible differences between the I/M and non
I/Mfleets that could impact on deterioration rates. On the one hand, it
has been postulated that the I/H fleet~would have a lower rate of
deterioration because the quality of service would generally improve
resulting in better maintenance for all cars across the board. In addition,
to the extent that defective vehicle components exist and are identified
and repaired in the I/M fleet, it is argued that the subsequent secondary
deterioration to other parts due to that defect (e.g., catalyst burn up
due to ignition misfire problems) will~be eliminated or at least ameliorated.
PAGENO="0206"
204
On the other hand, it has been argued that more tampering may be done
to the I/N fleet to compensate for possible driveability problems which
exist when the vehicles are adjusted to low emission levels.
Based on a careful review of the available data and lengthy discus.~
sions between the respective offices, it is the collective best judgement
of the technical staff that the deterioration rates of the I/N and non I/N
fleets are the same within the limits of accuracy of current data, over
one year, although there are those who still disagree. This judgement is
reflected in the draft revised Appendix N which was circulated for comment
on September 30, l976.~~
In the past, EPA has assumed that the percentages of emissions
reduction obtained from successive I/M cycles was identical to that achieved
in the first cycle. The assumption of a repeat performance was reasonable
given a further assumption that one year ofter an I/M cycle emissions
return to the levels that would have existed in the absence of I/N. How-
ever, with the tentative conclusion as stated above that the I/N fleet does
not deteriorate to the levels which would have existed in the absence of
I/M and if one further assumes that the I/M vehicles will deteriorate and
be repaired in future years in the same manner as in the first year, the
I/M benefits will increase with time. Over a long term in other words,
if both of these assumptions are true I/N programs will actually impact
on the lifetime deterioration of vehicles.
This is illustrated in Figure 15.
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205
No study exists or will exist for~several years which proves or
disproves the hypothesis that t/M vehicles will deteriorate over their
lifetimes at a lower rate than non I/N vehicles. Concern has been
expressed that because of some of.the assumptions made, vehicle emissions
are estimated to remain at or near standards throughout their entire life
if a maximum* I/N program is properly applied. There is considerable
disagreement over whether this is actually possible.
Other sources of data however, were reviewed to determine if they would
shed any light on this issue. Figures 16 and 17 summarize linear regressions
of all available emission factor and in-use compliance CO and HC data for
1972 and 1973 model year cars normalized according to their respective zero
mile values. The emission factor data are representative of the normal
non-I/M emission levels of in-use cars while the IUCP data represent what
emission levels could be if all carswere properly maintained and tuned up
just prior to testing (this may be a~most optimistic I/M case except for
the potential impact of I/N on the qUality of maintenance performed).
There is a lot of scatter in the data but it does indicate that properly
maintained and tuned cars tend to have lower deterioration rates for CO
and HC than `normal" cars. While this does not prove that I/N cars would
have lower lifetime deterioration rates than non I/M cars, it does indicate
that to the extent that I/N results in more and better maintenance it would
tend to lower deterioration.
The only data available which address this point for catalyst cars are
from the FY 74 emission factor program and are summarized in Figures 18 and
19. It should be noted that these figures represent extrapolations
`~emi~-annua1 inspection, 50% stringency factor with mechanic training
PAGENO="0208"
206
of data from vehicles with very little mileage accumulation; the average
accumulation is only 8700 miles and 75% of the sample have fewer than
15,500 miles. With the data available, however, regressions of emissions
versus miles were developed for two groups of cars, those which would
fail an idle inspection test with a cut point of 1.5% CO and those vehicles
which would pass. The CO deterioration rate for failing cars is significantly
greater than for passing cars while the reverse is true for HC.
In terms of average emissions over a 100,000 mile lifetime, CO emissions
are projected to be substantially lower for passing cars than for failing
cars, HC slightly lower.
One of the critical factors upon which the impact of I/M on long term
deterioration hinges is the use of constant short test cut points. It
has been argued that the use of constant cut points would increase failure
rates over time which would be politically unacceptable leading to a
gradual loosening of these cut points.42 Such a loosening would reduce
any tendency to slower I/M vehicle deterioration rates. Of course, the
critical question here is whether there will be ~a shift in in-use vehicle
maintenance due to an I/M program or not, a shift which not only goes to
the amount of maintenance performed but probably more importantly to the
quality of maintenance and adjustments made.
Figure 20 surrinarizes the mean idle test emission levels in the New
Jersey I/N program for each model year vehicle tested.44 These data
show that idle emission levels are fairly stable in New Jersey, presumably
in response to the I/M program. A glance at failure rates over time as
shown in Figure 21 also indicates a fairly stable failure rate for cars more
than a year old. Data collected in New York State45 and Pennsylvania46as illustratn
PAGENO="0209"
207
in Figures 22 and 23 also show that idle emissions in New Jersey are
lower than in surrounding areas although negligibly so for HC. These
data tend to support the argument that the quality of adjustment will
improve with I/N and that therefore there will not be a need to relax
I/N cut points with time.
THE BENEFITS OF A GOOD I/N PROGRAM
Ultimately, the benefits of an I/N program depend on the quality of
the program which is implemented. A poorly designed or poorly managed
I/N program could result in very little oreven no benefit. On the other
hand a well planned, well operated system could be the cornerstone of the
entire motor vehicle control effort in a given area. What distinquishes
a good program from a poorer one? At a minimum, any good program would
provide for the following:
(1) regular periodic inspection (at least annually) of all
vehicles for which emission reductions are needed.
(2) retest of failing vehicles following maintenance to
assure that necessary maintenance is performed.
(3) a careful and well designed quality control program to
assure the reliability of the inspection system and
equipment accuracy. This *should include routine
maintenance, calibration and inspection of equipment
and routine auditing of results.
Some question exists whether a decentralized I/N program could ever
~achieve the full benefits that I/N is estimated to be capable of. If it is
to do so, certain additional provisions such as the following must at a
minimum be included:
(4) licensing of the inspection facilities which assures the use
of proper equipment in an acceptable manner by people who
have been adequately trained.
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(5) maintenance of records on each vehicle inspected including -
vehicle descriptive data, test results and vehicle operator
signatures. Records must also be maintained on the calibration
of testing equipment.
(6) copies of these inspection records should be submitted on a
periodic basis to the governing agency for auditing.
(7) the governing agency should inspect each facility at least
every ninety days to check the faci~lities' records, check
- the calibration of the testing equipment and observe that
proper test procedures are followed.
(8) the governing agency should have an effective program of
unannounced/unscheduled inspections both as a routine measure
and as a complaint investigative measure.
Finally, all good I/ti programs should have provisions for dealing
directly with the service industry to keep them informed of system changes,
to handle consumer complaints and to assure that excessive tampering is
not taking place.
The absence of any or all of the above would tend to reduce the amount
of emission reductions achieved by an I/ti program and could even make the
program worthl ess.
Based on the data presented in previous sections on emissions deterioration
without I/ti, idle test/FTP correlation etc., and further based upon certain
key assumptions regarding service industry repair capability and deterioration
following such repair, also discussed previously, I/ti emission reduction
estimates have been generated using computerized models.47'48 The results
indicate that the benefits of a good inspection/maintenance program can be
significantly greater than had previously been believed. This conclusion is
summarized in Figures 24, 25 and 26 which reflect EPA's current estimates of
emissions with and without inspection/maintenance for 1975 and 1974 model cars.
PAGENO="0211"
209
These figures show that stabilized emission reductions of 41% and 25%
are possible for CO and HC, respectively, after several years of an~ I/H
program with catalyst cars at a 30% stringency factor. Higher or lower
numbers are possible if more or less stringent programs are implemented.
Since there is an almost infinite variety of options available to a
state in implementing a program (exemptions for vehicles requiring repairs
which cost in excess of some upper limit, selecting cutpoints which focus
on one or another pollutant exclusive~y, emphasizing fleet vehicles, to
give but three examples) the actual emission reductions attainable must be
estimated on a case by case basis.
