It usually takes a bit for comments to post, so here are images of the comment I submitted
![Dear Administrator Morrison,
The League of American Bicyclists (Leagues) appreciates the opportunity to comment
on proposed changes to the New Car Assessment Program (NCAP), including an update
to NCAP’s 10-year roadmap in Docket No. NHTSA-2026-1651. [1] The League is a
national non-profit organization dedicated to building a Bicycle Friendly America for
everyone.
When announcing the NCAP’s first-ever pedestrian safety test results, the
announcement said “NHTSA’s 5-Star Safety Ratings program is the gold standard.” [2]
The League supports NHTSA’s NCAP 5-Star Safety Ratings being the gold standard, but
given current tests and the proposed delays found in the NCAP 10-year roadmap, we do
not believe that it is the gold standard at this time. The League urges NHTSA to
reconsider the timelines laid out in its 10-year roadmap and to invest more in the NCAP
5-Star Safety Ratings so that they once again set the gold standard for the world.
The American people deserve Safer Vehicles and the U.S. Department of
Transportation’s National Roadway Safety Strategy (NRSS) makes Safer Vehicles one of
its “three core objectives.” [3] Unfortunately, the NRSS makes only one mention of
NCAP and the proposed 10-year roadmap proposes a delay to the implementation of
advanced crash test dummies mentioned in the NRSS. In fact, the proposed 10-year
roadmap includes 32 years of delay across 22 tests. [4] This is not consistent with a gold
standard or delivering the Golden Age of Transportation through Safer Vehicles.
The primary justifications for delays contained within NHTSA’s proposed 10-year
roadmap are “resource constraints” and the complexity of research. [5] These can be
valid justifications. A gold standard should be well resourced and well researched.](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:g2z32fff3xf4k342zkotinxy/bafkreicquuuwqa5rksrqyaj7k6yrrynsfrhiyccqqm7ile56p7hsepltte)
![However, NHTSA’s Fiscal Year (FY) 2027 Budget Estimate makes no mention of NCAP
and does not request additional resources for the testing of new vehicles, administration
of the program, communication of results, or development of new testing protocols. [6]
Before FY 2027, NCAP was included in every previous NHTSA Budget Estimate since at
least FY 2010, with its requested budget peaking at $35 million in FY2017 and ebbing at
$6 million in FY 2026, which was $9 million lower than the inflation-adjusted FY 2010
budget request. [7]
With no budget request for NCAP in FY 2027 and the long-term decline in budget
requests for NCAP, the “resource constraints” appear self-imposed and not befitting of a
gold standard program. The League urges NHTSA to request appropriate resources so
that the agency’s gold standard NCAP is no longer delayed due to resource constraints
and the 23 new tests or protocols included in the 10-year NCAP roadmap can be
accomplished in a timely manner.
The League has experience with the long and slow update process of NCAP. Since 2015,
the League has requested that bicyclist-Automatic Emergency Braking (AEB) should be
incorporated into NCAP. [8] The proposed 10-year roadmap includes bicyclist-AEB, but
proposes a delay of three years for implementation until 2030 even as it reflects that the
research phase has been completed. [9] No explanation is provided specifically for this
delay.
Bicyclist deaths in the United States have increased dramatically since 2015, from 829
to 1,148 in 2025 according to NHTSA estimates. [10] Even as drivers and occupants
have seen their traffic deaths decrease in recent years, bicyclist deaths have continued
their upward trend, increasing by 3% in 2025. White men between the ages of 55 and 64
are the largest demographic of people killed while riding bikes in America over the last
decade. [11] To delay the implementation of bicyclist-AEB while bicyclist deaths increase
is not consistent with a gold s…](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:g2z32fff3xf4k342zkotinxy/bafkreihtp3fxlkijqwr6hra3vhtqskfbnwdyusd2ciezh4sici5c5vwc6u)
![2017, more than a decade before NHTSA now proposes implementing its own
bicyclist-AEB tests. [13] In previous comment periods related to NCAP, automakers like
Tesla, Hyundai-KIA, GM, Honda, and BMW have supported the inclusion of
bicyclist-AEB tests, with BMW stating that bicyclist-AEB has been a standard feature in
its vehicles after 2017. [14] To delay implementation of a mature technology like
bicyclist-AEB is not consistent with a gold standard approach.
