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The Delivery

of a

Vision Zero

Petition

2016

In Memory of

AnnaLeah and Mary Karth

VISION ZERO

ZERO CRASH DEATHS AND SERIOUS INJURIES

VISION ZERO

ZERO CRASH DEATHS AND SERIOUS INJURIES

VISION ZERO

ZERO CRASH DEATHS AND SERIOUS INJURIES

The Delivery

of a

Vision Zero

Petition

March 2016

AnnaLeah & Mary for Truck Safety

Published by AnnaLeah & Mary For Truck Safety

Interior design, layout, and production: Isaac Karth

First Edition

annaleahmary.com

10 9 8 7 6 5 4 3 2 1

This book is

lovingly compiled

in memory of

AnnaLeah Karth

(forever 17)

and

Mary Lydia Karth

(forever 13)

Precious ones,

your lives were cut

far too short.

Contents

Contents

vii

Introduction

ix

I

Vision Zero

1

1 What is Vision Zero?

3

2 Why Are We Advocating For Vision Zero?

5

3 Traffic Injuries & Fatalities Data

9

4 Truck Underride: A Practical Application of a Vision Zero Goal 11

II

Petition

15

5 Petition Letter to Secretary Foxx

17

6 About the Signers

19

7 Selected Comments by Signers of the Vision Zero Petition

21

8 Signatures to the Petition

25

9 Comments by Signers of the Petition

483

vii

viii

CONTENTS

III Executive Order

493

10 Why do we need a Vision Zero Executive Order?

495

11 What is Needed to Bring About a National Vision Zero Goal? 501

11.1 Action One: Set a National Vision Zero Goal . . . . . . 502

11.2 Action Two: Establish a White House Vision Zero Task

Force To Achieve Significant Crash Death Reduction . . 503

11.3 Action Three: Sign a Vision Zero Executive Order To Au-

thorize Vision Zero Rulemaking Policies . . . . . . . . . 507

12 Petition Letter to President Obama

513

13 Letter of Support for the AnnaLeah & Mary for Truck Safety

Vision Zero Executive Order Petition

515

14 Selected Comments From Current Executive Order Petition

Signers

519

A Vision Zero Posts from AnnaLeahMary.com

523

A.1 Chronologically archived: . . . . . . . . . . . . . . . . . . 523

A.2 Alphabetical listing of Vision Zero posts: . . . . . . . . . 529

Introduction

In the aftermath of losing our two youngest daughters, AnnaLeah (17)

and Mary (13), due to a truck underride crash on May 4, 2013, we became

aware of far too many facts about traffic fatalities.

Along the way, we discovered that a global movement is underway-called

Vision Zero. This term was coined in Sweden and has as its basis a couple

of “ethical rules”

• “Life and health can never be exchanged for other benefits within

the society”

• “Whenever someone is killed or seriously injured, necessary steps

must be taken to avoid a similar event”

Every life is worth saving; there is no person who will not be missed by

someone:

In an effort to do more than just put a bandaid on the problem, we

launched a campaign to call for major change in how safety laws and

regulations are determined. This book is a compilation of our request for

a National Vision Zero Goal and for a Vision Zero rulemaking policy.

It includes our petition letters to President Obama and DOT Secretary

Foxx—along with the signatures and comments of thousands of people

who signed the petitions and are speaking up with us to call for a move

Towards Zero Crash Deaths & Serious Injuries.

http://www.monash.edu/miri/research/reports/papers/visionzero

https://www.youtube.com/watch?v=bsyvrkEjoXI

Part I

Vision Zero

What is Vision Zero?

Vision Zero, in the simplest language, is the embracing of a vision or hope

that we could work toward reducing crash deaths (and serious injuries)

to zero. That no one would ever die in a traffic crash. It is, of course,

understood that—life being what it is—we will never actually reach zero.

But Vision Zero insists that certainly such a goal is desirable and, in fact,

so much so that everything humanly possible should be done to accom-

plish it. One life at a time. To do anything less would be unthinkable.

What would a Vision Zero philosophy/goal/policy mean to us as a coun-

try? Here is how Neil Arason, Canadian author of No Accident, views

Vision Zero:

“I think people have different views about vision zero but here

is mine. The airline industry does not apply cost benefit anal-

ysis to fixing aviation problems. They just fix problems and

that is that. Using a cost benefit model is incompatible with

vision zero because it applies trade-offs and vision zero does

not entail that. Vision zero is about making the system a safe

one and does not assign value to a human life because doing

that, the thinking goes, is unethical.”