As previously discussed, vehicles in use are deteriorating faster than
predicted. Accordingly, cities with mobile source air pollution problems
cannot expect the improvement previously estimated in their transportation
control plans. However, I/H can do more than previously estimated and can
therefore make up much of the shortfall. Figures 27 and 28 illustrate the
significance of these new estimates for an average U.S. City* with a mobile
source air pollution problem as ~iell as certain representative cities (Phoenix,
Boston, Seattle and Portland). These data show that the typical emission
reduction from 1970 to 1980 expected from the FMVCP has been reduced to
about 60% of the previous estimate fdr CO and about 70% for HC. If an
I/H program were instituted in each of these cities in 1977 with a 30%
stringency factor** and mechanic training, much of the short fall could be
*averaga JJ,S, car popuTation end qye~'a9a n]ileaga growth rate for areas with
existing transportation control plans.
**strtngancy factor i:s ~ ireesura of the rigor nf a program based on the
estimated fraction of:thayefticla popul4tion whose emissions could exceed
cut~pomnts for either or both tarbán monoxide and hydrocarbons were no
improvements in maintenance habi~s. or quality to take place as a result of
the program.
PAGENO="0212"
210
regained. Whereas I/H was formerly estimated to be responsible for about
4% and 10% of the total reduction from the FMVCP and I/H combined for CO
and HC respectively, the latest estimates attribute roughly a third to
I/H for each pollutant.
COSTS OF I/H
Cost data with regard to I/H are available from three main sources, the
CARB/Olson study, anqlysis of existing programs by the Office of Transportation
and Land Use Policy (OTLUP) and the Office of Planning and Evaluation (OPE)
and are summarized in Figure 29.
In the CARB/Olson study, a comparison of the maintenance and fuel costs
was made between the I/H fleet and the control fleet over a one year period.
The results showed that while the maintenance costs were greater for the
I/H fleet than for the control fleet, they were more than offset by the fuel
savings (assuming $0.60 per gallon fuel prices) of the I/H fleet resulting
in a net annual savings of $0.42. This study did not estimate the inspection
fee which would be required to pay for system start up, administration and
operating costs. A close examination of the data collected in this study
indicates that the maintenance cost estimate is probably high in that
subsequent to being repaired sufficiently to pass the idle inspection test,
the repair costs for the remainder of the year were found to be higher for
the I/H fleet than for the non-I/fl fleet. This seems counterintuitive in
that one would expect some of the repairs which were done for the I/H fleet
to be needed during the year by the control fleet cars. One possible
explanation is.that since there was less control of the non-I/H fleet during
the year some of the repair costs on these cars were not reported. Of course,
PAGENO="0213"
211
an alternative explanation might be that the cars repaired to pass the
I/M program experienced driveabilii~y problems and were subsequently
`readjusted" to drive better and therefore had higher costs.
The OTLUP analyses49'5° were based upon data collected by operating
I/M programs and, derived relations~ips between initial failure rates and
repair costs and fuel consumption. It included estimates of fixed and
operating costs of various program t~'pes. As in the CARB/Olson study,
OTLUP's analyses lead to the conclusion that incremental maintenance
costs are completely offset by fuel savings; therefore the entire program
costs would be fixed and operating expenses~ for the inspection, which
ranged from $1.76 to $1.92 per car.
The OPE analysis42 was based upon a very comprehensive review of all
existing I/M programs as well as studies of maintenance habits in the
absence of J/M. Fuel savings were not analyzed by OPE but maintenance
costs were found to range from somewhat lower to about the same as~
previous estimates. The inspection costs to cover start up and operating
expenses were estimated to be higher than OTLUP's estimates.
Based upon all three studies a best estimate is that incremental
maintenance costs and fuel savings approximately offset each other and
that the average out of pocket costs of JIM will be about $5 per car.
Some individuals, however, may be significantly impacted with high repair
costs possibly coupled with increased fuel consumption.
PAGENO="0214"
212
Not included in this analysis is another cost which is not a direct out
of pocket cost but is still a perceived cost; this is the cost of time
spent getting one's vehicle inspected and in some cases repaired and
reinspected. OPE has estimated this time to average 21 minutes with an
average cost of about $1.75 per car.
There are no comprehensive cost data with regard to catalyst cars and
inspection/maintenance. While the inspection costs will be the same as
for non-catalyst cars there is considerable uncertainty with regard to
the repair costs. Limited low mileage data collected by EPA36 indicate
that no permanent catalyst damage has occurred and normal engine repairs
bring cars into compliance, therefore indicating that the repair costs ~iould
be approximately the same as for non-catalyst vehicles. However, there is
concern that in the long term, extended use of vehicles out of adjustment
could result in permanent catalyst damage and therefore much higher repair
costs. To the extent that this is true, however, the effectiveness of I/N
should also increase.
I/ti COST EFFECTIVENESS
Based on the cost data cited in Figure 29 and the latest estimates of
I/N effectiveness, the cost-effectiveness of I/N has been calculated.
These results, and for comparative purposes the estimated cost effectiveness
of reducing light duty vehicle emission standards from interim to statutory
levels51 and stage 1 Vapor Recovery59 are summarized in Figure 30. I/N is
shown to be quite cost effective.
PAGENO="0215"
213
RESULTS IN NEW JERSEY
The first fully mandatory I/N prdgram was instituted by the State
of New Jersey in February 1974. The developers of the program adopted a
gradual phase-in approach, starting with relatively lenient standards
to allow the public and the service industry to adapt to the program and
slowly tightening down the cut points to the level which they initially
deemed appropriate. They remained in~Phase 1 until November of 1975, failing
approximately 12% of the cars which were inspected. Investigations carried
out by EPA have indicated that gross tampering has gone down in New Jersey,
from 10% in 1974 to 5% in 1975 (compared to 15% recorded in 1974 in
Washington, D.C., an area, which while it has not been demonstrated to be
an appropriate control group for New Jersey, is *known to differ in at least
one significant respect, that it was without a mandatory I/N program in
1974). 27,28 While many factors could influence this, including the
energy crisis and the change in vehicle mix, it could also be at least
partly the result of the disincentive provided by I/N.
Finally, while air quality is influenced by many factors (meterology,
transport, emissiQn standards, etc.) `it is enough to note that average
ambient carbon monoxide levels and contraventions of the air quality
standard declined during this ti~me period. These results are summarized in
Figures 31 and 32. Similar reductions in oxidant levels were not recorded
although this is not surprising since oxidant levels are much more impacted
by other sources, and the initial New Jersey cut points were oriented more to
carbon monoxide than hydrocarbons.
PAGENO="0216"
214
VOLUNTARY I/N
In many areas of the country, private groups and fleet managers have
instituted inspection programs on their own just for the fuel economy and
maintenance benefits which are derived. Notable among these are the
California State Auto Association, the City of Phoenix and various fleets
of American Telephone and Telegraph. In the latter case, recent data from
Cincinnati Bell as summarized in Figure 33 indicate that the program may
have helped reverse a trend of.rising running expenses (less gasoline) for
their fleet. Similar reductions were noted in fuel costs as shown in
Figure 34, which may also be due to their new maintenance program.
CONCLUSIONS
This review of available data indicates that the Federal motor vehicle
control program is not reducing emissions from in-use cars as rapidly as
expected. Improper adjustments and a lack of proper maintenance seem to be
major reasons for the shortfall. The latest technology with catalytic
converters seems as sensitive as older cars to proper maintenance and adjustment,
although the results in California with catalysts and air pumps are encouraging.
The ability of short tests to identify high polluters is established and the
service industry seems capable of repairing failed cars at reasonable cost.
Costs of repairing catalyst cars are still somewhat of a question although
initial indications are that required repairs %/ill be similar to those on
non-catalyst cars. Deterioration of vehicle emission levels following I/N
is still subject to some dispute but a best estimate indicates that I/N will
slow down the long term rate of emission control degradation. I/N is an
* effective means of bringing cars into compliance with standards and early
results from New Jerseys I/N program are encouraging.
