The State Highway Department Draft of the New Mexico Highway Safety & Performance Plan Revision for 2002 was shared with the DWI Resource Center on August 14, pursuant to the Department's required compliance with a lawsuit settlement agreement. Analysis reveals some disturbing decisions by the Johnson Administration regarding their traffic safety plans.

Under US Department of Transportation Rules the Plan must state New Mexico's traffic safety goals, which must be representative of a broad consensus on goals. In New Mexico's Plan, the Department re-expressed its traffic safety goals (page 25) for traffic deaths and alcohol-related crash deaths in terms of deaths per 100 million vehicle miles. On page 24 it state that the goals represent the "goals established in laws.according to performance-based budgeting processes." House Bill 2 establishes in law goals for total traffic fatalities and alcohol-related traffic fatalities, and those do not seem to be presented in the Plan, nor their omission noted. It would be far better to state goals as fatality counts, as those are the measures most meaningful to the public. It would harm little to also state them as rates per capita or rates per mile travelled, but not without the counts that share with the public the meaning of the goals.

There is a conceptual problem with this exclusive use of vehicle mile rates. Suppose traffic volumes increase enormously and so deaths do as well. The use of rates as performance measures imply that the Department wishes its safety programs to be judged successful even if death counts rise dramatically, as long as traffic goes up as well. From a public health standpoint, it is the death of the person that matters, not how many miles he or she drove reaching it. In terms of emergency medical services load, years of life lost, brain and spinal injury effects, and every other quality of life aspect of traffic safety, it is the injury that counts as bottom line effect of traffic safety failures, not the vehicle, not the mile. Rates per mile travelled are useful for comparing road and vehicle performance and for little else, especially considering the poor data quality that characterizes traffic volume statistics.

Since the Plan apparently provides only rates per mile travelled, we have attempted to translate its goals to a scale meaningful for determining whether they reflect at all the input the agency received from the 300 Lives Campaign supporters. To do so, we have had to project vehicle mile counts from the agency figures. This is challenging in a number of ways. First, the Department has declined to share with us updated vehicle mile data, on the stated basis that the data for 2000 has inconsistencies that must be resolved before release. While we certainly do not favor releasing data it cannot stand behind, we are taken aback to find it nonetheless basing its Plan on that data. Second, the Department does not seem to have released, in the Plan or elsewhere, projected vehicle mile figures for 2001-2005, making it hard to interpret what its goals mean in terms of related measures of deaths and deaths per capita that are far more meaningful for public health promotion. Third, the flaws and instabilities in the agency's measurement systems for vehicle miles travelled produce discontinuities and artifacts that make it very hard to measure long-term trends in the rate measures it likes and therefore hard to judge performance. Fourth, the Plan figures for vehicle miles travelled do not agree for many years with figures released in databases it have provided us on this subject.

We do the best we can under the limitations its choices impose upon us. Table 1 below shows the Plan's vehicle mile figures, and results of extrapolating the data to 2001-2005 by assuming that the average growth rate for 1997-2000 will continue for 2001-2005. This rate is very low compared to historical levels of vehicle mile growth, so this is an extrapolation very generous to the Department's safety program in that higher volumes mean higher deaths, according to its approach.

Table 2 shows the Plan goals, with linear interpolation of intermediate values.

The table shows the Department's goal is actually to increase the death rate for non-alcohol-related crash deaths. Surely this is a mistake, as the rate goals in that category far exceed actual rates achieved in the state for 1992-1994. The Department should reconsider. The huge increases in recent years in non-alcohol-related crashes in New Mexico must make all push for progress in this category. This plan does not.

These values can be converted to death counts through simple multiplication, producing the values shown in Table 3.

The goals seem to call for increased crash deaths compared to current levels, and for increasing non-alcohol crash deaths nearly to their historic maximum. At the same time, the goals calls for less progress at reducing alcohol-related crash deaths than in any comparable recent period, though the Plan states the Department has three times more funding than ever before. The Department should set its sights higher.

Table 4 presents a comparison of results of the Department's goals to those of its own Highway Safety & Performance Plan 2001- 2005 (released in September 2000) and the Highway Safety & Performance Plan 2000-2005 released in October 1999. Also shown are the counterpart goals for the national Partners In Progress objectives and New Mexico's own 300 Lives Campaign that has broad public support in New Mexico.

Despite improved 2000 death counts compared to 1999, the newest Plan revisions call for more deaths than its own Plan called for last year. Its revisions last year, in turn called for more deaths than its Plan for the year before. It claims its goal-setting process was inclusive and responsive to input, yet we know of no input from any source that called for increasing future death targets.

Table 5 shows in the same format figures regarding alcohol-related crash death counts.

The new Plan calls for 53 more alcohol-related crash deaths from its 2001-2005 programs than its Plan of October 2001 called for, and 146 more deaths than the same Plan in October 1999. The Department received extensive public input calling for adopting the 300 Lives Campaign goals, which provided a workable approach without new funding for achieving here in New Mexico the ambitious national goals for 2005 of CDC, USDOT and MADD for crash death reductions. Instead of making its programs and goals more aggressive, it has responded by weakening them still further. We know of no public input that it received to call for increasing its death goals, so its decision to do so seems to fly in the face of the public involvement the Plan claims to heed and that federal regulations require.

The new Plan calls for 26 fewer non-alcohol crash deaths than the same Plan did in October 2000, but 108 more than the Plan did in October 1999. The Plan falls short of national Goals by 100 extra deaths, and the 2005 Goal is for a death count far higher than the current level. No public input supported this. The National Goal is very timid in this category, and the 300 Lives Goal based on the National Goals is therefore timid also. New Mexico can certainly do better than the 300 Lives goal, and should, as there is no room for timidity in a category that has produced record high death counts in recent years, killing 305 more people in 1995-2000 than in 1989-1994.

The goals in the Draft Plan are inconsistent with and weaker than national goals, inconsistent with public input, and far more timid than the Department's own Plans in prior years. They do not seem to reflect the increased level of effort and results that the Department's safety funding increases ought to produce. It should reconsider and revise them for the Final Plan. A reasonable restatement for 300 Lives goals in the Department's own terms of vehicle miles would be:

• Reduce alcohol-related NM crash deaths to under 0.58 deaths per 100mvm (or 147 deaths) in 2002 and under 0.47 deaths per 100 mvm (or 129 deaths) in 2005.
• Reduce total NM crash deaths to under 1.60 (or 404 deaths) in 2002 and under 1.34 mvm (or 354 deaths) in 2005.