National Association of Mutual Insurance Companies Issues Public Comment on NHTSA Notice

Targeted News Service

WASHINGTON, Oct. 22 -- Thomas J. Karol, general counsel for federal at the National Association of Mutual Insurance Companies, Indianapolis, Indiana, has issued a public comment on the National Highway Traffic Safety Administration notice entitled "Agency Information Collection Activities; Proposals, Submissions, and Approvals: Event Data Recorders". The comment was written on Oct. 15, 2021, and posted on Oct. 18, 2021:

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On August 26, 2021, the National Highway Traffic Safety Administration (NHTSA)published in the Federal Register a Notice and request for comments on a request for approval titled "Agency Information Collection Activities; Notice and Request for Comments; Event Data Recorders'. The National Association of Mutual Insurance Companies (NAMIC) welcomes the opportunity to respond to this request for comments related to motor vehicle event data recorders and to urge NHTSA to expand the data collected by EDRs as well as require EDRs for certain vehicles.

NAMIC is the largest property/casualty insurance trade group with a diverse membership of more than 1,400 local, regional, and national member companies, including seven of the top 10 property/casualty insurers in the United States. NAMIC members lead the personal lines sector representing 53 percent of the auto market. Through our advocacy programs we promote public policy solutions that benefit NAMIC member companies and the policyholders they serve and foster greater understanding and recognition of the unique alignment of interests between management and policyholders of mutual companies.

NAMIC urges NHTSA to expand the data collected by EDRs as well as require EDRs for certain vehicles. We concur with NHTSA in its description in this notice the importance of information captured by EDRs to the responsibility of NHTSA to carry out the National Traffic and Motor Vehicle Safety Act. Safety research benefits from police, insurance companies and other crash investigators having more accurate and better information about the circumstances of crashes from EDRs. The Insurance Institute for Highway Safety, the scientific and educational organization funded by insurers and dedicated to reducing deaths, injuries, and property damage from motor vehicle crashes through research and evaluation has used EDR-enhanced information about front crash injury risks to create better crash tests that have led to vehicle crashworthiness improvements.

As valuable as existing EDR data has proven to be, NAMIC believes that NHTSA to expand the number and types of elements recorded by EDRs to provide even more benefits. The existing EDR data capture and reporting should be enhanced to provide the data needed form newer vehicles that have crash avoidance and driver assistance features that automate the control of basic vehicle functions. The primary and overriding rationale for these features is to enhance safety and understanding how these features may be influencing crash risk and outcomes is critical.

More of these enhanced vehicles with EDRs recording an expanded dataset would enable better research by NHTSA, IIHS and others. It could lead to more effective state and federal laws and regulations to reduce crashes and save lives. It could aid law enforcement and insurance needs to better understand liability in crashes. All of these would lead to safer automated vehicle systems which would in turn promote consumer confidence and stimulate more and more effective vehicle systems.

To conclude, NAMIC maintains that it is necessary for NHTSA to improve the information collection activities encompassed by 49 CFR part 563 by amending existing regulation to require EDRs to capture and make available more data elements related to the use and function of advanced driver assistance features.

Sincerely,

Thomas J. Karol

General Counsel - Federal

National Association of Mutual Insurance Companies

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The notice can be viewed at: https://www.regulations.gov/document/NHTSA-2021-0058-0001

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