PAGENO="0217"
215
REFERENCES
1. WHAT ARE WE DOING ABOUT COMBUSTION? BY J.M. Campbell, AMA
(August 16-18, 1954) SAE Preprint
2. SOME EFFECTS OF ENGINE-FUEL VARIABLES ON EXHAUST-GAS HYDROCARBON
CONTENT BY F.G. Rounds, P.A. Bennett, andG.J. Nebel, GMC
(January 10, 1955) Presented at SAE 50th Annual Meeting
3. USING THE ENGINE FOR EXHAUST CONTROL' BY C.M. Heinen, Chrys1e~
(November 1962) SAE Paper S355
4. SMOG TUNE-UP FOR OLDER CARS BY Miles L. Brubacher, Donel R. Olson
(April, 1964) SAE Paper S403
5. DATA ON EXHAUST EMISSION REDUCTION BY TUNE-UP BY John Hawley
(February 24, 1971) New York State Department of Environmental
Conservation
6. EFFECTIVENESS OF SHORT EMISSION INSPECTION TESTS IN REDUCING
EMISSIONS THROUGH MAINTENANCE BY R.R. Carlson, T.A. Huls,
S.G. Kuhrtz, G.M. Wilson (June 24-28, 1973) APCA Paper #73-80
7 THE NEED FOR A NATIONWIDE SYSTEM OF COMPREHENSIVE PERIODIC MOTOR
VEHICLE INSPECTION BY The Automotive Industry Coordinating
Committee To Conserve Energy
8. THE NEED FOR AUTOMOTIVE EMISSION INSPECTION BY Miles L. Brubacher
(September 20, 1972)
9. CLEARING THE AIR Federal Policy on Automotive Emissions Control
BY Henry D. Jacoby, John D. Steinbruner, and Others,Ballinger
Publishing Co., 1973
10. THE AUTOMOBILE AND THE REGULATION OF ITS IMPACT ON THE ENVIRONMENT
BY Frank P. Grad, Albert J. Rosenthal, James A. Fay, John Heywood,
John F. Kain, Gregory K. Ingram, David Harrison, Jr., Thomas
Tietenberg (June 30, 1974)
11. ECONOMICS AND PUBLIC POLICY: THE AUTOMOBILE POLLUTION CASE BY
Donald N. Dewees MIT Press, 1974
12. VEHICLE INSPECTION AND MAINTENANCE FOR MASSACHUSETTS BY Greg
Conderacci (May 27, 1976)
l~3. HIGHLIGHTS FROM PRELIMINARY ANALYSIS OF RESULTS FROM EPA EMISSION
FACTOR SURVEILLANCE CONDUCTED IN CHICAGO Eric 0. Stork to
Roge~ Strelow (November 14, 1975)
PAGENO="0218"
216
14. 1974 EMISSION FACTOR PROGRAM Eric 0. Stork to John Hidinger,
B. Steigerwald, Norman Shutler (February 27, 1976)
15. PRELIMINARY DATA ON EXHAUST EMISSIONS FOR 1972-1975 MODEL YEAR
CARS FROM THE FY 1974 SURVEILLANCE PROGRAM Eric 0; Stork to
Roger Strelow
16. SUPPLEMENT NO. 5 FOR COMPILATION OF AIR POLLUTANT EMISSION FACTORS
U.S. Environmental Protection Agency (December 1975)
17. ESTIMATES OF EMISSION DETERIORATION FOR 1975 MODEL YEAR VEHICLES
Marcia Williams to John DeKany (August 6, 1976)
18. NEW ESTIMATES OF DETERIORATION FOR THE 1968-1974 MODEL YEARS
BASED ON THE CHANGE IN MEAN EMISSIONS OVER MILEAGE Lois Platte
to Eric Stork (September 13, 1976)
19. 1973 In Use Compliance Program
20. AUTOMOBILE EXHAUST EMISSION SURVEILLANCE ANALYSIS OF THE FY73
PROGRAM BY Jeffrey Bernard, Paul Donovan, H.T. McAdams,
Calspan Corp. (July, 1975)
21. FY74 Emission Factor Program, preliminary data
22. EMISSIONS FROM PROPERLY ADJUSTED IN-USE VEHICLES, 1975 MODEL
YEAR (MSED INTERNAL MEMO)
23. FY74 Emission Factor Program, preliminary data
24. TELEPHONE CONVERSATION WITH CALIFORNIA AIR RESOURCES BOARD
REPRESENTATIVE (September 3, 1976)
25. DIFFERENCE BETWEEN CALIFORNIA AND 49-STATE EMISSION RESULTS
FOR 1975 MOREL YEAR CARS Michael P. Walsh to Norman D. Shutler
(June 17, 1976)
26. INTERNAL MSED DATA
27. RESULTS OF THE D.C. TAMPERING SURVEY Albert K. Lee to Director,
Mobile Source Enforcement Division (June 10, 1974)
28. THE INCIDENCE OF TAMPERING ON CARS IN NEW JERSEY DURING 1975
Mobile Source Enforcement Division (June 22, 1976)
PAGENO="0219"
217
29. COMMISSION/OMISSION ERROR PATES USING I/M CUT POINTS Michael
P. Walsh to Benjamin R. Jackson (Nay 7, 1976)
30. ACCEPTABLE LEVEL OF ERRORS OF COMMISSION Michael P. Walsh to
Norman D. Shutler (November, 20, 1975)
31. ACCEPTABLE LEVEL OF ERRORS OF COMMISSION II Michael P. Walsh to
Norman D. Shulter (November 27, 1975)
32. ACCEPTABLE LEVEL OF ERRORS OF COMMISSION John P. DeKany to
Norman D. Shutler (December 12, 1975)
33. NEW JERSEY,ARIZONA AND OREGON REPAIR COST DATA compiled BY
Joe Cutro (October 12, 1976)
34. CUMULATIVE COST-OF-REPAIR SUMMARY BY Oregon Department of
Environmental Quality Vehicle Inspection Program (September
19, 1975 - April 30, 1976)
35. TME AUTOMOBILE TUNE-UP, Champion Spark Plug Company Second
Edition (April, 1975)
36, INTERNAL MSED DATA
37. NEW JERSEY'S AUTO EMISSION INSPECTION PROGRAM: ~N ASSESSMANT
OF ONE YEAR'S MANDATORY OPERATION BY John C. Elston, Daniel
Cowperthwait (June, 1975) APCA Paper #75-42.3
38. EFFECTIVENESS OF MAINTENANCE, IN REDUCING EMISSIONS ~Y Jerome
Panzer and Hugh F. Shannon, Exxon Research and Engin~ering
Company (September 25, 1974) MVECC III
39. 38FRl5l98, June 8, 1973, Appendix N, Emission Reduction Achievable
th~ough Inspection Maintenance and Retrofit of Light Duty
Vehicles
40. DEGRADATION EFFECTS ON MOTOR VEHICLE EXHAUST EMISSIONS, Olson
Laboratories With State of California Air Resources Board
(March, 1976)
41. ISSUES REQUIRING RESOLUTION TO PERMIT COMPLETION OF APPENDIX N
REVISION Eric 0. Stork to Ed Tuerk (August 23, 1976)
42. VOLUME 3: INSPECTION/MAINTENANCE: COST-EFFECTIVENESS AND
FEASIBILITY OF IMPLEMENTATION BY E.J. Bentz, Sandra J~
Bodmer-Turner, Barry Korb, William P. White III,
Office of Planning and Evaluation
21-335 0-78-15
PAGENO="0220"
218
43. Draft Revised Appendix N, Hidingerto Addressees (September
30, 1976)
44. Discussion between R. Reichlen and Daniel Cowperthwait
45. Data from Walt Pienta, NYS DEC
46. AEROSPACE REPORT ON `ANALYSIS OF REGIONAL DATA ON VEHICLE
IDLE EMISSIONS' John. P DeKany to Eric Stork (July 7, 1976)
47. COMPUTER SIMULATION OF EMISSION INSPECTION PROCEDURES - ASSESSMENT
OF EFFECTIVENESS By Marcia E. Williams (June, 1976) SAE
No. 760555
48. COMPUTER SIMULATION OF VEHICLE EMISSIONS FROM AN INSPECTION
AND MAINTENANCE PROGRAM Jay Wallace to Michael P. Walsh
(September 27, 1976)
49. BEST ESTIMATES OF I/N FUEL ECONOMY BENEFITS, Joe Cutro,
OTLUP, 4/1/76.
50. BEST ESTIMATES OF I/N COSTS TO CONSUMERS, Joe Cutro, OTLUP
51. DRAFT ENVIRONMENTAL AND INFLATIONARY IMPACT STATEMENT,
INTERIM HEAVY DUTY ENGINE REGULATIONS FOR 1979 and LATER
MODEL YEARS, MSAPC, 4/21/76.
