HIGHWAY LOSSDATA INSTITUTE

1005 N. GLEBE RD., ARLINGTON, VA 22201 TEL. 703/247-1600 FAX 703/247-1595 www.highwaysafety.org

August 27, 2001

Christine T. WhitmanAdministratorU.S. Environmental Protection Agency1200 Pennsylvania Avenue, N.W.Washington, D.C. 20460

Control of Air Pollution from Motor Vehicles and New Motor VehicleEngines; Revisions to Regulations Requiring Availability of

Information for Use of On-Board Diagnostic Systems and Emission-Related Repairs on 1994 and Later Model Year Light Duty Vehicles andLight Duty Trucks and 2005 and Later Model Year Heavy Duty Vehicles

and Engines Weighing 14,000 Pounds Gross Vehicle Weight or LessDocket No. EPA Air A-2000-49

Dear Ms. Whitman:

The Environmental Protection Agency has requested comments on thepublication of information by vehicle manufacturers that would allowaftermarket repair facilities to complete emissions-related vehiclerepairs. This information specifically includes the codes that somemanufacturers have incorporated into their antitheft devices. TheHighway Loss Data Institute (HLDI) is very concerned that the publication of this information will substantially weaken the theftdeterrence value of modern immobilizing antitheft devices.

HLDI is a nonprofit public service organization, wholly supported byauto insurers, that gathers, processes, and publishes data on the waysin which insurance losses vary among different types of vehicles.

HLDI has closely monitored the effectiveness of antitheft devicesavailable as original equipment from auto manufacturers. A 1983 comparison of 1980-81 General Motors vehicles with optional antitheftdevices reported a decrease in both the claim frequency and averageloss payment per claim for the vehicles with antitheft devices. In alater study, theft losses for Chevrolet Camaros and Pontiac Firebirdsdropped sharply when standard antitheft devices were added to 1989models. A 1996 study examined the lower theft losses associated withuse of antitheft devices on selected 1994 General Motors cars (HLDI,1996a). Another 1996 study documented the much lower theft losses in1995 BMW models after improved antitheft devices were installed (HLDI,

Christine T. Whitman August 27, 2001 Page 2 1996b). In 1997, HLDI looked at the effectiveness of antitheft devices installed on selected 1996 Ford models and noted that theft losses had dropped by almost 50 percent for vehicles with the devices (HLDI, 1997). In 2000, HLDI studied new antitheft devices available from a range of manufacturers for the 1999 model year and concluded that all of the devices were effective in lowering overall theft loses (HLDI, 2000). The publication of information that would allow these types of antitheft devices to be reset by any repair facility has the capacity to seriously compromise their effectiveness. Furthermore, it would be difficult if not impossible to confine this information to appropriate employees of repair facilities, with the almost certain result that people involved in vehicle theft would have access to the information and use it to steal vehicles. Currently, auto insurers view factory-installed passive immobilizing antitheft devices as being an effective loss control measure. In many states, insurance premium discounts are available for vehicles equipped with these devices. If vehicle manufacturers must publish the codes and other information necessary to start the vehicle once the immobilizer is activated, insurers will be forced to reassess the effectiveness of the devices and associated discounts. HLDI asks the agency to rescind this proposal to force vehicle manufacturers to publish codes and other information specific to antitheft devices. Factory-installed passive immobilizing antitheft devices from a wide range of manufacturers have been shown to be an effective deterrent to vehicle theft. Their value should not be compromised by the release of information that would allow thieves to subvert the system.

Sincerely, Kim L. Hazelbaker Senior Vice President

cc: Docket Clerk, Docket No. EPA Air A-2000-49 Enclosures

Christine T. Whitman August 27, 2001 Page 3 References Highway Loss Data Institute. 1996a. Theft loss bulletin 14(1). Arlington, VA. Highway Loss Data Institute. 1996b. Theft loss bulletin 14(2). Arlington, VA. Highway Loss Data Institute. 1997. Theft loss bulletin 15(1). Arlington, VA. Highway Loss Data Institute. 2000. Theft loss bulletin 18(1). Arlington, VA.

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Nissan Maxima Ford Ranger 4WD Ford F-150 Ford F-150 4WD Chevrolet Venture

1998 models - No immobilizing antitheft device1999 models - Standard immobilizing antitheft device

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HIGHWAY LOSS DATA INSTITUTE

THEFT LOSS

BulletinPrevious studies by the Highway Loss Data Institute have foundsignificant decreases in vehicle theft losses when factory-installedpassive immobilizing antitheft devices are introduced.1,2 RecentTheft Loss Bulletins have found appreciable decreases in the over-all theft losses for vehicles to which General Motors, BMW, andFord added passive immobilizing antitheft devices as standardequipment.3-5

Several manufacturers introduced standard factory-installedpassive immobilizing antitheft devices on 1999 models. Thosevehicles with unchanged designs for 1999 and sufficient exposurefor 1999 and 1998 model years were selected for this study: NissanMaxima, Ford Ranger 4WD, Ford F-150, Ford F-150 4WD, andChevrolet Venture.

