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Mr. FLORIO. Mr. Lent.

Mr. LENT. Thank you very much, Mr. Chairman.

First of all, I want to thank Ms. Lightner for the contribution that she has made to the work of this committee and many other ways as well.

Ms. Lightner, I would like to ask you-perhaps this is a philosophical question. In your view, what is the most important feature of this bill, H.R. 3870, its uniformity or the age level that it sets? Let me give it to you another way. In other words, as long as the age was uniform, would setting it at 19 or setting it at 20 be equally as effective as 21 in your opinion in preventing alcohol-related deaths?

Ms. LIGHTNER. No, sir. It has to be at least-the drinking age has to be at least 21, based upon all of the studies and the statistics that we have looked at.

Mr. LENT. Well, do you think that, as some have said, that every time you go up another notch in the drinking age, the enforcement becomes more difficult? Is there anything to that?

Ms. LIGHTNER. Sir, out of every drunk driver that is caught, they say another 200 to 2,000 go without being caught or convicted, yet I still believe it is important to enforce the laws having to do with drunk drivers, as I believe it is important to enforce any laws that we have, including the laws raising the drinking age to 21.

Mr. LENT. The reason I asked you that is, we have an editorial from the newspaper, Newsday, of October 2, 1983, which is one of America's leading newspapers, and they are for this bill, but they make the point that, "Enforcement of the drinking age limit tends to become more difficult as the age goes up, so setting 21 as the national minimum could backfire, especially in States where the drinking age is now lower than that."

I just wonder, you do not agree with the contention that enforcement could backfire?

Ms. LIGHTNER. I would have to see the studies from States who have raised their drinking age to 21 and find out if that is a problem in those particular States, and in all the States that we have checked into, we have not heard that information.

Mr. LENT. Later this morning we will hear testimony by Michael Birkley, of the National Licensed Beverage Association, who will say that there is no consistently reliable basis for making the prediction that the Insurance Institute for Highway Safety made that, "Any State that raises the legal drinking age can expect a 28-percent reduction in fatal crashes among those affected by the law." More specifically, Mr. Birkley will testify that although the institute's prediction did come true in Michigan, it did not come true in Montana, Massachusetts, Iowa, Minnesota, Maine, or Florida, and according to Mr. Birkely's testimony, some of those States actually showed a rise in alcohol-related fatalities when the drinking age was raised.

Now, would you comment if you wish to on Mr. Birkley's allegations?

Ms. LIGHTNER. Well, No. 1, we are not basing our information on just one study, but on a multitude of studies, and No. 2, I think you have to look at where Mr. Birkley is coming from, and it is well known that their organization has opposed our organization in rais

ing the drinking age to 21 in the States that do not have it for whatever reason. So, I happen to look at him with a very biased and jaundiced view.

Mr. LENT. One final question. No. 1, we appreciate, certainly, your support of our bill, and let me ask you if you have any suggestions as to how H.R. 3870 could be strengthened or improved in any way to better effectuate the goal of reducing alcohol-related fatalities.

Ms. LIGHTNER. We have already worked with Congressman Florio on those changes, and those changes have already been made, so we are very pleased with the bill as it now stands.

Mr. LENT. We appreciate your support.

Mr. FLORIO. Would the gentleman yield?

Mr. LENT. I would be happy to yield.

Mr. FLORIO. I would just like to request unanimous consent to insert in the record a letter that is dated June 16, 1983, directed to Senator Packwood, the chairman of the comparable committee on the Senate side, that is from the Insurance Institute for Highway Safety that puts into question the scientific validity and methodology of the Insurance Institute document that Mr. Lent made reference to and undoubtedly will be made reference to by the National Licensed Beverage Association. I think it is something that is interesting, because there is some detailing of the methodological deficiencies of that report as evaluated by the Insurance Institute, and I think it should be made a part of the record, and without objection, so ordered.

