May 11, 2011

HB 540: Biennial Vehicle Safety Inspections

NHADA opposes HB 540 and the move to change motor vehicle safety inspections from annual to every other year.

• The attempt to kill or modify this program has been made before and has been defeated every time. The identical bill was voted Inexpedient to Legislate (ITL'd, or killed) in 2006, in 2008, and in 2009.
• This session the House Transportation Committee sent this bill to the floor with a recommendation of ITL by a vote of 11 to 1.

Up front we would like to state: The safety inspection process is not one that is about maximizing profit for a dealership or inspection station, as the sponsors would have you believe. It is about ensuring that the customers, citizens, and the motoring public are kept safe and protected. This is the most important issue.

It is difficult, if not impossible, to quantify the number of accidents that were prevented because our safety inspection regulations were in place. However, of the over 265,000 vehicles that failed their safety inspection in 2010, there is a strong possibility their condition might have led to an accident.

It is quite alarming that almost 20 percent of the over-1.3 million vehicles inspected on an annual basis fail.

• The NH Department of Motor Vehicles (NH DMV) has stated that nearly 80,000 vehicles failed for brakes in 2010. Brakes are only one of 13 inspection items.
• Another 79,410 NH vehicles failed for front-end and steering issues in 2010.
• In 2010 over 40,000 vehicles failed for tire issues.

Studies on the issue are on our side.

• In a study conducted by the Institute for Research in Public Safety and the National Highway Transportation Safety Administration, mechanical defects and/or worn equipment on vehicles was a causative or an aggravating factor in 12.6 percent of crashes – over 850,000 accidents annually could have been avoided
• A study conducted by the Pennsylvania Department of Transportation in March 2009, the most recent and exhaustive to date (it included analysis of 17 previous studies), found that:
  • Nationally, vehicle safety inspection programs appear to be a signficant factor in lowering fatal crashes, and
  • As a result of the Pennsylvania inspection program, there are between 115 and 169 fewer fatal crashes, which correspond to between 127 and 187 fewer fatalities annually.

Safety inspections are an annual maintenance procedures that actually save customers money.

• Preventive maintenance and annual inspections clearly save customers money:
  • Brake pads cost less than $200, brake pads and rotors cost $350.
  • Steering component repair (a ball joint, spring, or tie-rod) can cost $300, a steering component failure can cost over $3,000, not including potential bodily injury and harm.
  • With annual inspections, problems can be found while vehicles are still covered by the manufacturers' warranties, saving citizens money!

We hope the legislature weighs the benefits of saving consumers the cost of a small annual expense versus the cost of neglecting a problem for up to 23 months. For consumers this could mean failure to repair a vehicle even while it is still under warranty (i.e., an emissions-related issue), which can lead to their liability for unnecessary and expensive repair costs. It is less expensive to repair just brake pads rather than brake pads with calipers and rotors.

It is important to note that a safety inspection is a snapshot inspection on the day of review, not a prospective-looking, 12-month analysis. Extending this to 24 months is far too risky for public safety.

With the current economy our members are reporting that people are doing only the bare minimum of repairs to vehicles. They want to spend as little as possible. Going to inspections every 24 months will aggravate this and lead to more unsafe roadways. Shops report that a majority of customers will repair mechanical safety issues only if they have to.

Studies also show that the average age of vehicles on the road has increased more than ever. The median age of cars in the U.S. fleet has climbed to an all-time high of 9.4-years, according to RL Polk. Nearly 35 percent of the light vehicles on the road are 11 years or older! The median age has been increasing year after year; we have an older fleet. Under HB 540, those older vehicles will be looked at less often, not just for wear and tear, but for serious safety issues.

New Hampshire has a harsher New England climate and terrain. We cannot be compared with other states that do not require safety inspections (Arizona, California, Florida, and drier but snowy states such as Colorado). Our wear and tear on vehicles is unlike that of many other states.

• Many of our neighboring states including ME, MA, VT, PA, and NY all have annual safety inspections.

The NH Department of Safety and the Division of Motor Vehicles, oppose this bill for many reasons including the fiscal impacts that this legislation may have on their budgets, but most importantly for public safety. DMV Director Richard C. Bailey Jr. stated during house testimony that this is far too risky a study for NH to conduct with its citizens. Although difficult to quantify, increased accidents due to vehicle mechanical failures on our roadways will certainly cost the state money for additional emergency response, accident investigations, and roadway repair.

The NH Department of Environmental Services is opposed to the bill due to the potential for negative air quality impacts. The department fears that the state will become non-compliant with EPA Clean Air Act requirements and be subject to sanctions and potential loss of federal highway funding of up to $300 million.

Ultimately the safety inspection program in New Hampshire is about finding a balance and providing a safe and secure quality of life with reasonable, sensible regulation. We feel it is not a program of over-regulation or under-regulation but one that makes common sense to our citizens, young, old, and in-between. It provides to them a great benefit and important protection.