52. OTLUP ANALYSIS OF CARE/OLSON STUDY, "DEGRADATION EFFECTS
ON MOTOR VEHICLE EXHAUST EMISSIONS," Joe Cutro (December 1975)
53. REGULATORY SUPPORT DOCUMENT SECTION 207 (b) NPRN,
THE EMISSION CONTROL TECHNOLOGY DIVISION MSAPC
9/21/76.
54. THE SHORT CYCLE PROJECT; EFFECTIVENESS OF SHORT EMISSION
INSPECTION TESTS IN REDUCING EMISSIONS THROUGH MAINTENANCE,
VOLUME 2-METHODOLOGY AND RESULTS, FINAL REPORT, EPA
CONTRACT 68-01-0410, OLSON LABORATORIES, INC. 31 JULY 1973.
55. HIGH ALTITUDE VEHICULAR EMISSION CONTROL PROGRAM;
VOL VII EXPERIMENTAL CHARACTERIZATION, D.R. Liljedahl
et al, AUTOMOTIVE TESTING LABS, INTERIM REPORT
JULY 1974, STATE OF COLORADO.
56. CALIFORNIA VEHICLE INSPECTION PROGRAM.,: RIVERSIDE TRIAL
PROGRAM REPORT, OPERATIONS FROM 9/2/75 to 2/13/76, VOLUME 2-
SUMMARY REPORT, CALIFORNIA INSPECTION PROGRAM BRANCH,
BUREAU OF AUTOMOTrVE REPAIR, MAY 1976.
57. IDLE EMISSION TESTING, PART III, J. Panzer, ESSO Research and
Engineering
58. DATA compiled by Joe Cutro, October 1976
59. COST EFFECTIVENESS OF STAGE 1 VAPOR RECOVERY AT SMALL BULK PLANTS,
Robert R; Hunter to James J. Sakolosky, October 19, 1976
PAGENO="0221"
219
RECALL
FIGURE 1
PAGENO="0222"
FIGURE 2
1/14 STUDY PESULT3
* Fleetwide Initial (intrediately follcwing repair) Effectiveness
FTP Evaluations
Short Special Sample Model % Emission Thsduction
Mares of Study Test Conditions Size Years Failure HC(~1) CO(%) NO~ (%)
Olson Short CycleS4* Idle 299 1957-71 31 21.7 16.5 (-)1.4
Loaded 149 1957-71 32 20.3 15.9 0
Loaded w/ inachanic training 150 1957-71 34 33 22 (-) 1.5
56
ATL-'lMW Colorado Idle high altitude 55 1964-73 50 18 12 (-)0.8
40
Olson Degradation Idle 144 1968-74 41 23.1 14.8 (-)2.8
Cl\en-Riversida~ Idle 238 1955-74 35 18.8 15.0 1.4
Loaded 393 1955-74 35 17.3 15.6 (-)1.5
Idle 1672 1975-76 17.5 12 (est.) 22 (est.) 9 (est.)
Short Test Evaluations
Short Special Sample Modal % Emission Deduction
Marie of StixIy Inst Conditions Size Years Failure MC (%) CD (%) NO~ (%)
Exxon57 Idle 396 1959-72 14 22 11 --
Idle 24 23 17
Idle 56 35 31
58
New Jersey Idle 9070 thru 74, 26 26.5 27.3
k ~sfore and after repair comparisons not performed on salle cars. Sanple size is for all vehicles tested.
*re lerences
PAGENO="0223"
FIGURE 3
EMISSIONS DURING CALENDAR YEAR 1975
(1975~ FTP)
CARBON MONOXIDE
AP-42 LATEST ESTIMATE*
9.0 23.7
39.0 43.2
41.0 5O.~O
43.0 56.8
58.5 63.~6
61.0 70.3
71.4 77.1
73.6 83.9
96.0 117.2
221
MODE.L YEAR
1975
1974
1973
1972
1971
1970
1969
1968
PPE- 68
HYDROCARBONS
AP-42 LATEST ESTIMATE*
1.0 1.4
3.5 3.4
3.8 4.1
4.1 4.7
5.1 5.4
6.3 6.0
6.3 6.6
8.0 7.3
9.0 9.4
* ref ltcts latest emission data adjusted to reflect
July 1, 1975 emission levels.
PAGENO="0224"
ut td at at S - N N ~
at
FIGURE 4
222
EMISSIONS DIVIDED DY STANDARDS Vs. CALENDER YEAR
La
Is
N
PAGENO="0225"
:223
EMISSIONS OIVIOEO, BY STANOAROS Vs. CALENOER YEAR
d
N
In
N
n~ ul td
N
HVDFIOCPIaQNS Mon.t:L. vtri~ I
Ill
Si Si
at at 13
PAGENO="0226"
SIGNIFICANCE OF MAINTENANCE
CARBON MONOXIDE
53.5
7.
1973
Standard - - - - -
(39 g/isi) 37.3
1,249 140
__ - fl~)
Proper As Found .~hicles
Maintenance Condition Adjustment* Tested
and Tuned
1973 Model Vehicles Avg. Milesa-.15,000 1975 Model Vehicles Avg. Miles <10,000
*proper adjustment means idle CO levels equal to or less than 0.6% for catalyst cars and equal to or
Loss than 1.0% for non rnthlvef- rare
PAGENO="0227"
Si
FIGURE 14
All
- Selected
f~1
(`4
HYDCR~JN~
In
z
D
In
`Ji
Li
IM
N
~It~
- ~-- -~--
D
z
Control Croup
All: All vehicles èompleting 12 month program
Selected: All vehicles except those showing deterioration in excess of 400%
MDNTH~
PAGENO="0228"
SIGNIFICANCE OF MAINTENANCE
HYDROCARBONS
4.07
:andard - - - - -
3.03
Cars / COre
Proper As Found
Maintenance Condition
and Tuned
1973 Model Vehicles Avg. Miles'a15,000
*proper adjusttBent means idle CO levels
less than 1.0% fop' non catalyst cat-s.
1975
Standard
(1.5 g/ini)
Proper
Adjus tment*
* All venic~
Tested
1975 Model Vehicles Avg. MilesI10,000
equal to or less than 0.6% for catalyst cars and equal to or
PAGENO="0229"
FIGURE 8
E~USSION D~Th F~M fl'i-USE 1975 MT)DEL ~iIFOPN1A CARS
STDS EPA ESTIMATE1! EPA DATA CARD DATA 4/
i~ _J6 FY 74 EFP2!~FY75 EFP3/
Co 9.0 5.4 5.9 5.7 (l8%)~" 10.6 (50%) 9.1
HC 0.9 0.6 . 0.7 0.5 (0%) 0.7 (36%) 0.9
NO~- 2.0-- ~2;0- 2~06 2~3 (35%) ~2.7(-i4%)-- 2.3-------
No. . 4*3 14 43
Miles 8329 19060 "lS,OOO
Failure Rate-Overall 50% 57% 51%
(1) AP-42 (Supp. 5)
(2) Measured during calendar year 1975
(3) Measured during calendar year 1976
(4) Measured during calendar year 1976 by the California Air Resources Board
(5) Numbers in parentheses. refer to failure rates by pollutant
PAGENO="0230"
FIGURE 9
CAN I/N IDENTIFY HIGH POLLUTING VEHICLES?
IDLE TEST IS EASIEST TEST
MEAN FTP RESULT MEAN FTP RESULT
Co RESULTS* 72 - 74 MYk L 75 - 76 MY** //
CARS PASSING IDLE TEST 40.54 (39) 207 13.50 (15) 349
CARS FAILING IDLE TEST 65.39 290 36.73 238
MC RESULTS*
CARS PASSING IDLE TEST 3.26 (3.4) 207 0.97 (1.5) 349
CARS FAILING IDLE TEST 4.92 290 1.83 238
*IDLE TEST POINTS SELECTED FOR 5% ERRORS OF COMMISSION; FTP vs. FTP CAN RESULT IN SAME COMMISSION
ERROR RATE ALTHOUGH LOWER OMISSION ERROR RATE
STANDARDS
Data Source: FY 74 Emission Factor Program
*pass/Fajl cutpoints for ldle tests: 2.71% CO, 261 PPM HC
**Pass/Fail cutpoints for idle test: 1.0%, 168 PPM HC
PAGENO="0231"
FIGUPE 8
E~SSIDN D~T~ FR~M IN-USE 1~75 M~)EL ~ALDOI~IA CM~S
EPA DATA
_Fi~__F~EPV_FY7 5
5.7 (18%)~~' 10.6 (50%)
0%) 0.7(36%)
2.3 (35%) 2.7 (14%)
43 14
STDS EPA ESTIMATE1!
