January 9, 2003, Open letter to Sam Kazman
http://energy.saving.nu/biofuels/kazman.shtml
(Sam Kazman's response to the open letter at the end of this mail.)

Dear Sam Kazman,

It is nice to hear from you and get a chance to understand on what basis 
you constructed your opinion, even if you did not answer on a single one of 
the questions I gave you. On your request I will of course copy my answer 
to the same recipients as my first letter. I think it is a very important 
issue and I welcome the opportunity to discuss it with you, even thought 
your answer might have been more effective without the comment about 
"moralistic ranting".

The link you gave me,
http://books.nap.edu/books/0309076013/html/3.html#pagetop
was valuable and it is honest of you to so clearly present the basis of 
your understanding. I assume that you refer to the whole report and not 
just the single table 2-2. I read the report, it offers much valuable data 
and opinion, some that I agree with and some not. The issues that I have 
another opinion on are mostly related to European data that differs and 
some of the conclusions. I recommend anyone to read the report, it is good, 
it even recognizes the fuel economy success of diesel cars in Europe.

If you read my letter, I did not really intend to take up your favorite 
issue of vehicle weight, but rather to deal with a car type that has some 
specific and dangerous properties. I will therefore try to keep to this in 
my answer, even if it is tempting to challenge your whole argument of 
weight which can be done based on the report that you refer to. I have to 
touch on the weight issue anyway and maybe we can expand that discussion at 
a later stage.

In the report it is clearly stated that the largest change of fatalities 
relating to weight does not come from the absolute weight but from a change 
in the mix of the different weights in the fleet. This means in absurdum 
that if the fleet consists of only two types, one half of very light and 
the other half of very heavy vehicles, the risk and fatalities reach a 
maximum. If the fleet consist of vehicles of equal weight the risk would be 
minimum, if they have a maximized safety design. If we had an equal weight 
vehicle fleet, the absolute weight might or might not be an issue for 
safety concerns. The point is that a change in the relations between heavy 
and light vehicles will effect the number of fatalities.

The report covers vehicles between 1 and 3 years of age. The 1993 numbers 
point to an effect of a switch over to lighter vehicles due to the CAFƒ 
standard and had a rising effect on fatalities. The report however 
recommends incentives/penalties that would encourage measure to make 
vehicles over 4,000 lb lighter and states that this could give safety 
gains. Your opinion on the weight issue is therefore worth further 
scrutiny. In the last few years we have a very large change in the mix, 
with the marketing, tax incentive and popularity of SUVs and therefore a 
substantial risk of a rise in fatalities. It is maybe necessary to mention 
that statistically the fatalities/million cars would go up for fatalities 
in normal cars in this case and go down in heavier cars. The data in the 
report to support this is not conclusive enough, even if there is good 
reason to suspect it. The biggest rise in SUV sales is in the period after 
1999, where data are not available.

My letter and opinion about SUVs only touches the weight issue as a 
possible secondary parameter. I am talking about a car type that has a high 
gravity point and a design that makes it dangerous on the roads. The SUV is 
designed for off road environments and the on road considerations are 
therefore not optimized for safety.

You are claiming that the roll over effects are included in table 2-2 and I 
will give you the benefit of the doubt and assume that you did not look at 
table 2-3, which explicitly deals with the total numbers from roll over. I 
recommend that you go back and look at it. It shows that between 1993 and 
1999 the normal cars had a decrease of 5% in fatalities caused by roll over 
and an increase of 40% in the category that SUV belong to. This despite the 
fact that the most successful yearly sales of SUVs are in the years after 
1999.

The table 2-3 is also very interesting on the weight issue, with the 19% 
decrease in fatalities in collisions car to car and 20% increase in 
collisions car to light truck (SUV group). It is also a remarkable 60% 
increase in fatalities from truck to truck collisions, which seems to 
mirror the changes in fleet composition and the additions of SUVs. These 
numbers are a very strong support for my opinion and make it even more 
difficult to understand where your opinion on the weight issue comes from. 
In light of this, I suggest that you might have a reason to reevaluate and 
adjust your opinion and message.

