Vol. 6,No.15 October 6, 1 1

is proposing to abandon the currentoffering weaker against crash UU.JL.U·U..MV.

The proposals range from maintaining barrier and 3 corner.......... "'1-' ....... ,"" ... tests for front but substituting a barrier test and 1.5 corner impact test

for rear to eliminating test requirements for front and rear systems, except for certainheight provisions. (See on page The rule now being met all new cars since therequires manufacturers to provide bumpers that withstand 5 perpendicular and 3

.............................1-.. """ either to the car or the system.

.... ....... JL"""..I.~' ... _Jl'lio.. .... ..L~'J-J notice provides for a comment period and announces ameeting on the The meeting will be divided into two sessions. The first will be held "'""-"',"'¥.¥~,

and, if necessary, October session for November 2. If necessary the .Ll.l.~/~L,JL1Jl.-"

be on November 1

2 - Status Report, Vol. 16, No. 15, Oct. 6,1981

Nine alternative proposals for changing the Part 581 Bumper Sta11dard, each one of whichrepresents a weakening of a bumper's ability to protect a vehicle from crash damage, have beenoutlined by NHTSA. Retention of the present standard, which has been met by all new passengercars since the 1980 model year, is not offered as an option. Briefly, the alternatives offered arethese:

Alternative I-A - Retain the present 5 mph test impact speed for front bumpers, but changethe rear bumper test impacts to 2.5 mph, with 1.5 mph corner pendulum impacts.

Alternative I-B - Same as I-A, but going back to Phase I damage criteria for both front andrear bumpers. (Phase I allowed damage to the bumper itself and its brackets and fasteners.)

Alternative II-A - Keep front-bumper requirements the same as they now are, but eliminateregulation for rear bumpers except for a standard height requirement.

Alternative II-B - Same as II-A, but substituting Phase I damage criteria for the front bUln-per.

Alternative III-A - Change test impacts, both front and rear, to 2.5 mph, with 1.5 mph pen­dulum impacts for corners.

Alternative III-B - Same as III-A, but substituting the Phase I damage criteria for both frontand rear bumpers.

Alternative IV-A - Reduce front-bumper test impact to 2.5 mph, wit11 1.5 mph corner iln­pacts. Eliminate all but a height requirement for the rear bumper.

/!lternative I~/-B - Same as IV-A, but substituting Phase I damage criteria for front bumper.

Alternative V - Eliminate current tests for front and rear bumpers, retail1ing only a heightrequirement and a minimal 1.5 mph pendulum impact.

lVHTSA Offers Nine Weaker Bumper Rules (Cont'd from page 1)

In its rulemaking notice, NHTSA reverses its own earlier findings on the costs and benefits of the 5tn.ph bumper standard. In 1979, the agency issued an analysis which concluded that a 5 mph "no-damage"rule would be cost-beneficial to consunlers. Earlier this year, using revised cost estimate assumptions, theagency concluded that a 5 Inph frontal test impact requirement would be cost-beneficial for consumerswhile such a standard for rear bumpers is not worth the cost.

In the rulemaking notice, NHTSA says it has tentatively concluded that " ... the current standard costsconsumers more than it saves then." Such a conclusion, the notice says, makes it statutorily necessary forthe agency to undertake rulemaking aimed at reducing such costs.

"Action at this time is deemed necessary beca"use of the degree of agency confidence in the conclusionthat each alternative under consideration is superiorjn statutory terms to the current standard," NJ-ITSAsays in its notice.

Present Rule Issued in 1976

The Motor Vehicle Inforlnation and Cost Savings Act, passed in 1972, directed the Departnlent ofTransportation to set effective sta11dards for reducing low-speed crash damage. In 1976, NHTSA isslled a

4 Status Report,

..............."' ....... .LJ.. _ that "considerable uncertai11ty still about many aspects of the bumperits new notice of proposed fulemaking has invited comment on 25 questions that it saysof an alternative weakened standard. are paraphrased highlights the questions:

inon the choice

on page

Bumper technology has so changed since the 1973model year when 2.5 mph bumpers were required that it isimpossible to determine what benefits of 2.5 mph bumperswould be today. How should NHTSA deal with this issue?

• If regulations were to be dropped, how would com­petitive pressures on auto makers affect bumper ...... "" ........ _ .......and how would this affect cost estimates?

• What effect would addition 1.5 mph test im­to the "height only" alternative have on bumper

designs and costs?

• If bumpers were redesigned under lower standards,would other vehicle components have to be lTIodified tocompensate for this reduced bumper energy Inanagementcapability? Is there a minimum level of bUlnper perfor­mance necessary to assure compliance with crashworthinessstandards?