~ ~
CO 9.0 5.4 5.9
MC ------0.9--- --0.6- 0.7~
NOx 2.0 2.0 2.06
No.
CARB DATA
9.1
0.9
-
2.3
43
Miles ~8329 19060 ~`15,000
Fa~i1ure Rate-~Overal1 50% 57% 51%
(1) AP-42 (Supp. 5)
(2) Measured during calendar year 1975
(3) Measured during calendar year 1976
(4) Measured during calendar year 1976 by the Ca1iforni~ Air Resources Board
(5) Numbers in parenthesea. refer to ~ai1ure rates by pollUtant
PAGENO="0232"
SIGNIFICANCE OF MAINTENANCE
HYDRoCARBONS;
3.03
/1,249
Cars
1975
Standard
(1.5 g/mi)
73
indard
.4 g/tni)
4.07
Proper As Found Proper All
Maintenance Condition Adjus tmcnt* Te~tod
and Tuned
1973 Model Vehicles Avg. Mileo.sl5,000 1975 Model Vehicles Avg. Mlles~l0,OO0
~proper adjustment means idle CO levels equal to or less than 0.5% for catalyst cars and equal to or
less than 1.0% for non catalyst cars.
PAGENO="0233"
FIGURE1O
CAN SERVICE INDUSTRY REPAIR CARS?
OREGON RESULTS
TYPES OF REPAIRS NEEDED
CARBURETOR ADJUSTMENT 78%
TUNE UP 14%
ENGINE OVERHAUL 1%
VALVES 1%
OTHER 6%
PAGENO="0234"
232
FIGURE 11
REPAIR COSTS FOR EXISTING
PROGRAMS -
N = 4000 (does not include those
who performed their own repairs)
Avg. Repair Cost 25.42
Median: 50% of repairs cost
less than $15
67% of repairs cost less than
average
New Jersey (flunk rate - 12%)
Oregon (flunk rate = 35%)
less than $10 29.7%
No cost 32%
$10 to $25 26.4%
*
less than $10 40%
$25 to $50 22.l~
$10 to $30 15%
$50 to $100 16.1%
$30 to $50 6%
m~re than $100 5.6%
$50 to $75 3%
$75 to $100 2%
more than $100 2%
N = 16,000
Avg. Repair Cost = $32.97
Median: 50% of repairs cost
less than $21
65% of repairs cost less than
average
N = 6,527 (primarily newer cars)
Avg. Repair Cost = $18.86
Median: 50% of repairs cost
less than $6
79% of repairs cost less than
average
Arizona (flunk rate = 47%)
less than $5 24%
$5 to $10 17%
$10 to $25 25%
$25 to $50 20%
$50 to $100 11%
more than $100 3%
PAGENO="0235"
233
FIGURE 1?
IMPACT OF POST MAINTENANCE DETERIORATION ON JIM
EFFECTIVENESS OVER A SINGLE I/N CYCLE~
HC EMISSIONS
RAPLD
DETER IORAT1ON
->T I ME
_____ EMISSION
______ REDUCTION
OBTAINED
* FOR PURPOSES OF ILLUSTRATIONJ THESE CURVES ASSUME THAT
THE I/M FLEET DETERIORATES BACK TO ITS PRE-I/M EMISSION
LEVEL OVER ONE CYCLE AND THAT *THE NON-I/M FLEET DOES
NOT DETERIORATE OVER THIS TIME PERIOD
21-335 0 - 78 - 16
LINEAR SLOW
DETERIORATION DETERIORATION
PAGENO="0236"
T
I .
Ui
Iul~l
In
Ui Control c
S0100 ted
- -
I/H Group ~
2:
/ COffipleting 12 month
/ Selected; All Vehicles °~cept tho~ showing deterjoratjo. ifl Ozc~55 of 4Oo~
FICUnE 13
PAGENO="0237"
H~F~DCF1F~6DNE~
All.
I1Crp_--~~ ~Selected
All; All vehicles completing 12 month program
Selected;All vehicles except those showing deterioration in excess of 400%
1-
MDNTH~
r~i
P4 tO
FIGURE 14
PAGENO="0238"
Lrl:
z
LII
L[L
L[T
>1
236
Impact of I/N Fleet Deceriorazion Rates On
Lifetime Emission Levels
I/N
tYITH I/N
12L
EMISSIONS
ELIMINATED BY I/N
iiI~iIffl
H.
WITHOUT I/N
1~Li
WITH I/N
I. 2.
VEHICLE HEE
PAGENO="0239"
237
- hi hi hi U
~ & b
23.3
E32
n
Li
2
p
N
2
El
133.21 P1
Fl
S
21
ill
a
S
`I
I
n
-1
a
I
111.
PAGENO="0240"
238
in
Q
I-
V
L
z
Q
in
in
z
[Li
Li øøøi
in
[Li
I
a.
V
* SL~A~1 UOISSLW3 L~~p~I `~8 P~PY4U ~:~OLSStUp
3H - ~NG!EE;k43 Zfl~4~ciN
"1- ~ Li Li
m ci ccc
PAGENO="0241"
212L
FIGURE 18
CO GM/MI
EZL2I.
DETERIORATION OF CO EMIssIoN Vs MILEAGE
1975 IN-UsE VEHICLES
GL21.
- n I L~ .tfl N m m
PAGENO="0242"
FIGURE 19
C
Cl
DC GM/MI
DETERIORATION OF DC EMISSION Vs MILEAGE
1975 IN-UsE VEHICLES
3.
:2.
:000)
rsi S S S
- P4 P1 r La W N LU Ut
PAGENO="0243"
241
FIGURE 20
Average Idle Test Emission Levels In New Jersey
1972 1976
uEN JENSEY DATA
July 1972 to SeDlenber 1976
pre 1968 e.odel year
1976
S?~NPLE YEAR
NEW JERSEY DATA
July 1972 to Septerebur 1976
~~prel96~nodelyear
z
19i4 197~ __.---~
1976
SN1PLR YEAR
PAGENO="0244"
242
FIGURE 21
Failure Rates at
New Jersey
Calendar Year
Model Year 1972 1973 1974 1975 1976
1976
-
-
-
-
1975
16.7
1974
7.4
14.5
13.8
1973
8.7
15.4
16.3
17.1
1972
10.8
14.4
18.8
19.7
21.7
1971
23.6
21.1
27.8
26.4
25.9
1970
30.8
28.7
30.8
29.6
32.4
1969
18.0
15.5
20.3
21.4
22.4
1968
26.7
19.8
23.9
24.6
27.1
1967
& Older
24.1
19.1
21.5
19.2
18.4
* ~ssumes phase I standards constant througho~it this period
PAGENO="0245"
H.~
3.7 %
3.3 %
3.0 %
0
~-
LU
.~ -
.~
N.LJ. `N.Y. FFL
IDLE TEST EMISSION RESULTS ON IN-USE VEHICLESDURING CALENDER YEAR 1975
(Based on Nationwide Age Distribution for each Site~
FIGURE 22
PAGENO="0246"
0,
0~
L)
I
U
-J
franz,
rzjz
N.Li N.Y. FF1.
