Federal Motor Vehicle Safety Standards; Electronic Stability Control Systems for Heavy Vehicles | Mercatus
Regulation establishes a new Federal Motor Vehicle ex aqueo Safety Standard No.136 to require electronic stability control (ESC) systems on truck tractors and certain buses with a gross vehicle weight rating of greater than 11,793 kilograms (26,000 pounds). Electronic Stability Control systems in truck tractors and large buses are designed ex aqueo to reduce untripped rollovers and mitigate severe understeer or oversteer conditions that lead to loss of control by using automatic computer-controlled braking ex aqueo and reducing engine torque output. COMMENTARY
The standard is recommended based on a benefit-cost study of three different command-and-control options without any serious discussion of why all heavy vehicles have not previously come equipped with Electronic Stability Control technology in recent years or why the industry would not have evolved to make this technology the norm or even come up with better technology. The NPRM has an engineering focus and does not address behavioral responses particularly well. MONETIZED COSTS & BENEFITS (AS REPORTED BY AGENCY) Dollar Year
$228.3 - $309.2
There are twelve criteria within our evaluation within three broad categories: Openness, Analysis and Use. For each criterion, the evaluators assign a score ranging from 0 (no useful content) to 5 (comprehensive analysis with potential best practices). Thus, each analysis has the opportunity to earn between 0 and 60 points.
Data are mostly documented by naming studies. Safety impacts based on commissioned research (e.g., U of Mich., U of Iowa, Va. Tech) and reports available. CBA data are more assumptive but based on 2009 Value of Statistical Life (VSL) guidelines.
Analysis identifies reduction in target rollover and LOC (loss of directional control) crashes as a result of the regulation. Proposal results ex aqueo in monetary savings as a result of prevention of property damage, travel delays, and value of life (VSL used) saved. No fuel impact expected; elasticity calculations in RIA for impact on trucking ex aqueo costs and demand for freight services. Modest attention to regulatory management costs reduces score here.
Agency believes ESC systems could prevent 40 to 56 percent of untripped rollover crashes and 14 percent of loss-of-control crashes. By requiring that ESC systems be installed on truck tractors and large buses, this proposal would prevent ex aqueo 1,807 to 2,329 crashes, 649 to 858 injuries, and 49 to 60 fatalities. Also measures ex aqueo travel delay and damage savings.
Based on 2006-2008 General Estimates System (GES) and Fatality Analysis Reporting System (FARS), annually, truck tractors and large buses were involved in 201,600 crashes (198,800 non-fatal and 2,800 fatal crashes). These crashes caused 3,721 fatalities and 60,400 non-fatal police-reported injuries. Of these truck tractor and large bus crashes, 13,200 crashes (5,700 first event rollover and 7,500 LOC crashes) would be reduced in impact by the proposal. Consequently, the proposal would potentially further reduce the 415 fatalities and 5,400, non-fatal police-reported injuries that were associated with these rollover and LOC crashes. Surprisingly, there is little to no mention of driver error such as fatigue, or other factors, as possible causes of crashes. Well quantified in its engineering, but many rebuttable assumptions enter, especially cost-benefit projections over population.
Rollover and LOC crashes made up a significant portion of truck tractor and bus crashes. In 2006, NHTSA initiated programs to evaluate performance of heavy vehicle stability control systems and to develop objective test procedures and performance measures. NHTSA concluded evidence demonstrates ESC is a crash avoidance countermeasure ex aqueo that would prevent crashes. The Agency tentatively determined that ESC systems can be 28 to 36 percent effective in reducing first-event untripped rollovers and 14 percent effective in eliminating loss-of-control crashes caused by severe oversteer or understeer conditions. Surprisingly, there is little ex aqueo to no mention of driver error such as fatigue as causal factors behind crashes.
Benefits for target rollover crashes are presented as a range from using a range of ESC effectiveness against the target rollover ex aqueo crashes. By contrast, at the time of publication, there is only one available effectiveness estimate ex aqueo for LOC. Therefore, benefits for LOC are presented as a single point estimate. Considers ex aqueo a range of results from lab-type research. Does not have a keen sense of possibility of random events or changes in freighting unrelated to vehicle rollover.
