U.S. Department Of Transportation FINAL REGULATORY IMPACT ANALYSIS FMVSS NO. 214 AMENDING SIDE IMPACT DYNAMIC TEST ADDING OBLIQUE POLE TEST OFFICE OF REGULATORY ANALYSIS AND EVALUATION NATIONAL CENTER FOR STATISTICS AND ANALYSIS AUGUST 2007 TABLE OF CONTENTS Executive Summary.............................................................................................E-1 I. Introduction .................................................................................................I-1 II. Background ...............................................................................................II-1 III. Injury Criteria ........................................................................................... III-1 IV. Test Data and Analysis of Pole Test Data ................................................IV-1 V. Benefits .....................................................................................................V-1 VI. Technical Costs and Lead Time ...............................................................VI-1 VII. Cost-Effectiveness and Benefit-Cost Analyses .......................................VII-1 VIII. Test Data and Analysis of Moving Deformable Barrier Test ............... VIII-1 IX. Alternatives...............................................................................................IX-1 X. Regulatory Flexibility Act and Unfunded Mandates Reform Act Analysis............................................................................................... X-1 XI. Sensitivity Analyses ……………………………………………….........XI-1 XII. Probabilistic Uncertainty Analysis..……………………… ................…XII-1 Appendices A. The Side Impact Air Bags Sales Volume ..................................................... A-1 B. Head and Side Air Bag Hypothetical Case Study .........................................B-1 C. FMVSS 201 Benefits and Adjusted Target Population .................................C-1 D. Impacts of ESC on Side Impact Crashes ...................................................... D-1 E. Derivation of Bag Effectiveness and Benefit Estimates .................................E-1 F. The Effect of Side Air Bags on Fatalities and Ejection in Side Impacts .......F-1 G. Comments on the PEA ................................................................................. G-1 E-1 EXECUTIVE SUMMARY This Final Regulatory Impact Analysis analyzes the potential impacts of new performance requirements and test procedures for head and thorax protection systems in side crashes. The intent of this rulemaking is to improve occupant protection for belted and unbelted occupants in side crashes. Test Requirements The rule requires a new 20 mph, 75-degree oblique pole test run in two different configurations, one with a 50th percentile male (ES-2re) dummy and the other with a 5th percentile female (SID-IIs Build D) dummy. In addition to the oblique pole test, the rule requires a test with the ES-2re in the front seat and the SID-IIs Build D in the rear seat in the moving deformable barrier (MDB) dynamic FMVSS 214 side impact test, in place of the test with two 50th percentile male side impact dummies on the struck side of the vehicle (49 CFR Part 572 Subpart F (SID). Countermeasures The agency believes that side air bags for the head and thorax will be used to pass the tests and that most manufacturers will have to make their current side air bags wider to pass the oblique test. We analyzed the costs and benefits of three countermeasures: (1) the combination head/thorax side air bag, 2 sensor system, (2) the window curtain plus a separate thorax side air bag, 2 sensor system, (3) the window curtain plus a separate thorax side air bag, 4 sensor system. Combination air bags and thorax air bags are assumed for front seat occupants only, window curtains are assumed to provide head protection for both front and rear seat occupants. The agency believes the most likely E-2 countermeasure used by manufacturers will be a window curtain and separate thorax side air bag system with 2-sensors per vehicle. A few vehicles failed the moving deformable barrier test with the 5th percentile female dummy. The agency did not test any specific countermeasures to assure that these failing vehicles could pass the 5th percentile female moving deformable barrier (MDB) test. However, based on the MDB test results we believe that minor design changes such as the addition of door padding, improved armrest designs, and larger window curtains that come down to the window sill area, will lead to better protection for smaller occupants. This test will help assure that smaller sized occupants are protected to the same extent as the 50th percentile male occupants. Benefits The agency estimates benefits for occupants in outboard seating positions in