Idle Test Emission `Yesults on In-T.ise Vehicles During Calender Year 1975
(Based on Nationwide Aqe Distribution for Each Site)
riGunE 23
PAGENO="0247"
245
EMI:IoN REDUCTIONS FROM T/M PRoc~RAM AT sTNE~
~~~dLEGID
1. Latest Estimate-No I/H
rn 2. I/M with Mechanic
Training
3. I/M without Mechan
ic Training
~7 *7~* 77 .7~ 7~
1~7~ MDD~ ~`EFI}R
~
(HLEN~RR. YERR
-. FIGURE. 24
PAGENO="0248"
LIP
-~
u1~
UI
z~
246
EMISSIONS REDUCTIONS FROM I/N PROGRAM AT 30% STRINGENCY
9 7 L~l Ni ~ £3' ~ I_ "i" ~
LEGEND
1. Latest Estimate
2. I/N with Mechanic
Training
3. I/M without Mechanic
Training
9 ~7 ~ Ni ~ "r~ ~
(HLEN~H~ YEH~
FIGURE 25
PAGENO="0249"
247
FIGURE 26
LATEST ESTIMATES OF EMISSIONS REDUCTIONS
WITH A GOOD I/H PROGRAM-PERCENT
CO HC
PRE-CATALYST CATALYST PRE-CATALYST
3 (6) :8 (11) 1 (4)
8 (12) *20 (24) 5 (9)
13 (18) 28 (33) 7 (12)
19 (25) 33 (39) 10 (16)
22 (29) 37 (44) 11 (18)
21 (31) 26 (33) 26 (36)
26 (37) 38 (46) 30 (41)
31 (43) 46 (55) 32 (44)
37 (50) 51 (61) 35 (48)
40 (54) 55 (66) 36 (50)
OVER VEHICLE LIFETIME
10 (16) :15 (19) 11 (17)
15 (22) :27 (32) 15 (22)
20 (28) ~35 (41) 17 (25)
26 (35) 40 (47) 20 (29)
29 (39) 44 (52) 21 (31)
with mechanic training
STRINGENCY
FACTOR
A-FIRST YEAR
.10
.20
.30
.40
* 50
B-EIGHTH :YEAR
* 10
.20
.30
.40
.50
C-AVERAGE
.10
.20
.30
.40
.50
( )
CATALYST
1 (4)
3 (7)
9 (14)
16 (22)
24 (31)
26 (33)
28 (36)
34 (43)
41 (51)
* 49 (60)
11 (15)
13 (18)
19 (25)
26 (33)
34 (42)
PAGENO="0250"
248
PERCENT REDUCTION IN CARBON MONOXIDE EMISSIONS
(1970 TO 1980)
~xj
CD
~! W I ~ 4 ~ -~
S S S
$ $ $ . S
I-
-<~
fl
~
~
~J
-H
I
~
~
.
:
~
~
z
.~
LCD:
~
~
~H
~
~
~
Cfl~Jr~
H~
~
~
fl
FORMER ESTIMATE
.
LATEST~~
FORMER
LATEST
FORMER
r~
-----~-- -~-------~--~--~
-H
2J
~
~
.
C.')
ill
IIA~~T~i
PAGENO="0251"
Figure 28
I/M Assucptions
(7) 30% Stringency
2~ -~ Program Starts in 1977
FM V
I/N WITH MECH TRAINING
cnoo
~ _
c ~
2~C)
F~ I
TYPICAL BOSTON SEATTLE PHOENIX
CITY
PAGENO="0252"
250
FIGURE 29
COSTS OF JIM
CARB*
Maintenance 15.41
Fuel Savings -15.83
Inspection -
Total
*Reference 40
**Reference 49,50
***Referencc~ 42
OTLUP* ~
9.60
-9.60
1.76-1.92
BEST ESTIMATE
9.60
-9.60
5.00
5.00
NEW APPENDIX N WITH
MECHANIC TPAINING 338.28
REDUCING LDV EMISSION
STANDARDS FROM INTERIM
TO STATUTORY 437
OPE'*** -
2.80-10.56
2.21-5.87
FIGURE ~
* I/M COST EFFECTIVENESS ($/TON)
HC CO
12.42
41
STAGE I VAPOR RECOVERY
446 - 1448
PAGENO="0253"
.~ 0
O tP
H 0
.50 C)
H H ~
HH 0
OH
H
90
~i
H ~4 ~`
0
o o.o
4~)4)
4) ~.49
900
H I
9.1
0!
H
4-,
0
9
0
0
C)
9
H
H
0
CCI
0
0
251
Fig~re 31
CARBON MONOXIDE AIR POLLUTION
AND
GASOLINE CONSUNPTION
1972
1973
Years~ I
*Monthly moving avera~eS
for 18 monitoring sites
PAGENO="0254"
Figure 32
~44,
0-.
03 ~
4-4 0~~
0-
5'O
00
DC
H ~O
43 r
0 0
~ 43
i-i e
43, `(~
dx
no
LI'
o
0
CO
.q o
1-4 1
r. U
Contravontions of the Carbon- Monoxide
Ambient Air Quality Standard at
Eighteen New Jersey Air Monitoring Sites*
0'
Yoars
* Does not include Elizabeth Trailer, Atlantic City, Morristown, and Trenton
** National Ambient Air Quality Standard tor 8-Hour carbon monoxide dose - 9 ppm.
PAGENO="0255"
Figure 33
RECENT DATA FROM AT&T ON
CINCINNATI BELL FLEET
RUNNING EXPENSE LESS GASOLINE
~PER1OJOOOM - PER VEHICLE
1972 $6~O
1.973 708 693
197q 803 78~
1975* 753 .715
~ TUNE UP WITHOUT EXHAUST ANALYSIS
PAGENO="0256"
254
FIGURE 34~
CINCINNATI BELL
YEAR GALLONS OF GAS MILES TRAVELED MPG
1971 1003178 10,910,275 10.9
1972 1044174 11,095,716 10.6
1973 1087209 11,508,209 1O.~
(1) 1974 1077324 11,792,715 10.9
(2) 1975 1059583 11,661,291 11.0
(1) Started to check vehicles with infra red analyzer
(2) No tune up without analyzer check
Mr. ECKHARDT. You mention in your testimony some 25 urbnan
areas in 18 States and the District of Columbia have emissions
inspections and maintenance provisions in their implementation
plans under the Clean Air Act. You further note there are four
mandatory and five demonstration plans in operation. Are any of
the demonstration projects you mention the same as those?
Dr. SHUTLER. No, sir, they are not.
Mr. ECKHARDT. So that is in addition?
Dr. SHUTLER. Yes, sir.
Mr. ECKHARDT. You mention consumer and state resistance to the
emission inspection and maintenance program. In the Alabama
project, of course, the initial inspection was by government grants,
so it was free, but for complete examination of the emissions
characteristics of the automobile in order to to give full diagnostic
testing, the Alabama project offered to the consumer at a $5 cost an
opportunity to use this.
We understand that this was very well received. Apparently a
good number of the persons availed themselves of that program.
Do you believe the resistance you have talked about will be
reduced if diagnostic inspection for emission were required buy
banned other diagnostic services were offered to consumers on a
voluntary basis?
I do not know precisely how you would do it, whether you would
offer it in a single package of mandated inspection or you would, as
PAGENO="0257"
255
in the case of Alabama, offer it as an extra service if it were desired
to be paid for.
Do you think there could be some reduction of that resistance to
mandatory inspection by such a process?
Dr. SHUTLER. I think, yes, that directionally it has to reduce the
resistance. Whether it would be significant I am not really sure.
The people who availed themselves of additional service at extra
cost I presume were volunteers in the first place when they came
in.
Mr. ECKHARDT. They were likely to be more thoughtful drivers, I
suppose, and then, of course, also the original service was free, so
the additional amount was only $5 for a pretty complete inspection.
That might not be available at such a price under a mandatory
program, but at least it indicated that this group of people found
the opportunity of a neutral inspection an inviting prospect which
they were willing to accept.
Dr. SHUTLER. It is, sir, and I think it is one of the big selling
points we have. Again, whether or not it is going to appeal to a
significant percentage of the people or merely to those who are
naturally more conscientious and concerned about their cars is
difficult to say.
There is a program in Chicago at which inspection is supposedly
mandatory and only about 15 percent of the people go through the
lines, although everyone has already paid for the service in the
registration fee of the automobile. So our impressions of success
with purely voluntary programs are not good.
Mr. ECKHARDT. I suppose one thing that makes a program accept-
able is the convenience by which these services are rendered and
whether or not one must wait in a long line and spend the better
part of a day in order to get it done.
Dr. SHUTLER. There is no doubt one of the most troublesome of
getting the program adopted is the public convenience, and there is
nothing more inconvenient than this waiting in line. Every program
that is currently ongoing I believe without exception has experienced that
problem. However, there are all sorts of ways that programs can work to
reduce those problems.
In the State of Arizona there is a working arrangement with
radio stations who broadcast the availability of an inspection at a
given location. They give a running commentary where you can go
to get through the fastest. There are lots of things that can be done.
There does seem to be a tendency of people to wait until the last
moment to get a required inspection, and so to some extent there
will be lines that are probably irreducible.
