NCPA - National Center for Policy Analysis

Proposed Motor Vehicle Safety Standard Has Few Benefits

March 5, 2013

A new regulation proposes that hybrid and electric motor vehicles make enough sound to alert the blind or visually impaired of their presence. The Regulatory Impact Analysis (RIA) of the rule states that there is a net benefit; however, it seems that the benefit has been overestimated, says Jerry Ellig, a senior research fellow at the Mercatus Center.

  • The RIA calculates monetized benefits of $221.1 million for avoided pedestrian and pedalcyclist injuries with only $25 million in costs, and concludes the regulation is effective at either a 3 percent or 7 percent discount rate.
  • The official cost-benefit analysis overestimates the benefits by including more than $115.1 million in benefits for pedalcyclists, whom the law is not specifically targeted at.
  • Only 3.3 percent of the U.S. population is blind or vision-impaired.

Regardless of how present value is discounted for the future, the NHTSA states the regulation will be effective as long as it reduces 13 percent to 15 percent of the discrepancy in crash rates between internal combustion and hybrid vehicles.

  • The proposed rule states that it is targeted at blind or vision-impaired individuals but the RIA uses estimates of crashes involving all pedestrians, not just the blind, which make estimates of the rule's beneficiaries inflated.
  • The RIA also claims significant benefits to cyclists, though it acknowledges that the crash rate for cyclists and hybrids below 35 miles an hour is not statistically significant.
  • The RIA also fails to establish any baseline for the crash rate between normal vision pedestrians and cyclists, so it is impossible to estimate the benefits to this population.

Given the inaccuracies of the official cost-benefit analysis, alternative options should be pursued. If alternative options cannot be identified, at the very minimum, the RIA should be updated to reflect the true costs and benefits of this proposed rule before it is adopted.

Source: Jerry Ellig, "National Highway Traffic Safety Administration Federal Motor Vehicle Safety Standards," Mercatus Center, February 27, 2013.


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