In the NRSS, Secretary Duffy said, “The Golden Age of Transportation means that
parents make it home from work, kids arrive at school safely, freight moves around the
country without jeopardizing lives, and critical workers who build and maintain our
infrastructure can go about their days without fear of injury or death.” [15] Today, over
1,000 bicyclists each year - parents, kids, delivery workers, and workers who plan, build,
and maintain infrastructure - do not make it home from their trips on bikes.
Bicyclist-AEB is a mature technology commonly included in NCAPs of peer and
competitor markets and it should not be further delayed as proposed in the 10-year
roadmap update.
Bicyclist-AEB is just one example of how NCAP currently fails to provide a gold
standard for Safer Vehicles. NHTSA should request an increased budget for NCAP to
reduce delays related to resource constraints and aim for at least parity with peer and
competitor NCAPs in other markets. The American people deserve the gold standard
and it will take more action than the delays proposed for NCAP to deliver it.
Sincerely,
Ken McLeod
Policy Director
ken@bikeleague.org](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:g2z32fff3xf4k342zkotinxy/bafkreid4boh4nczgaa276j2dplgzbdpmuw5bl7if4luozhpkmuhholsaw4)
![Endnotes:
[1] https://www.regulations.gov/document/NHTSA-2026-1651-0001
[2] https://www.nhtsa.gov/press-releases/first-ever-pedestrian-safety-test-results
[3]
https://www.transportation.gov/sites/dot.gov/files/2026-08/USDOT-National-Roadway-Safety-Strategy-2026.pdf at page 1
[4] See https://www.datawrapper.de/_/sTruh/?v=2 comparing data from
https://www.regulations.gov/document/NHTSA-2026-1651-0001 in Tables 1 and 2 compared to Figures
18 and 19 in
https://www.nhtsa.gov/sites/nhtsa.gov/files/2024-11/NCAP-Final-Decision-Notice-Advanced-Driver-As
sistance-Systems-Roadmap-11182024-web.pdf
[5] See https://www.govinfo.gov/content/pkg/FR-2026-08-17/pdf/2026-16735.pdf printed pages 53344
and 53345
[6] https://www.transportation.gov/sites/dot.gov/files/NHTSA_FY_2027_Budget_Estimates_CJ.pdf
[7] See https://www.datawrapper.de/_/zt5vS/?v=6 comparing data from NHTSA Fiscal Year Budget
Estimates over time
[8] See Docket NHTSA-2015-0119 where nearly two-thirds of comments were from the League and
supporters: https://www.regulations.gov/docket/NHTSA-2015-0119/
[9] See https://www.govinfo.gov/content/pkg/FR-2026-08-17/pdf/2026-16735.pdf printed page 53345,
Table 1
[10] https://crashstats.nhtsa.dot.gov/Api/Public/ViewPublication/813768
[11] Based upon query of NHTSA data retrieved from https://cdan.dot.gov/query for the period
2015-2024
[12] https://www.safetywissen.com/requirement/
[13] See 2017 protocol available at
https://cdn.euroncap.com/cars/assets/euro_ncap_aeb_vru_test_protocol_v202_5323bb181e.pdf
[14] See automaker comments on https://www.regulations.gov/docket/NHTSA-2021-0002, BMW
comment is on page 12 of their comment:
https://www.regulations.gov/comment/NHTSA-2021-0002-3050
[15]
https://www.transportation.gov/sites/dot.gov/files/2026-08/USDOT-National-Roadway-Safety-Strategy-2026.pdf at page 1](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:g2z32fff3xf4k342zkotinxy/bafkreigwfgs3sqfuqyhhzbbjso5t3kzir2alyh7n6ujofd22cgpyeujpay)
Ken McLeod
@kenmcld.bsky.social
1.7K followers 1.4K following 3.8K posts
Bicyclist and policy wonk hoping to make the US more safe for people when they need to go places. Policy Director @bikeleague.org