Mr. ECKHARDT. I have seen a program governmentally operated
in England respecting trucks. It seemed to me to be very efficient to
handle with trucks running through within a short period of time.
This was one of the larger inspection locations. Of course, trucks
would be somewhat more limited in number than automobiles.
Apparently this does afford at least something within manageable
limits.
Dr. SHUTLER. In a given situation a facility can handle a large
number of cars. In Arizona some of the stations are only open three
days a week because there is inadequate demand. The test takes
PAGENO="0258"
256
only a minute or two or three if the consumer is given a fairly
diagnostic report. It is just a matter of how many arrive in a period
of time to be serviced.
Mr. ECKHARDT. I have seen a program that seemed initially
operated not under direct governmental auspices but private aus-
pices, for automobiles in Belgium that seemed to work very well.
But they had a number of stations conveniently located to everyone.
No one had to go far to one of these stations.
Dr. SHUTLER. That is clearly a key. One thing a State can do in
addition to having fixed inspection stations is to have mobile
stations that can be located in different positions through the
community to increase their geographical coverage.
Mr. ECKHARDT. Suppose we could solve these questions of con-
sumer convenience and suppose we were able to invite consumers
successfully to have their automobiles inspected with respect to
emissions and safety, and, in addition to that, other diagnostic
inspection capabilities combined in the same inspection facility. Do
you think consumers would realize significant cost savings?
Dr. SHUTLER. I think it is highly likely in the emissions area,
which is the only area with which I am familiar. By the time you
add the cost of maintenance and inspection and subtract out the
fuel economy benefit, the consumer is facing something like an
additional $5 a year over what he might spend otherwise. Our
analyses indicate the cost of the maintenance and the fuel economy
benefits pretty well wash each other out and the consumer ends up
paying a net $5 for the inspection more.
In the other areas whether he could end up actually making
money, I am not sure.
Mr. ECKHARDT. It is somewhat more difficult to determine the
intangible advantages of saving the consumer from an accident
because of faulty brakes.
Dr. SHUTLER. Certainly from the safety side that is an advantage
and from the emission side protection of the public health is a very
real benefit.
Mr. ECKHARDT. Thank you very much for your excellent
testimony.
Mr. Richard C. Foster, Assistant Director for Marketing Prac-
tices, Bureau of Consumer Protection.
Proceed.
STATEMENT OF RICHARD C. FOSTER, ASSISTANT DIRECTOR FOR
MARKETING PRACTICES, BUREAU OF CONSUMER PROTECTION,
FEDERAL TRADE COMMISSION
Mr. FOSTER. My name is Richard C. Foster, Assistant Director for
Marketing Practices, Bureau of Consumer Protection of the Federal
Trade Commission. I am here as a staff member and my views do
not necessarily represent the views of the Commission or any
commissioner.
I have been asked to comment specifically on the Commission's
investigation of crash parts.
The Bureau of Competition began its investigation of the crash
parts industry out of a concern over possible monopolization of
PAGENO="0259"
257
crash parts by the major automobile manufacturers and their
refusal to sell such parts to companies other than their dealers. On
March 22, 1976, the Commission issued a complaint against General
Motors alleging monopolization of crash parts and the refusal of
General Motors to sell them to companies other than its dealers.
The trial date has been set for February 8, 1978.
Because this investigation is in litigation I cannot comment
further.
The principal reason I am here today is to testify about the
Bureau of Consumer Protection's investigation of the auto repair
industry and our consultations with the National Highway and
Traffic Safety Administration about processing already-collected
information that would help us in that investigation.
More than any other country, the United States is dependent
upon the automobile. Over 100 million cars are 90 percent of all
miles traveled by Americans ~re by car and 8 out of 10 workers use
automobiles to get to work.
Inevitably cars break down and need repair. But consumers'
experience with auto repairs is often unsatisfactory. Consumers
complain about auto repair more than about any other marketplace
transaction.
The staff of the FTC is trying to determine what, if anything, the
Commission, Congress or the States can do about this problem.
From our preliminary research we know that: 80 to 90 percent of
all car owners need to get their cars repaired at least once a year;
they spend annually over $40 billion doing it; judging by the level of
consumer complaints, owners feel that much of the $40 billion is
wasted. They may be right. According to preliminary estimates
based on data collected by the commission staff, almost one-third of
all money spent on auto repair-$12 billion-may be wasted each
year on unnecessary repairs.
As high as this estimate is, it does not include either the loss from
repairs that are not properly made or for work paid for which was
not done.
I do not want to belabor the issue. The problems consumers have
getting a car repaired are well known.
As I mentioned before, the commission staff has begun an investi-
gation of these problems. My staff and I believe that before a
solution can be devised-whether by the FTC or by Congress or the
States-we need to know more about the problem. Specifically, we
need to know the actual repair experience of large numbers of
vehicles involving a variety of mechanical problems and a wide
cross section of different facilities. This data would enable us to
determine with some precision where consumer economic loss oc-
curs. Armed with this information and analysis, we could begin to
determine the causes of these losses, and whether they can be
reduced through government action and, if so what actions should
be taken.
DOT has already collected the needed information actual repair
experiences. Public Law 92-513 established vehicle diagnostic in-
spection projects in Arizona, Puerto Rico, Tennessee, Washington,
D.C., and Alabama. These centers have inspected over 66,000 cars.
Approximately 31,000 of these cars were inspected by diagnostic
centers both before and after being repaired.
PAGENO="0260"
258
Specifically, each of these cars was inspected by a diagnostic
center, and the owner told what parts or systems failed the inspec-
tion. The cars were then taken to service facilities of their owner's
choice. After repairs were completed, the cars were returned to the
diagnostic center for reinspection. The receipts detailing the repairs
performed were also turned over to the diagnostic centers.
Data concerning these 31,000 cars, if analyzed, would be invalu-
able. It constitutes the only potential source of detailed information
about the nature of auto repair problems including the incidence of
unnecessary and unsatisfactory work and the resulting economic
loss to consumers for each type of repair, in each type of shop, and
whether most problems occur in a few bad shops or whether
problems are industrywide.
We think the analysis we are urging DOT to perform can be
performed at a moderate cost. The analysis involves three steps:
(1) coding information from the diagnostic reports and repair
receipts and determining from these records whether repairs paid
for were necessary;
(2) putting this information into a computer; and
(3) programing the computer to produce the desired tabulations.
As part of the DOT program, a University of Alabama team
under DOT direction has applied most of this analysis to the data
collected by the Alabama demonstration project at a cost of $88,000.
A substantial portion of this cost consisted of the fixed cost of
setting up the procedures and devising the computer programs. Now
that this has been done, the additional cost of processing the data
would be approximately $8,000 per 1,000 repair transactions or
about $208,000 for the remaining vehicles.
I might emphasize that this analysis requires only processing of
raw data presently in DOT's files. It does not require collection of
any additional information.
Because of the basic importance of this information to our investi-
gation, our former chairman wrote a letter to Secretary of Trans-
portation Brock Adams requesting that his Department analyze the
data obtained by the diagnostic centers. Secretary Adams replied
that since all funds for the proposed projects had been spent and
staff reassigned, he could only make the raw data available for our
analysis. Unfortunately, the commission does not have money in its
budget to process this raw data.
The DOT data was collected at a cost of approximately $17
million. It is a unique and invaluable data base on auto repair
problems. We urge that it be analyzed now to provide basic informa-
tion essential to the solution of the auto repair problems.
If you have any questions, I would be glad to field them. [The
letter and reply referred to follow:]
PAGENO="0261"
259
FEDERAL TRADE COMMISSION
WASHINGTON. D. C. 20580
TheThöñ~órable Brock Adams, :.~.
Secretary of Transportation
Room .10200
400 7th Street, S.W.
Washington, D.C. 20590
Dear Mr. Secretary:
As you know auto repair is felt by many to be a major
consumer problem area. The Commission is undertaking a
general investigation of consumer problems in this area.
The purpose of this letter is to request cooperation from
the Department of Transportation in analyzing data collected
as part of the diagnostic inspection demonstration pro-
jects established by the Department under P.L. 92-513.
The Commission staff ~recently brought to our attention
preliminary data obtained from the diagnostic demonstration
project in Huntsville, Alabama showing the extent of
consumer loss from unnecessary repairs in the Huntsville,
Alabama area. This data and similar data obtainable from
the Huntsville Center and the four other demonstration
projects is of considerable interest to the Commission
and its staff.
