Comments of the Competitive Enterprise Institute and Consumer Alert to the United States Department of Transportation, National

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COMMENTS OF

THE COMPETITIVE ENTERPRISE INSTITUTE AND CONSUMER ALERT

TO THE UNITED STATES DEPARTMENT OF TRANSPORTATION,

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION,

CONCERNING ITS TECHNICAL REPORT ON VEHICLE WEIGHT, FATALITY RISK AND CRASH COMPATIBILITY

Docket No. NHTSA-2003-16318

68 FR 66,153 (Nov. 25, 2003)

The Competitive Enterprise Institute (CEI) and Consumer Alert hereby submit these comments on NHTSA’s new technical report by Charles J. Kahane, Vehicle Weight, Fatality Risk and Crash Compatibility of MY 1991-99 Passenger Cars and Light Trucks (Oct. 2003).

CEI is a non-profit research and advocacy organization dedicated to reducing government overregulation.  Consumer Alert is a membership organization involved in protecting and expanding consumer choice in the marketplace.  Both of these organizations have long been involved in CAFE and related issues.  In 1989-95 they undertook a series of court challenges to NHTSA’s treatment of the CAFE-safety issue.  The holdings in those cases are highly critical of NHTSA’s treatment of the CAFE-safety issue.

CEI and Consumer Alert file these comments in light of calls by some organizations and individuals for more stringent CAFE standards and for heightened regulation of SUVs.  In our view, such action is unwarranted; in fact, the new Kahane study provides support for actually reducing CAFE standards.