NHTSA, at the request of our beloved Congress, wants to find out if the various forms of obscure data that you didn’t know existed are of value when buying a new vehicle.
In 1972 Congress passed the Motor Vehicle Information and Cost Savings (MVICS) Act which was later codified in Title 49 U.S.C 32302. The law requires that dealers take information provided to them by the Department of Transportation and pass it along to car buyers.
The following three categories made up the information required by MVICS:
- Damage susceptibility, meaning the “susceptibility of a passenger motor vehicle to damage in a motor vehicle accident.”
- Crashworthiness (how protected you are in a crash), crash avoidance, and any other areas the Secretary determines will improve the safety of passenger motor vehicles
- Degree of difficulty of diagnosis and repair of damage to, or failure of, mechanical and electrical systems
The law also required dealers provide buyers insurance cost data, based on damage susceptibility and crashworthiness, and collision loss experience data.
NHTSA gathered insurance costs in a booklet known as the Insurance Cost Information Booklet. Dealers were required by law to share this information with potential buyers and because the Department of Transportation decided in 1993 to only give one-per-dealership, dealers had to make their own copies of the booklet. The booklet’s information was developed using information from years prior. For example the latest book, dated February 2013, uses average loss payment per insured vehicle for 2010-2012 models. I'm uncertain how this applies to someone buying a car today as most of the data regarding motor vehicle damage is specific to a certain models' design and a 4 year gap will likley cross into a newly designed vehicle meaning the data could be useless.
The data was of little value at predicting actual costs as it didn’t take into account a buyer’s age, driving record, state or vehicle storage (street-parked vs. garage-parked). If a buyer was really anxious with the costs to insure one vehicle over another, all they need to do is log into their insurance website to compare rates.
Stop and consider just how time consuming (and inaccurate) this process might have been. NHTSA had to request, compile, package and serve all of this data to over 2,700 dealerships in the hopes that it was informing consumers. In my many years of exciting car-buying adventures I don't recall ever being asked if I wanted to see a copy of the Insurance Cost Information Booklet.
Thankfully on January 10, 2013, after 40 years of producing the booklet, Congress repealed the requirement saying it was “obsolete.” (You think?)
While Congress didn’t repeal the Secretary’s “discretionary authority” to “require dealers to distribute damage susceptibility information” they did mandate that the agency ask for the public's input before deciding on how to provide this "valuable information" [costs to insure and damage suspecibility].
This is where the rubber meets the road and where you, the public (can/maybe/should/won't?) take action.
While this specific rulemaking doesn't seek to threaten your motoring livelihood, it is a good practice run for how to participate in government and not sit on the sideline moaning about it.
How to post a comment
Before you post your clever Kinja-comment/gif below let me explain how to comment on a Proposed Rule should you decide to participate.
Note: Deadline for comments is January, 28, 2014.
First, go here: https://federalregister.gov/a/2013-28590
Next, click on the large green box that says SUBMIT A FORMAL COMMENT .
A new window will pop up where you type in your comment and your name. You can use your real name or an anonymous name, like your Kinja username. Either way the NSA already knows who and where you are so anonymous is somewhat irrelevant.
Uncle Sam has some sage advice for new commenters:
“A comment can express simple support or dissent for a regulatory action. However, a constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making.” In other words, gifs of cars spitting fire or comments like “CAFE sucks, while entertaining, they are not constructive.
For those that don’t feel like participating in the process, below are the questions NHTSA would like you to consider when providing comments.
a. Provide any comments on consumer experiences with the usefulness, reliability and availability of insurance cost information based on damage susceptibility for motor vehicles.
b. Have there been any instances that can be provided to support whether consumers have requested information on the damage susceptibility of vehicles when they have visited dealerships?
c. Have there been any instances that can be provided to support whether consumers have seen, requested or were provided a copy of the Insurance Cost Information Booklet when they have visited dealerships?
d. What suggestions do you have to increase public awareness of damage susceptibility and insurance cost information?
e. What suggestions would you make to improve the availability of damage susceptibility and insurance cost information to new car purchasers?
f. Provide any comments or information on consumer usage of the Insurance Cost Information booklet as a reference tool for purchasing a vehicle.
g. Is the information helpful/useful and why?
h. What changes could be suggested to make the Insurance Cost Information Booklet more useful, informative, simple and understandable to consumers?
i. Are there any reliable real-world data or studies available on damage susceptibility and collision loss characteristics of passenger vehicles? Please provide applicable data and source, or other information you believe would be helpful to the agency in determining the best possible information/data available.
j. Are real-world data or studies available relevant to insurance premium differences? Please provide applicable data and source or other information you believe would be helpful to the agency in determining the best possible information/data.
k. What would be the impact of not providing the damage susceptibility and insurance cost information to prospective purchasers of new vehicles?
l. Does the current information provided in the agency's Insurance Cost Information Booklet address the needs of consumers? If so, how? If not, what could the agency do to enhance the information to meet the needs of consumers?
m. Are there any agencies or organizations that would find it useful to provide the damage susceptibility and insurance cost information to its consumers, customers or clients and if so, why?
n. Is the current format for the Insurance Cost Information Booklet simple and understandable? Would you recommend changing the format? If so, how would you recommend it be changed?
o. What would be the best method for distributing this information to consumers?
p. What would be the best way to convey information to consumers about the likelihood of a vehicle being damaged in an accident?
q. Are there any organizations or state agencies that collect the information identified in this notice that NHTSA should be aware of? If so, how do these entities use and/or publish this information?