• NHTSA estimates reducing bumper design speedsto 2.5 mph will cut manufacturers' variable costs from 15to 30 percent and assumes these savings will be passedthrough to the consumer. Are these reasonable assumptions?

• Would auto makers incur any increased retoolingcosts if the bumper standard were modified?

Savings in finance charges associated with possiblereductions of car prices resulting from bumper modifica­tions are figured in bUlnper benefits, using the presentdiscounted value of the finance charges. Is this an appro-

adjustment?

• NHTSA uses the General Motors' X-car as a modelin estimating the percentage of bumper consumer costrepresented by variable cost (64 percent). Is this modelrepresentative?

What effect would reduction of the bumper stan­dard to 2.5 mph or less have on repair costs for other carcomponents in collisions at speeds greater than 5 mph?Would increased damage to vehicle safety systems resultingfrom reduced bumper damage resistance increase the num-ber and of traffic crashes?

NHTSA estimates that heavier bumpers are re­quired by higher test speeds and that each pound of weightadded results in the consumption of 1.1 gallons of fuel overthe life of the car. Is there a better means of measuringlifetime fuel savings?

• In computing bumper costs, NHTSA estimates gas­oline will cost $1.60 a gallon in 1982 (in 1981 dollars). Isthis reasonable?

• What would be effects in repair costs of mixingmore "agressive" (5 mph) front bumpers and less "aggres­sive" (height only) rear bumpers?

• Which data source is most reliable in measuringthe frequency of unrepaired and unreported low-speedcrashes?

• How should the cost of unrepaired damage bevalued? At full repair cost or some other figure?

What data are available that would pennit calcu­lation of the probability of a crash at various stages of avehicle's life?

• Can significant differences in repair cost estimatesbetween 1978 and 1980 model years be attributed to theadded Phase II (no damage to bumper) requirements?

If the bumper standard is reduced, what would bethe impact on component suppliers and on the automobileinsurance industry?

In its calculations, NHTSA values consumer timesaved by improved bumpers at $7.10 an hour, but somestudies suggest consumers are not willing to pay that muchto avoid delays. Which is correct?

Is a $10 value on the loss of use of a car while itis being repaired adequate to account for alternative trans­portation and other factors?

• What new technologies are available in bUlTIperconstruction that may be precluded because of NHTSAtest procedures or Phase requirements?

Do benefits from iInproved bumper performancevary among different sized vehicles?

If the bumper standard were lowered, to whatextent would auto makers continue to offer 5 mph Phase IIbumpers? Would purchasers be sufficiently well-informedabout differences in bumpers to make intelligent purchasingdecisions?

Do bumper criteria unduly restrict manu-facturers in offering optional equipment (i.e. lalnpswhich must be attached to bumpers)?

Status Vol. 16, No. 15, Oct. 6,1981 - 5

*All 1980 dollars.

6 6, 1981

unneces-test reOIUU"emlentsWhat are the costscriteria "dent"of and "set" (aE~V12lt1c.n

............ "' .. ..,. .. r ..."" relative to the vehicle

Status 1981 7

advocate

8 Status Oct. 6,1981

page

standard is Industries, a corporation properties include amanufacturing steel In support of the Phase standard are representatives of

the industry, a soft-face bumper and which testifies thatexisting cost-benefit analyses, including the study, are "fatally flawed" and the

to gather more data .. After the extensive the committee members vote againstback the bumper requirements.

publishes its "final assessment" of the lLJ ................ "-J"-' ... u,",,,,,,..s. ... ",-,-,,,,,.... agrees with thestandard provides greater benefits than would a mph standard,

determines about million a year more .. Somewhat greater benefits are ......s. ... 'lo....... ....."L,..&." '-. a 7.5the agency observes, but it this conclusion "less than its basic ,"/""'} as to the

votes to back the bumper standard from~"''''~l'''''''''''''-''''''''i-''''''-' voice vote, comes on an amendment Senate

authorizations

In Phase the Part 58 standard takes effect; it specifies the 'lJ ....... ~L ...... RJ .......... U

"' ...... ,.,.' ............., .......... y ...... u .. along with other parts of car, also must be undamaged in the compliance tests.

staff in October by the House CommerceSubcommittee, strongly favorable to the notes:

'''<-Lll,'A.';''''-' costs under legislation is 8

House December votes a version of the authorizations without the ....., ... ..,.".... ....... ,,..,,.. ..::J ..,u..~.L-.".L

_ ' amendment; the conflicting al1d House bills must go to conference committee.