near-side crashes of 12-25 mph delta-V in vehicle-to-pole and vehicle-to-vehicle crashes. The agency has also found that the side air bags provide benefits to unbelted far-side occupants in side impacts and for belted drivers riding alone in the front seat. After adjusting for assumed full compliance with the FMVSS 201 upper interior requirements, 100% Electronic Stability Control (ESC) penetration and manufacturer’s planned side air bag sales1 in the model (MY) 2011 vehicle fleet, and current compliance 1 Seven manufacturers (comprising about 90 percent of all light vehicle sales) responded confidentially to a NHTSA request for planned side air bag installations and projected sales through model year (MY) 2011. For remaining manufacturers, MY 2006 side air bag percentages were assumed to remain constant through MY 2011. E-3 with the final rule (based on testing recent vehicles with side air bags), the incremental benefits of the final rule are estimated as shown in the following table. Benefits of the Final Rule by Countermeasure2 Combination Air Curtain & Curtain & Bag Thorax Bags Thorax Bags 2 Sensors 2 Sensors 4 Sensors Fatalities 266 311 311 AIS 3-5 Injuries 352 361 371 Window curtains are estimated to have more benefits than combination air bags because we assume that window curtains will cover and provide protection for occupants in the rear seating positions. On the other hand, if a combination air bag is provided in the front, the pole test does not require a countermeasure for the rear seat and we assume no benefits for combination air bags in rear near-side impacts. Curtain and combination air bags probably will have some benefit in non-rollover complete ejections, but the agency has no way to estimate their benefit at this time. No benefits are claimed for ejections in rollovers, since the test does not check the effectiveness of a combination air bag or window curtain to contain occupants in a rollover event. The majority of the benefits are for front seat occupants, but a small number of benefits (5 fatalities and 18 AIS 3+ from window curtains reducing head impacts and one AIS 3 pelvic injury in the MDB test) were estimated for rear seat occupants. 2 The benefits of 100 percent of the fleet having side air bags compared to 0 percent of the fleet having side air bags, assuming 100 percent of vehicles have Electronic Stability Control systems, are estimated to be 976 fatalities and 932 AIS 3-5 injuries. E-4 Costs Potential compliance costs for the pole test vary considerably and are dependent upon the types of head and thorax side air bags chosen by the manufacturers and the number of sensors used in the system. The costs for installing new systems range from wide combination head/thorax side air bags with two sensors at $126 per vehicle to wide window curtains and wide thorax side air bags with four sensors at a cost of $280 per vehicle. Given the level of compliance in the MY 2005 fleet the average vehicle incremental cost to meet this final rule, over the manufacturer’s plans for side air bags in MY 2011, with the lower cost combination air bag is estimated to be $25 per vehicle and with the wide window curtains and wide thorax side air bags with four sensors is estimated to be $66 per vehicle (2004 dollars). This amounts to a range of total incremental annual costs of $429 million to $1.1 billion. Incremental Total Costs and Average Vehicle Costs ($2004) Combination Window Curtain Window Curtain Head/Thorax and Thorax Side Air and Thorax Side Air Side Air Bags Bags, 2 Sensors Bags, 4 Sensors Incremental Total Costs $429 million $560 million $1.1 billion Average Incremental $25 $33 $66 Cost per Vehicle Total Vehicle Cost per $126 $243 $280 New System Cost Per Equivalent Life Saved and Net Benefits Estimates were made of the costs per equivalent life saved. The low end of the range is $1.6 million per equivalent life saved, using a 3 percent discount rate, assuming manufacturers currently with no side air bags or only thorax side air bags install combination head/thorax air bags rather than separate window curtains and thorax air bags. The high end of the range is $4.6 million per equivalent life saved, using a 7 E-5 percent discount rate, assuming the manufacturers install separate window curtains and thorax air bags with four sensors. Costs Per Equivalent Life Saved Present Discounted Value Cost Per Equivalent Combination Window Curtain Window Curtain Life Saved Head/Thorax and Thorax Side Air and Thorax Side Air Side Air Bags Bags, 2 Sensors Bags, 4 Sensors 3% Discount Rate $1.6 million $1.8 million $3.7 million 7% Discount Rate $2.0 million $2.3 million $4.6 million Net benefit analysis differs from cost effectiveness analysis in that it requires that benefits be assigned a monetary value, and that