I am sorry, but I do not see anything in the material that you pointed me 
to, that would cause me to change my opinion in my original letter. The 
report and the data, even if it is only goes to 1999, support my original 
opinion.

Hakan Falk


At 05:23 PM 1/10/2003 -0500, you wrote:
>I'm unfamiliar with the tax credit issue, but I can answer your safety 
>point.  In terms of the occupant death rate per registered vehicle, SUVs 
>and passenger cars overall are practically identical. This is clear from 
>table 2-2 of the National Academy of Sciences 2001 CAFE report.  Any 
>roll-over risk, of course, is represented in these statisticis, in 
>proportion to its frequency.
>
>  As that table shows, the smallest, worst-performing SUVs are still 
> better than minicars, while the largest SUVs do better than any class of 
> passenger car.  You can link to the report 
> at  http://books.nap.edu/books/0309076013/html/3.html#pagetop.
>
>Once you figure out the implications of that table for your moralistic 
>ranting about SUVs hazards, perhaps you'll send it to the recipients of 
>your smug Open Letter.
>
>
>Sam Kazman
>General Counsel
>Competitive Enterprise Institute
>1001 Conn. Ave. NW, Suite 1250
>Washington DC 20036
>www.cei.org <http://www.cei.org>
>Tel: 202-331-2265
>Fax: 202-331-0640
>
>
>-----Original Message-----
>From: Hakan Falk [mailto:[EMAIL PROTECTED]
>Sent: Thursday, January 09, 2003 5:57 PM
>To: Sam Kazman
>Cc: [EMAIL PROTECTED]; Info; [EMAIL PROTECTED];
>biofuel@yahoogroups.com; biofuels-biz@yahoogroups.com;
>[EMAIL PROTECTED]; [EMAIL PROTECTED];
>[EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]
>Subject: Open letter to Mr. Sam Kazman about SUV interview at CNN.
>
>
>
>Please help to distribute this letter to your friends and foes.
>Link to this letter: http://energy.saving.nu/biofuels/kazman.shtml
>
>
>Open letter to Mr. Sam Kazman about SUV interview at CNN.
>Competitive Enterprise Institute, CEI
>
>
>I saw you on CNN Insight and it was a real show performance, but
>unfortunately very thin on factual information. I am from Sweden, a country
>well recognized for its successful security policies to combat fatalities
>in road accidents. I was very disturbed by your opinions in the CNN
>interview. Further research on you and your organization by looking at
>Internet information, did not make me less disturbed. I only discovered
>ignorance and an unbelievable political use of the natural laws that
>supposed to fit the arguments.
>
>http://www.cei.org/ (your organization)
>http://www.cei.org/dyn/view_bio.cfm/45 (you)
>http://www.prwatch.org/improp/cei.html (what a reasonable watch dog
>organization says about you)
>http://energy.saving.nu/biofuels/oildependencies.shtml (what we say about
>oil dependencies)
>
>It is only a few questions that I like to get covered about SUV and your
>position. Since you pose in such a convincing way as expert, you should be
>able to answer at least a few of them, if not all.
>
>The U.S. government has a $35,000 tax rebate on SUVs, which to me looks
>completely insane and contradictory to any oil independence policy.
>
>- How can U.S. government justify such a tax rebate, with the talk about
>lessening the oil dependency?
>
>- How can you claim that SUV is the American people's choice, knowing that
>it is a tax rebate that in some cases cover around 75% of the price of a
>SUV that makes them so attractive to purchase? Wouldn't that make SUVs the
>American government's choice?
>
>- Suppose somebody, like me for example, would claim that this looks like a
>hidden subsidy to the American car industry and as such is against WTO
>rules. This based on availability and possible planning advantages in favor
>of the US domestic industry. What would be your answer?
>
>- US Automotive industry is quite honest about the typical buyers of SUV
>today. Considering this it can hardly be argued that the tax rebate for SUV
>can fall in any category of professional special utility vehicle. How would
>you argue it?
>
>- If I say that the tax rebate looks more like a corruption issue, what
>would be your answer based on facts?
>
>In the military I had extensive training in driving off road vehicles in
>both on and off road environment. I also heard that the procedures and
>demands are the same in the US military. To sign out an off road vehicle
>you have to do the following,
>
>1. Show that you have gone through a special training in driving and