""" ...... Jl.L ............ ~ issues to the standard. Inwithstand a 5 mph save motorists money.

the net benefits current 5and "

1lJ ....... ~~.L..l..lJ.J •.l......,-. by the Data inn'l'l1'"Y'\'Y"I.L"l. ..... safety performance standard has had a beneficial effect on

COlnpares insurance data for the year withtook finds that there were "substantial reductions" in

payments per year after the standard was

.. ~L/_....'.' ..... ....,. •• crash test results for 1 which are fully"show that 5 front-into-barrier 0 car-to-car T'L.>.,.T"_L.:• ..., T ·"'·.

the tested model cars. .. sustained little or no damage. This is in contrast to the many 'L£. ............... ...,

-......, ........ II.<\.Jl,U per car by and 972 models those manufactured before any standardin effect in identical tests.

authorizations go to conference and the~'I.4.1..I."'IIJ"""".L standard is adopted in the 1>-/ ...., ' 1 IlJC:..LV.l'l U~l .

the Houseamendment to back the

The Senate adopts the conference report by a voice vote in October, but the to act beforethe election recess.. after the the House cannot reach agreement

authorizations bill which also includes controversial airadjourns without action on the matter.

Status Report, Vol. 16, No. Oct. 6, 1981 9

The 5 mph property-damage bumper standard ..... L:lt."t"\""In ....."C' in effect.

1981: In March, the IIHS reports results of low-speed crasl1 tests on popular 1981 subcompacts,emphasizing the substantial differences in protection that different bumper systems offer. Ford Escortproves to have the best-perfoffi1ing system, having less than the damage of the worst­performing system, found on the Toyota Corolla Tercel. The relatively severe tests show that bumpers neednot be heavy to be effective, for Escort bumpers, front and rear, weighed 2.4 percent of the car's weight,v/hile the Tercel's system weighed 3.1 percent of the car's weight.

In April, NHTSA announced plans to virtually eliminate or substantially weakel1 bumper requirenlents.In a Notice of Intent released by t11e acting administrator, the agency revealed its plans to "propose amend­ments to the bumper standard in April 1981, which will propose eliminating the rear standard completely

either eliminating or modifying the front bumper standard, as appropriate."

Bumper That Can't(Copyright 1981 by Consumers Union of the United States, Inc., Mount Vernon, N. Y., 10550. Excerpted by permissionfrom Consumer Reports, June 1981.)

(Cont'd on page

Under the law, NHTSA has no power to roll back thebumper standard arbitrarily. An act of Congress requiresthat the standard achieve "the maximum feasible reductionof costs to the public and to the consumer." To eliminatethe standard, NHTSA has to show that the benefits (alighter bumper would save fuel and presumably cost lessto manufacture) outweigh the costs the increased damageto cars in low-speed crashes.

Now, presumably in the name of economy, the ne\tvcrew at the National Highway Traffic Safety Administra­tion says it intends to eliminate all crash standards for rearbumpers and either eliminate the front-bumper standardor reduce it from 5 mph to 2.5 mph (about the speed ofa person walking). That was one of the 34 changes pro­posed in April.

In addition, in the view of CD's auto engineers, thesloping

front end, are much less hazardous to pedestrians than werethe old-fashioned horizontal bars protruding on struts.

Crash tests conducted last year by the InsuranceInstitute for Highway illustrate what strong bumpersmean to consumers in dollars and cents. The insurancegroup crashed a dozen 1980 cars into a barrier at 5 o1ph;not a single car sustained damage. A decade ago, the insti­tute had done the same test on 1972 models; the damageaveraged $200 per car - the equivalent of about $400per car at today's prices for parts and labor.

basher." Before the new standard, it was not unusual forus to have to replace a bumper and make otherbefore we could resell a test car, since damage was oftenextensive. Now, on many new cars, there's no visibledamage.

As part of our routine testing, we ram bumpersat 5 mph with a heavy steel battering ram a "bumper

In testing cars over the years, CD has rarely en­countered a change as dramatic as that brought about bythe bumper standard that went into effect with the 1979models. Those rules require that both front and rearbumpers protect a car's body and grille from any damagein crashes up to 5 mph, and that, with the 1980 models,the bumper itself remain substantially undamaged. Theprevious standard, in effect for the 1973 to 1978 models,required only that the bumpers protect the safety systemsof the car - the headlights, for example - in low-speedcrashes.

Heart in mouth and papers in hand, he climbed outof the Rabbit to exchange the information that the insur-'!Hce cQ]llRaIlJ,~_S~~WJHJllt:1JJl~~J~~=::-_~a][}<::tlQ_Jn:~_p~Ql~th~L~,amagt~_.m ....~_.mmnew __bllm1peI·s,..Jmany of·wJbic.h .... alrejn1;eg][atE~dintoThere was none. Not a dent or a scratch anywhere, noteven on the bumpers. The Rabbit's bumpers, though notthe best bumpers these days, met the National HHrhuT':l"

Traffic Safety Administration's current standard.