This book is a compilation of our request for a National Vision Zero Goal

and for a Vision Zero rulemaking policy. It includes our petition letters

to President Obama and DOT Secretary Foxx—along with the signatures

and comments of thousands of people who signed the petitions and are

speaking up with us to call for a move Towards Zero Crash Deaths &

Serious Injuries.

http://annaleahmary.com/2015/12/starting-tzd-traffic-safety-

conversation-who-should-pay-for-the-cost-of-saved-lives/

4

CHAPTER 1. WHAT IS VISION ZERO?

The book also includes an appendix full of annaleahmary.com

posts writ-

ten on how and why Vision Zero should be applied. For example, one

of the posts describes why we are pushing so hard to get people to sign a

Vision Zero petition. What difference would it make anyway? The reason

we are devoting our lives to pounding on this door and asking for change

is that our daughters may have lost their lives due to the lack of a Vision

Zero policy.

A decision which concluded that recommended changes would not be

cost effective—in other words, that it would supposedly cost more to im-

plement safety measures than the lives saved would be worth—may have

led to lax underride guard standards. If the best possible protection had

been pursued when the regulations were last updated (1996), the trucks

on the road today (including the one on the road May 4, 2013) might be

much safer to be driving around.

Mary and AnnaLeah might even still be around.

Furthermore, the issue of underride guards is just one among many prob-

lems which, if a National Vision Zero Goal were in place, could be ad-

dressed more compassionately—as if human lives were really more impor-

tant to us than our pocketbook.

There is also a drafted Vision Zero Executive Order as a recommendation

for outlining a means of implementing a National Vision Zero Goal and

granting DOT the authority to adopt a Vision Zero rulemaking policy.

Finally, there is a draft for a presidential memorandum mandating a task

force to address these issues in a collaborative effort at a national level in

order to establish national traffic safety standards which should be adopted

by all states.

http://annaleahmary.com

Why Are We Advocating For

Vision Zero?

32,675 people died in U.S. traffic crashes in 2013.

Two of those peo-

ple were my daughters, AnnaLeah (17) and Mary (13). That number

decreased to 32,675 deaths in 2014. Down by 44, but still far too many

deaths in my book. In fact, early estimates show an increase in traffic

fatalities in 2015.

I survived a horrific truck crash in which our car was pushed by a truck

into the rear of another truck. Backwards. My daughters in the back seat

were not so fortunate; they went under the truck and the truck broke their

innocent bodies.

Underride deaths are preventable and unnecessary and now is the time to

take extreme action to reduce these deaths—no matter who caused the

crash! Let’s not wait for collision avoidance technology to kick in before

kicking out preventable underride deaths!

The underride problem is just one example of the fixable problems we need

to address. Michael Lemov has written an eye-opener, Car Safety Wars:

One Hundred Years of Technology, Politics, and Death, in which he tells us

that in the more than 110 years since the first traffic crash in 1898, more

than 3.5 million Americans have been killed and more than 300,000,000

injured in motor vehicle crashes [p.9]. This, I learned, is 3x the number

of Americans who have been killed and 200x the number wounded in all

of the wars fought by our nation since the Revolution [p.10]. Imagine.

http://www.nhtsa.gov/About+NHTSA/Press+Releases/2014/traffic-

deaths-decline-in-2013

http://www.nhtsa.gov/About+NHTSA/Press+Releases/2015/2014-

traffic-deaths-drop-but-2015-trending-higher

6 CHAPTER 2. WHY ARE WE ADVOCATING FOR VISION ZERO?

Are you aware that Death by Motor Vehicle is one of the leading causes

of deaths?

“Worldwide it was estimated that 1.2 million people were

killed and 50 million more were injured in motor vehicle

collisions in 2004.[2] Also in 2010 alone, around 1.23 million

people were killed due to traffic collisions.[3] This makes

motor vehicle collisions the leading cause of death among

children 10–19 years of age (260,000 children die a year, 10

million are injured)[4] and the sixth leading preventable cause

of death in the United States[5] (45,800 people died and 2.4

million were injured in 2005).[6] It is estimated that motor

vehicle collisions caused the deaths of around 60 million

people during the 20th century,[7] around the same as the

number of World War II casualties.”

Lemov’s book sheds light on many things including the fact that, although

the blame was often put on the driver for crashes in the 20th century,

in fact crashes and crash deaths are additionally caused by other factors

including environmental and vehicle factors. He uses a term which I had

never heard before—post-crash injury or “second collision.” He describes

it this way:

“It is the collision of the occupants of a vehicle with its interior,

or the road, after the initial impact of a car crash. Ultimately

the creativity of a few scientists, doctors, and investigators. . .

developed an understanding of what actually happens to a hu-

man body in a car crash. . . Researchers gradually developed

ideas they hoped would prevent this second collision.” [p.16]

We can thank these researchers for paving the way for improved vehicle

safety, including things like seat belts, air bags, and even car seats that lock

in position. But, for far too long, it has been a major battle—as Lemov

says, a car safety war—to bring about changes which will save lives.