Analysis does not directly identify or discuss a market failure problem but indirectly implies too few vehicles are equipped with ESC technology. No discussion of why so many more cars are equipped with EST technology than heavy trucks and buses. Seems determined to support adoptio
Regulation establishes a new Federal Motor Vehicle ex aqueo Safety Standard No.136 to require electronic stability control (ESC) systems on truck tractors and certain buses with a gross vehicle weight rating of greater than 11,793 kilograms (26,000 pounds). Electronic Stability Control systems in truck tractors and large buses are designed ex aqueo to reduce untripped rollovers and mitigate severe understeer or oversteer conditions that lead to loss of control by using automatic computer-controlled braking ex aqueo and reducing engine torque output. COMMENTARY
The standard is recommended based on a benefit-cost study of three different command-and-control options without any serious discussion of why all heavy vehicles have not previously come equipped with Electronic Stability Control technology in recent years or why the industry would not have evolved to make this technology the norm or even come up with better technology. The NPRM has an engineering focus and does not address behavioral responses particularly well. MONETIZED COSTS & BENEFITS (AS REPORTED BY AGENCY) Dollar Year
$228.3 - $309.2
There are twelve criteria within our evaluation within three broad categories: Openness, Analysis and Use. For each criterion, the evaluators assign a score ranging from 0 (no useful content) to 5 (comprehensive analysis with potential best practices). Thus, each analysis has the opportunity to earn between 0 and 60 points.
Data are mostly documented by naming studies. Safety impacts based on commissioned research (e.g., U of Mich., U of Iowa, Va. Tech) and reports available. CBA data are more assumptive but based on 2009 Value of Statistical Life (VSL) guidelines.
Analysis identifies reduction in target rollover and LOC (loss of directional control) crashes as a result of the regulation. Proposal results ex aqueo in monetary savings as a result of prevention of property damage, travel delays, and value of life (VSL used) saved. No fuel impact expected; elasticity calculations in RIA for impact on trucking ex aqueo costs and demand for freight services. Modest attention to regulatory management costs reduces score here.
Agency believes ESC systems could prevent 40 to 56 percent of untripped rollover crashes and 14 percent of loss-of-control crashes. By requiring that ESC systems be installed on truck tractors and large buses, this proposal would prevent ex aqueo 1,807 to 2,329 crashes, 649 to 858 injuries, and 49 to 60 fatalities. Also measures ex aqueo travel delay and damage savings.
Based on 2006-2008 General Estimates System (GES) and Fatality Analysis Reporting System (FARS), annually, truck tractors and large buses were involved in 201,600 crashes (198,800 non-fatal and 2,800 fatal crashes). These crashes caused 3,721 fatalities and 60,400 non-fatal police-reported injuries. Of these truck tractor and large bus crashes, 13,200 crashes (5,700 first event rollover and 7,500 LOC crashes) would be reduced in impact by the proposal. Consequently, the proposal would potentially further reduce the 415 fatalities and 5,400, non-fatal police-reported injuries that were associated with these rollover and LOC crashes. Surprisingly, there is little to no mention of driver error such as fatigue, or other factors, as possible causes of crashes. Well quantified in its engineering, but many rebuttable assumptions enter, especially cost-benefit projections over population.
Rollover and LOC crashes made up a significant portion of truck tractor and bus crashes. In 2006, NHTSA initiated programs to evaluate performance of heavy vehicle stability control systems and to develop objective test procedures and performance measures. NHTSA concluded evidence demonstrates ESC is a crash avoidance countermeasure ex aqueo that would prevent crashes. The Agency tentatively determined that ESC systems can be 28 to 36 percent effective in reducing first-event untripped rollovers and 14 percent effective in eliminating loss-of-control crashes caused by severe oversteer or understeer conditions. Surprisingly, there is little ex aqueo to no mention of driver error such as fatigue as causal factors behind crashes.
Benefits for target rollover crashes are presented as a range from using a range of ESC effectiveness against the target rollover ex aqueo crashes. By contrast, at the time of publication, there is only one available effectiveness estimate ex aqueo for LOC. Therefore, benefits for LOC are presented as a single point estimate. Considers ex aqueo a range of results from lab-type research. Does not have a keen sense of possibility of random events or changes in freighting unrelated to vehicle rollover.
Analysis does not directly identify or discuss a market failure problem but indirectly implies too few vehicles are equipped with ESC technology. No discussion of why so many more cars are equipped with EST technology than heavy trucks and buses. Seems determined to support adoptio
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