It was the first snowy day of winter. A CU staffmem­ber was driving a colleague to the office in his shiny Volks­wagen Rabbit, just two weeks off the showroom floor.On a snow-slicked incline leading from the New York State

the Rabbit began to slide downhill. Our staffmember brought the car under control before reaching theintersection. But a heavy four-door sedan behind him, alsosliding down the hill, failed to stop in time. It crashedsharply and loudly into the rear of the Rabbit - the kindof low-speed collision that leaves one shaken but unin­jured. As our staffer reached for his license, registration,and insurance papers, he visualized the broken glass andcrushed steel a quick end to the new-car honeymoon.

1981

That !rompage

Status Vol. 16, No. Oct. 6, 1981 11

Eliminating or the bumper standard wouldsave $650 million a year, claims the NHTSA. Barryassociate administrator of plans and programs for theagency, says that NHTSA studies indicate that, after tradingoff the costs the benefits, improved front bumperswere saving consumers about $15 a year while the rearbumpers were costing them $80 a year a net loss of$65. With 10 million cars sold a year, that came to $650million, said Felrice.

To come up with the $65 annual net "cost" to con­sumers for the improved bumpers, NHTSA calculated howmuch weight would be saved if they were scrapped. Theagency concluded that the average bumper system wouldweigh 39 pounds less without the requirement,

about $89. It also decided that the car's chassis couldbe 39 pounds lighter, saving about $43. It added to thosefigures a saving of some $75 in gasoline costs over 10 years,because the car would be 78 pounds lighter. From the total,it subtracted an estimate of what the stronger bumpers aresaving in costs. The net saving from scrapping thebumper standard was the $65.

But NHTSA's figures were based on the difference inbetween a pre-1973 bumper and today's bumper ­

an unreal comparison, since the auto industry would notreturn to the bumpers of that era. To n1ake real-world con1­putations, we called General Motors for its GM,which is not likely to understate the costs of complyingwith Government regulations, estimated it could savean average of 25 pounds if the bumper standard was

dropped. GM also estimated that another 15 to 19could be taken off the car itself. That makes GM'slation of the total weight saved to be 40 to 44 LJUl,U.lU,:).

not the 78 pounds used by NHTSA. NHTSA'sper-pound figures, the savings in dollars would be about$57 for the bumper itself, about $21 for the body weight,and about $42 for the gasoline. That totals $120, or sonle

less than NHTSA's That wipes out the supposed$65 saving and then some.

NHTSA's calculations also left out an almost certainrise in auto-insurance premiums. We asked the nation'stwo largest auto insurers how n1uch the rates for collisioninsurance would rise if the Government bun1per standardwere dropped. Allstate Insurance Co. told us there wouldbe a 15 percent increase" State Farm Mutual AutomobileInsurance Co. estimated "at least 10 percent." Accord-

to Allstate, the consumer who supposedly "saves"$65 on a car with bumpers would end up paying$110 in increased insurance premiums over a five-yearperiod.

The Administration announced its intention to waterdown the bumper standard in a booklet titIed "Actionsto Help the U.S. Auto Industry." How weaker VLf.Jl.L.LIJV.LiJ

would help the industry is not entirely clear. NHTSAAdministrator Diane Steed concedes that it would

cost the automakers $30 million to retool in order to pro­duce the flimsier bumpers. The NHTSA booklet, whichadds up the dollar savings to automakers from the variouscutbacks, doesn't take that $30 million into account.

• WEAKER BUMPER RULES are proposed by

NHTSA to replace the Part 581, Phase II standard in

effect since the 1980 model year. 1

NINE ALTERNATIVE PROPOSALS are listed by

NHTSA, but retaining the current bumper standard is

not offered as an option.. . ... Page 2

• IMPROVED TECHNOLOGY has been

NHTSA in equipping two different versions

of the Research Vehicle.. 3

25 have been asked NHTSA as

the basis of comments on the proposed changes in

bumper standards. . . Page 4

• LOW-SPEED CRASH TESTS conducted by theInstitute have shown the benefits of requiring more

damage-resistant bumpers. 5

• A BRIEF HISTORY of the development ofthe federal bumper standard covers 1969 to the

present. .. Page 6

• THE LITTLE BUMPER THAT CAN'T is anarticle reprinted with permission from the June

1981 issue of Consumer Reports. 9

VISIBLE PROOF of the improvement in bumper

designs under the federal standard is shown in a 974­

1981 model comparison. .. Page 10

part,

20037