Our own crash demonstrated the many factors which can contribute to the

occurrence of crashes as well as to the deaths and horrific injuries which

too often occur as a result. We learned the hard way that many of these

are preventable and that Our Crash Was Not An Accident.

Following our truck crash, on May 4, 2013, we have learned more than we

ever wanted to about traffic safety issues. We took the AnnaLeah & Mary

https://en.wikipedia.org/wiki/Epidemiology_of_motor_vehicle_

collisions

Stand Up for Truck Safety—Save Lives and Prevent Injuries! Petition to

DC on May 5, 2014 and helped to initiate an update in the underride

protection for tractor-trailers.

Following that, we worked to promote underride research and have helped

to organize an international Underride Roundtable on Thursday, May 5,

2016, when researchers, government officials, and industry leaders will

gather to discuss truck underride crashes and how to reduce the risks for

passenger vehicle occupants, bicyclists, and pedestrians. We will explore

the scope of the problem and how regulation and voluntary action can

help address it. There will also be a demonstration of underride guard

performance in a crash test.

But, along the way, as I engaged in safety advocacy efforts—calling, email-

ing, and meeting with legislators—I quickly realized that all too-often it

was 2 steps forward 3 steps backward. I began to ask, “Why is it so diffi-

cult to get anything done to save lives?” and “Why isn’t the best possible

protection being adopted?”

I learned that one of the biggest obstacles was that public policy and

more specifically DOT rulemaking is impacted by a requirement for

cost/benefit analysis which tips the scale in the favor of industry lobby

and the almighty dollar and makes a mockery out of the word safety.

Human life becomes devalued in the process when a safety measure is

rejected because it “may not have significant safety consequence.”

This is illustrated in the history of Federal rulemaking on truck underride

guards outlined by the Insurance Institute for Highway Safety, where it

was indicated that in “1974: US Secretary of Transportation says deaths

in cars that underride trucks would have to quadruple before underride

protection would be considered cost beneficial.”

I determined to battle such an inconceivable, incomprehensible, and un-

conscionable attitude and determined to find a better way to protect trav-

elers on the road. After talking with numerous engineers who either were

convinced that safer underride guards could be made or had already de-

signed ones, I also discovered a global movement that calls for the re-

duction of crash deaths and serious injuries: Vision Zero—An ethical

approach to safety and mobility.

After launching an online petition Save Lives Not Dollars: Urge DOT

to Adopt a Vision Zero Policy on September 29, 2015, I discovered that

http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-

1548

http://www.iihs.org/media/faa5dfa3-e46b-4f10-a542-228bb8844f17/-

2034281871/Testimony/testimony_2009-05-18.pdf

8 CHAPTER 2. WHY ARE WE ADVOCATING FOR VISION ZERO?

an Executive Order had been signed by Clinton which had set in place

the cost/benefit analysis rulemaking policy which all-too-often delays or

blocks traffic safety regulations. I immediately set out to petition President

Obama to set a National Vision Zero Goal with the establishment of a

White House Task Force to Achieve a Vision Zero Goal of Crash Death

Reduction. Furthermore, I believe that it is necessary to cancel out the

negative impact of Executive Order 12866 in order to end this senseless

war over safety. That is why I am asking President Obama to sign a new

Vision Zero Executive Order.

Why are we devoting our lives to pushing for a DOT Vision Zero pol-

icy? Because I truly believe that it can have an impact not just on truck

safety but on all issues related to highway and auto safety—including auto

safety defects, driver training requirements, all kinds of impaired driving

(including distracted driving, drunk driving, and driving while fatigued),

and proven national traffic safety standards which should be adopted by

all states.

We are taking these petitions (over 16,000 signatures to date) to Wash-

ington, DC, on March 4, where we will be meeting with DOT policy

officials to discuss the need for this radical change in how our nation pro-

tects the travelers on our roads. Help us persuade President Obama to set

a National Vision Zero Goal & to sign a Vision Zero Executive Order

which will allow DOT to adopt a Vision Zero rulemaking policy.

It is time to stop acting like the value of a human life can be measured

with and compared to corporate dollars. Every delay costs someone their

life.

Let’s get it right, America. Somebody’s life depends on it. Lots of some-

bodies.

Traffic Injuries & Fatalities Data

Figure 3.1: In 2004-2014, the leading cause of death in the United States

for ages 1-45 was Unintentional Injury Motor Vehicle Traffic

10

CHAPTER 3. TRAFFIC INJURIES & FATALITIES DATA

Figure 3.2: Motor Vehicle Traffic continues to be a leading cause of death

in the Unintentional Injury category for all ages.

Truck Underride: A Practical

Application of a Vision Zero Goal

An Essay by Marianne Karth

It is a common business practice to develop a Vision Statement which

exemplifies the goals of the organization and which will direct its decisions,

practices, and activities.