>loading the vehicle type and of course passed the tests.
>
>2. Make a technical inspection of the vehicle and especially tires.
>
>Many off road vehicles like the SUV have very special characteristics that
>make them behave differentially than a normal car. The high center of
>gravity can make them quite dangerous, especially on road in higher speeds.
>In Europe we have a driving license that is divided in 3 classes for
>motorbikes and 10 classes for automobiles, trucks and buses. To have a
>complete license, as I have, you have go trough 5 different exams. A
>license for a normal automobile is valid for car and trailer up to a
>nominal weight of 3,500 kg (including maximum load figures).
>
>The published figures for SUV accidents in the US now start to show some
>specifics that are alarming.
>
>- Roll over fatal accidents for SUVs are several times higher than for
>normal automobiles. Given these statistics and the experiences and demands
>from the military, don't you think that a special training and license are
>necessary for the public also?
>
>- Because of lesser safety demands in the construction (collision zones) of
>SUVs, their weight that in many cases are 4,000 kg (8,800 lbs) or higher
>and their height, the accidents involving SUVs show higher fatality rates
>for third party in collisions. This especially true for front to side
>collisions. Don't you think that it should be stricter safety concerns for
>SUV than for normal automobiles instead of the opposite?
>
>- The government through the military is very aware of all the special
>risks with this type of vehicles. Don't you think that the government
>directly is responsible if they neglect to take precautionary actions or at
>least demand the same rules for military and civil use?
>
>I also have some additional questions. In the CNN interview you claimed
>that the SUVs were necessary because their space and load capacity, also
>that the US public did not have any choices since automobiles was smaller
>than before.
>
>- Given the special characteristics of an SUV, specifically that it is more
>sensitive to how you load it and how much you load it; are you aware that
>with safety concerns, the SUV might have lower safe load capacity than the
>normal car?
>
>- US have a very broad range of mini vans and mini buses. They are safer
>and have higher load capacity than SUVs. Since you are living in US and
>know this, how could you claim that it was no alternative to SUVs?
>
>Finally a more personal issue that I am curious about, concerning your
>support of SUVs. Considering the disastrous fuel economy, the questionable
>tax rebates and foremost the now statistically proven higher fatality rates
>for accidents involving SUVs.
>
>Do you sleep well during the night? Your attitudes and arguments had and
>will have direct impact on life or death for much more people than 9/11.
>Are you sure that you represent views that save lives or do you contribute
>in ending more lives? Quite an awesome responsibility, especially when
>accident statistics now start to mirror the truth. If you are wrong and
>statistically it looks like it, did you only do your job and "followed
>instructions" or were you in charge of it?
>
>Hakan Falk
>http://energysavingnow.com/
>
>Please help to distribute this letter to your friends and foes.
>Link to this letter: http://energy.saving.nu/biofuels/kazman.shtml
>
>**********************************************
>If you want to take a look on a project
>that is very close to my heart, go to:
>http://energysavingnow.com/
>http://hakan.vitools.net/ My .Net Card
>http://hakan.vitools.org/ About me
>http://vitools.com/ My webmaster site
>**********************************************
>"A truth's initial commotion is directly proportional to
>how deeply the lie was believed. It wasn't the world
>being round that agitated people, but that the world
>wasn't flat. When a well-packaged web of lies has
>been sold to the masses over generations, the truth
>will seem utterly preposterous and its speaker a raving
>lunatic."  -- Dresden James
>
>"No flag is large enough to cover the shame of
>killing innocent people" -- Howard Zinn
>
>"Nobody grows old merely by living a number of years.
>We grow old by deserting our ideals. Years may
>wrinkle the skin, but to give up enthusiasm
>wrinkles the soul." - Unknown



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