The figure below compares the overall theft losses for these vehi-cles before (1998 models) and after (1999 models) introductionof the immobilizing antitheft devices. Losses are presented in

relative terms, with 100 equaling the all-passenger-car averagefor each model year. Results are based on coverage and lossesfrom a vehicle’s introduction through November 1999.

Overall losses decreased for all the 1999 models, although therewas a wide range of differences. The Nissan Maxima had thelargest decrease, from more than seven times the all-passenger-car average to just 32 percent above average. The Ford F-150and F-150 4WD also had significant decreases in overall theftlosses of about 50 percent. Overall theft losses for the Ford Ranger4WD and Chevrolet Venture were better than average before theimmobilizing antitheft devices were added but still decreasedsome for the 1999 models.

The drop in overall theft losses for the Maxima was due todecreases in both claim frequency and average loss payment perclaim (see table). The other four vehicles—Ford Ranger 4WD,Ford F-150, Ford F-150 4WD, and Chevrolet Venture—showed

VOL. 18, NO. 1 MAY 2000

RELATIVE AVERAGE THEFT LOSS PAYMENT PER INSURED VEHICLE YEAR,1998 VS. 1999 MODELS

HIGHWAY LOSSDATA INSTITUTE1005 North Glebe Road

Arlington, VA 22201

The Highway Loss Data Institute is a nonprofit public service organization that gathers, processes, and publishes insurance data on the human and economic losses asso-ciated with owning and operating motor vehicles.

COPYRIGHTED DOCUMENT, DISTRIBUTION RESTRICTED © 2000 by the Highway Loss Data Institute, 1005 N. Glebe Road, Arlington, VA 22201. All rightsreserved. Distribution of this report is restricted. No part of this publication may be reproduced, or stored in a retrieval system, or transmitted, in any form or by anymeans, electronic, mechanical, photocopying, recording, or otherwise, without the prior written permission of the copyright owner. Possession of this publication doesnot confer the right to print, reprint, publish, copy, sell, file, or use this material in any manner without the written permission of the copyright owner. Permissionis hereby granted to companies that are supporters of the Highway Loss Data Institute to reprint, copy, or otherwise use this material for their own business purposes,provided that the copyright notice is clearly visible on the material.

EFFECT OF PASSIVE IMMOBILIZING ANTITHEFT DEVICES ON THEFT LOSSES

Nissan Maxima Midsize car 1999 yes 36,217 112 134 99 1321998 no 85,466 770 307 240 736

Ford Ranger 4WD Small pickup 1999 yes 39,240 79 87 69 601998 no 66,111 137 80 99 79

Ford F-150 Large pickup 1999 yes 89,956 198 104 78 821998 no 239,933 786 130 131 170

Ford F-150 4WD Large pickup 1999 yes 44,467 88 92 52 481998 no 107,491 234 87 118 102

Chevrolet Venture Large passenger van 1999 yes 23,109 18 32 67 211998 no 64,807 56 31 78 24

All Passenger Cars 1999 100 =2.24 100 = $5,484 100 = $12.291998 100 =2.54 100 = $5,895 100 = $14.98

* Vehicles had optional alarm in 1998** Claims per 1,000 insured vehicle years

STANDARD

FACTORY- RELATIVE

INSTALLED RELATIVE AVERAGE

IMMOBILIZING EXPOSURE RELATIVE AVERAGE LOSS PAYMENT

BODY SIZE MODEL ANTITHEFT (IN INSURED NUMBER OF CLAIM LOSS PAYMENT PER INSURED

VEHICLE AND TYPE YEAR DEVICE* VEHICLE YEARS) CLAIMS FREQUENCY PER CLAIM VEHICLE YEAR

little or no improvement in claim frequencies for 1999 but diddrop significantly in average loss payments per claim for 1999.This pattern is typical for other vehicles to which immobilizingantitheft devices were added. The significant drop in average losspayments but not claim frequencies results from the antitheftdevice preventing the vehicle from being started and drivenaway; however, it does little to prevent partial thefts and damageto vehicles from attempted thefts. Hence, expensive total theftsof vehicles are reduced by the new antitheft devices, resultingin lower average loss payments; but theft claim frequencies,which are dominated by smaller claims, are less affected.

References1 Highway Loss Data Institute. 1994. Insurance Special Report A-42: FactorsAffecting Theft Losses , 1986-93 Models. Arlington, VA.

2 Highway Loss Data Institute. 1998. Insurance Special Report A-53: Theft LossFactors, 1990-97 Models. Arlington, VA.

3 Highway Loss Data Institute. 1996. Theft Loss Bulletin, Vol. 14, No. 1.4 Highway Loss Data Institute. 1996. Theft Loss Bulletin, Vol. 14, No. 2.5 Highway Loss Data Institute. 1997. Theft Loss Bulletin, Vol. 15, No. 1.