Let me give an example of this. Our family helped to develop a Vision

Statement for Family Promise of Midland, Texas: End Homelessness, One

Family at a Time. Will there ever be zero homeless families? Probably

not. But that vision is what we aimed for; it guided our steps.

What can a vision statement do? It can, “encourage strategic thinking

and help organizations share concise information about their plans and

progress toward impact.”

1 2

Similarly, Vision Zero: Reduce Crash Deaths & Serious Injuries is a vision

statement that serves to move us ever closer to ending preventable, sense-

less and tragic crash deaths & serious injuries—one life saved at a time.

That vision guides our steps to discover and implement proven means to

save lives—to make saving human life a priority over saving money.

Specifically, we have chosen to advocate for resolution of a problem which

has too-long been ignored: truck underride crashes. It is well-known that

the current underride guard standards are inadequate; they result in guards

that are weak and ineffective and all-too often lead to tragic deaths and

horrific injuries. The really bad thing about this is that many people have

https://www.guidestar.org/report/chartingimpact/650820583/family-

promise-midland-texas.pdf

http://www.midlandvolunteerconnections.org/agency/detail//?

agency_id=42248

12

CHAPTER 4. TRUCK UNDERRIDE

already taken the time to prove that this situation is unnecessary and that

better protection is possible.

Therefore this is what I am asking for as a Vision Zero strategic applica-

tion:

We have spent a lot of time reflecting on the inadequacy of current rear-

impact guards to prevent underride by passenger vehicles along with the

concomitant difficulty of holding trailer manufacturers accountable for the

horrific injuries and deaths which all-too-often occur as a result.

The current means of regulating the manufacture of underride guards re-

quires the trailer manufacturer to design its underride guards to meet cer-

tain specifications. Once the manufacturer has met those requirements,

then, currently, it cannot normally be held liable for any failure of the

guard to withstand a crash–along with any resultant property damages,

injuries, or death.

We would like to propose a change in the approach to regulating truck un-

derride guards. We are requesting/recommending that the manufacturer

be required to design and crash test a guard which would withstand a crash

at any speed up to 50 mph and at any point along the back of the trailer.

Furthermore, we are requesting that, when a real-life underride crash does

occur with one of their trucks, the manufacturer be held financially re-

sponsible for the cost of a thorough crash reconstruction, which would

identify—at minimum—the speed which was traveled and whether the

guard gave way with the impact of the crash.

With this new approach to regulating underride guards, the manufacturer

would thereby be accountable for any failure of the guard to withstand

a crash and thus be held responsible for ensuring a very important pub-

lic outcome: prevention of horrific injuries and deaths due to underride

crashes.

This is in sharp contrast to the current situation where no penalty is nor-

mally paid for a failed underride guard–except by the victims and their

loved ones.

p.s. This link provides a perspective on prevention of crash fatalities as a

public health outcome (although it does not mention truck safety issues in

particular): World Health Organization: Road Traffic Injuries

and see,

also: NHTSA: The Crash Outcome Data Evaluation System (CODES)

And Applications to Improve Traffic Safety Decision-Making

3

http://www.who.int/mediacentre/factsheets/fs358/en/

http://www-nrd.nhtsa.dot.gov/Pubs/811181.pdf

p.p.s. We do not pretend to be experts on details such as whether 50 mph

is the most appropriate speed limit to require. We do know, however, that

requiring manufacturers to prevent crashes only at lower speeds inevitably

means that many lives will be unnecessarily lost–placing a low value on

human life. Corporate gain over tragic, preventable, and irrevocable loss

of life.

p.p.p.s. Additionally, we have been told that this level of protection is

highly possible and we are taking steps to encourage further research on

this in the near future.

p.p.p.p.s. Oh, and did I ask for a requirement to install not only rear un-

derride guards but to likewise protect people from side and front underride

collisions on all new trucks, as well as retrofitting existing trucks?

The stated mission of the National Highway Traffic Safety Administration

(NHTSA) is “to save lives, prevent injuries, and reduce economic costs

due to road traffic crashes, through education, research, safety standards,

and enforcement activity.”

To be in accord with that mission, NHTSA

should act now to make a comprehensive underride regulation in a timely

and decisive manner. Why wait?

To not provide the best possible protection, and thereby sentence countless

people to Preventable Death by Motor Vehicle, is ethically and morally

unconscionable and unthinkable.

Marianne Karth,

The Survivor of a truck crash

which resulted in rear underride

and Passenger Compartment Intrusion (PCI)

into the back seat of her Crown Victoria

where AnnaLeah (17) and Mary (13) met their untimely end

http://annaleahmary.com/

http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-

0070-0018

February 5, 2016

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