The diagnostic records of vehicles diagnosed before
and after being repaired, and the corresponding repair
receipts comprise an invaluable data base with which to
analyze the nature and quality of industry performance.
Analysis of this data and further collection of data
could reveal, for example, the extent. of consumer cconoii~ic
loss resulting from unnecessary repairs of particular
components at different types of repair outlets; the
extent to which the performance of unnecessary repairs
varies from shop to shop; whether the incidence of unnec-
essary repair and the quality and cost of repair differ
significantly between shops that employ mechanics certi-
fied by voluntary certification programs and those that
do not; the effoct of flat rate and othor mechanic corn-
ponsation systems on th~ quality áf repair work and the
incidence of unnecessary repairs; and whether and the
cxtent to which the incidence of unnecessary repairs
may be reduced when consumers have access to diagnostic
centers which specify in detail what repair work needs
to be done.
PAGENO="0262"
260
Secretary J~c1ams -2--
In this regard my staff informs me that comparable
data is not readily available from other sources. In
addition to being of significant help to the Commission
and its staff, I believe such information would also be
helpful to Congress and state legislatures in their
respective attempts to find solutions to auto repair
problems, and would be of considerable interest to
consumers as well.
Accordingly, I believe the public interest would be
well served if your department were to undertake further
analysis of the data which your demonstration diagnostic
centers have collected. In the interest of making this
data most useful to our respective agencies, Congress,
and the public, I suggest we direct our staffs to work
together to develop possible ways in which this data can
be analyzed, and make the results of their efforts known
to us at the earliest possible time.
I very much appreciate your cooperation and interest.
Calvn 3. Collier
Chairman
PAGENO="0263"
~61
THE SECRETARY OF TRANSPORTATION
WASHINGTON, DC. 20590
APRI 3(~T7APR 181977 )
Honorable Calvin J. Collier
Chairman, Federal Thade O~nrnission
Washington, D.C. 20580
Dear Mr. Chairman:
With regard to your letter of February 23, I am in
agre~ennt that autonntive repair is of major consurer
concern. The Deparbrent is pleased that you are interested
in the diagnostic inspection denonstration projects authorized
under Title III of the Motor Vehicle Information and Cost Savings
Act and will certainly cooperate to the extent practicable in
providing the information you seek.
A final report is being prepared at this tine and will be
available in June. While this report will contain mach of
the information you requested, I must point out that it will
not meet all your needs. The projects were designed to gather
specific information stated in the enabling legislation and,
ti~refore, do not include certain areas of your interest.
These projects cospleted their first phase of operation of
June 30, 1976. Three of thea have been extended until Septenber 30,
1977; I~iever, no additional analysis is planned by the Department.
The staff has been reassigned to other projects and all program funds
have been expended. Lacking any additional analysis capability, we
will, however, make the pertinent raw data available to you should
you wish to analyze it yourself.
The Department will be willing to cooperate in every way
practicable and will forward a report to you as soon as
it becxzres available.
Sincerely,
PAGENO="0264"
262
Mr. ECKHARDT. What kind of information do you ultimately
expect to get? I read from your testimony on pages 3 and 4 that you
want information about the nature of the auto repair problems
including the incidence of unnecessary and unsatisfactory work and
resulting economic loss to consumers for each type of repair in each
type of shop and whether or not most problems occur in a few shops
or are industry-wide. As I read that, you want generic informa-
tion. You are not trying to go out after individual repair shops?
Mr. FOSTER. That is correct. Essentially what-we are looking for,
there are a lot of consumer complaints; we are trying to get
information sufficient to give us leads as to the further staff efforts
that we should undertake to lead to potential solutions of some
problem areas.
For example, we suspect that some problems may arise because
some parts are replaced more frequently than many other parts. If
so, we want to look at the lifetimes of parts, whether we should
have more information in the marketplace by some fashion, so
consumers can compare information about a particular part. Also
there are differing compensation schemes. This is information we
could get ourselves; it also may have an impact on the level of
unnecessary repair that occurs.
Mr. ECKHARDT. I do not mean to say this assumption that I am
about to state is necessarily true, but the kind of information you
get might test it. I have always felt that whenever I stuck with a
dealer indefinitely with respect to a car, there was to a certain
extent conflict of interest. If the car cost me enough to repair, I
might have to buy another one. It is at least conceivable the dealer
was used to lavishly repairing the car first under a warranty
contract and then following that, continuing the habit to the point
where it became noneconomic for me to maintain the car. Whereas
if I broke loose from the dealer as soon as the warranty was over
and found an individual mechanic, I might get better service.
It might be argued I might not get as good a standard of service
because the individual mechanic might not know as much about
that make.
After all, I have to rely on my own personal experience. If you
had this information you would throw some light on that situation,
would you not?
Mr. FOSTER. That is true. We are trying essentially to get some
kind of feeling. The Alabama data that shows a considerable vari-
ability among parts, et cetera. We are trying to get a complete
picture across the country to get a feeling where potential trouble
spots may lay.
Mr. ECKHARDT. There may be the question of whether or not a
repair shop that ordinarily repairs cars for insurance companies
might develop a pattern of higher costs because the costs are totally
paid by insurance, whereas charging an individual at such a rate
might lose his customers. We might get some light thrown on that
question, might we not?
Mr. FOSTER. Of course, I don't think out of this particular data
you would get that, because the type of repair by insurance is for
crash parts, and so forth, and the repairs represented in here are
really not crash related but are maintenance kinds of items-how
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well the engine is operating and things of this sort. This is not
complete. It is the best that we, know of that exists right now.
Mr. ECKHARDT. I suppose you would also get some information
with respect to whence come the parts and to what extent are the
prices of those parts controlled by the manufacturer of the particu-
lar make of automobile?
Mr. FOSTER. I am not sure. I would suppose if they would actually
retain receipts at diagnostic centers you could develop that informa-
tion, but as far as I know, no one has put that into the computer.
Mr. ECKHARDT. I suppose you would be able to determine, or
would you be, the extent to which an entire system or entire
combination of parts would be purchased and replaced rather than
the actual part that was giving you trouble?
Mr. FOSTER. That would certainly be part of this particular study.
It seems to me in connection with the parts that were examined you
could determine that. As a matter of fact, some of the information
would lead you to believe, at least that I have seen in the Alabama
study, that when the consumer receives more precise information
on what it is that is wrong and communicates that to the repair
dealer, the repair dealer knows he has the specific information and,
that is, what is repaired. This ~`ould bear on that.
Mr. ECKHARDT. It would seem to me this data would also give you
some indication of what the life of the given part actually was as
compared to that which has been assumed to be the life of the part,
like spark plugs, for instance.
Mr. FOSTER. I am not entirely certain in my own mind whether
that is so or not. Maybe someone knows the data better than I do. I
am operating through about four or five different levels of hearsay,
so it is very difficult for me to respond.
Mr. ECKHARDT. I think to a certain extent the `Alabama project
went into those questions or at least that last question.
I note in a quick calculation here your estimate of $208,000 for
examining the results of the $17 million grant program would
constitute only 1.2 percent of that program. It would seem to me
that would be money well spent rather than letting the data go
unanalyzed.
Mr. FOSTER. That is why we sent the letter initially and that is
why I am here today, Mr. Chairman.
Mr. ECKHARDT. I feel that we should look into this matter care-
fully because it is my own feeling that the act which I had some
part in drafting was intended to obtain just the type of information
under title III that you are now seeking.
I also have no doubt in my mind that the purpose of the act was
not merely to assemble the information but also to put it to some
reasonable purpose, which would seem to me to be an analysis. It
reminds me of a Federal district judge saying one time that he was
sure that the petition was nOt filed with him to throw in the
commode but to file with the clerk. It does seem to me quite obvious
that the language of the act intended something more than the
mere stacking of bricks.
I thank you very much for your testimony.
Mr. FOSTER. Thank you, Mr. Chairman.
Mr. ECKHARDT. This concludes the entire oversight hearing on the
Automobile Information and Cost Savings Act.
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The subcommittee is adjourned at this time until future call of
the Chair.
[Whereupon, at 5:10 p.m., the subcommittee adjourned.]
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