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Highway Loss Data Institute

Theft Loss

Bulletin

Vol. 15, No. 1 September 1997

Previous HLDI studies have found significant decreases in theft losses when factory-installed passive immobilizing antitheft devices are introduced.1,2 Two recent Theft Loss Bulletins have found appreciable decreases in the overall theft losses for vehicles to which General Motors and BMW added passive immobilizing antitheft devices as standard equipment.3,4

Ford began installing passive immobilizing antitheft de-vices, known as Securilock, on high-end 1996 Ford Mus-tang and Taurus and Mercury Sable models. On other models of these vehicle series, the new antitheft device was not available. The Securilock system is activated by removing the key from the ignition and features a com-puter chip programmed with a security code embedded into the ignition key. If someone attempts to start the ve-

hicle without the correct key, the system disables the en-gine to block a drive-away theft.

The figure below compares the average loss payment per insured vehicle year of 1996 Ford models with the Se-curilock system and corresponding 1995 models without this antitheft device. Only the Ford Mustang coupe and four-door Taurus had sufficient exposure to be listed. Results are based on coverage and losses from a vehicle’s introduction through April 1997. As shown in the figure, overall theft losses decreased dramatically after the anti-theft devices were added — an approximate 50 percent drop for both the Mustang GT/Cobra and Taurus LX/SHO. In contrast, models without such devices showed only minimal change in overall losses between the 1995 and 1996 model years. The all-passenger-car

Theft Average Loss Payment per Insured Vehicle Year1995 Models vs. 1996 Models

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$20

$40

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$80

1995 1996 1995 1996 1995 1996 1995 1996 1995 1996

Ford Mustang Coupe

No Antitheft Device

Standard Antitheft Device

Base All Cars

Ford Taurus Four-Door

G/GL GT/Cobra LX/SHO

average loss payment per insured vehicle year also changed minimally. Significant decreases occurred in both claim frequencies and average loss payments per claim for models with passive immobilizing antitheft devices. The average loss payments per claim showed the more pro-nounced decreases — 20 percent for the Ford Mustang GT/Cobra coupe and 28 percent for the four-door Ford Taurus LX/SHO — while the all-passenger-car result in-creased 8 percent. The reduction in theft losses for Fords with Securilock is consistent with results from other stud-ies of General Motors and BMW vehicles.3,4

Typically, the addition of passive immobilizing antitheft devices results in large decreases in average loss payments per theft claim and smaller decreases in theft claim fre-quencies. This pattern is not surprising because the anti-theft devices prevent vehicles from being started and driven away, but they do little to prevent partial thefts and damage to vehicles from attempted thefts. Hence, expen-sive total thefts of vehicles are reduced by the new anti-theft device. This results in lower average loss payments, but theft claim frequencies, which are dominated by smaller claims, are less affected.

Effect of Antitheft Devices on Ford Theft Losses

Vehicle

Model Year

Factory Installed Passive

Immobilizing Antitheft Device

Exposure (insured vehicle years)

Number of Claims

Claim

Frequency (claims per

1,000 insured vehicle years)

Average Loss

Payment per Claim

Average

Loss Payment

per Insured Vehicle Year

Ford Mustang base coupe 1995 No 72,327 415 5.5 $4,145 $23 1996 No 23,783 117 4.8 $5,213 $25

Ford Mustang GT/Cobra coupe 1995 No 44,966 427 8.9 $9,157 $82 1996 Yes 17,289 105 5.7 $7,312 $42 Ford Taurus G/GL four-door 1995 No 203,038 562 2.8 $4,253 $12 1996 No 68,706 149 2.3 $5,021 $11

Ford Taurus LX/SHO four-door 1995 No 21,017 76 3.9 $7,383 $29

1996 Yes 23,081 57 2.8 $5,341 $15

All Passenger Cars 1995 9,496,545 41,364 4.4 $5,632 $25 1996 3,708,796 14,113 3.8 $6,101 $23

References 1. Highway Loss Data Institute. 1983. A Comparison of the Theft Loss Experience of General Motors Passenger Cars with and without

Factory Installed Theft Deterrent Systems, A-19. Arlington, VA. 2. Highway Loss Data Institute. 1994. Insurance Special Report. Factors Affecting Theft Losses – 1986-93 Models, A-42. Arlington, VA. 3. Highway Loss Data Institute. Theft Loss Bulletin, Vol. 14, No. 1. February 1996. 4. Highway Loss Data Institute. Theft Loss Bulletin, Vol. 14, No. 2. April 1996.

1005 NORTH GLEBE ROAD, SUITE 800, ARLINGTON, VA 22201

The Highway Loss Data Institute is a nonprofit public service organization that gathers, processes, and publishes insurance data on the human and economic losses associated with owning and operating motor vehicles.

COPYRIGHTED DOCUMENT, DISTRIBUTION RESTRICTED © 1997 by the Highway Loss Data Institute (HLDI), 1005 N. Glebe Road, Arlington, VA 22201. All rights reserved. Distribution of this report is restricted. No part of this publication may be reproduced, or stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise, without the prior written permission of the copyright owner. Possession of this publication does not confer the right to print, reprint, publish, copy, sell, file, or use this report in any manner without the written permission of the copyright owner.