[The material referred to follows:]

INSURANCE INSTITUTE FOR HIGHWAY SAFETY WATERGATE SIX HUNDRED. WASHINGTON, D.C. 20037

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On May 26, 1983, Matthew Protos, President of the National Licensed
Beverage Association, made a statement before the Committee on Commerce,
Science & Transportation concerning Title II of Senate Bill 1108, the
"Highway Safety Act of 1983." In his statement, Mr. Protos argued
against the proposal to raise the legal drinking age to 21 years in every
state, basing his opposition on a document published by the Blaney
Institute entitled "Death and the Legal Drinking Age: A Tri-State Study"
(copy attached). In this document, it is claimed that the reductions in
crash involvement occurring among young drivers in Michigan and Illinois
after the drinking age was raised in those states were not as great as
reductions in Wisconsin, where the drinking age was not raised. The
document concluded that the drinking age should not be raised.

The Blaney Institute document is scientifically inadequate. It presents
data on three measures of alcohol-related crash involvement for 18-20
year olds in Wisconsin for the years 1976-1981. Data from 1976-1980 were
used to predict expected values for these measures for 1981, and
comparisons of actual and expected values indicated that there were
reductions in alcohol-related crash involvement in 1981. The two
measures which showed the largest reductions were then compared with
reductions reported by other researchers for Michigan and Illinois (see
Table 3). These comparisons are invalid. As indicated by Table 3 in the
Blaney Institute document, the "comparisons" are based on different
measures of alcohol-related crash involvement, different years, and a
different age grouping in the case of Illinois. For example, the study
compares the change in involvement of 19-20-year-old male drivers in
nighttime single-vehicle crashes in Illinois in 1979 with the change in
number of fatally injured 18-20-year-old drivers with blood alcohol
concentrations greater than 0.05% in Wisconsin in 1981.

The insurance Institute for Highway Safety is an independent, nonprofit, scientific and educational organization. It is dedicated to reducing the losses deaths, injunes and property damage resulting from crashes on the nation's highways. The Institute is supported by the American Insurance Highway Safety Association, the Amencan Insurers Highway Safety Alliance, the National Association of Independent insurers

This is a classic example of comparing apples and oranges, and the dissimilarities make the comparisons meaningless. The credibility of the Blaney document is further eroded by the use of 1981 reduction data for Wisconsin (different years were cited for the other states); this overlooks the fact that in 1981 fatalities dropped in virtually all

states.

Many studies using scientifically valid research methods and procedures have found that raising the drinking age results in substantial reductions in crash involvement among those affected by the law change. I have enclosed a copy of a study which found that in nine states that raised their drinking age, there was on average a 28 percent reduction in nighttime fatal crash involvement among drivers to whom the law changes applied. The Blaney Institute document has no validity whatsoever and does not merit serious consideration.

Yours truly,

Allan F. Willin

Allan F. Williams, Ph.D.
Senior Behavioral Scientist

AFW: Sc

Enclosures

RESPONSE TO SENATOR ROBERT PACKWOOD ON THE INSURANCE INSTITUTE'S CRITICISM OF THE BLANEY INSTITUTE STUDY MADE BY WILLIAMS.

Response to Dr. Williams....

JUNE 18, 1983

Williams' first criticism is that we used only "the largest reductions" for comparison with Michigan and Illinois, implying that the smaller figure (reductions in Had-been-drinking crashes) was not used because it was smaller than the same data item for Michigan. As stated in our study "The data selected for comparison in Table 3 are those least likely to be distorted by influences other than real occurances." We did not compare the results of HBD analyses for the same reasons Wagenaar, and most responsible highway safety researchers place little reliance on HBD data; namely, they are subject to distortion due to a variety of influences on initial observers.

Williams' second criticism is that changes in three-factor-surrogate and fatal
crash data can not be compared; "a classic example of comparing apples and oranges".
This is essentially the same criticism illustrated by Dunham's murder vs. robbery
analogy. Both reflect a clear lack of knowledge of the significance and usefulness
of the three-factor-surrogate 3FS measurement. Developed by Wagenaar's prede-
cessors at the University of Michigan Highway Safety Research Institute in 1974,
3FS data are exactly what the name implies: scientifically valid substitutes for
real alcohol-related fatal and serious injury crashes. Research has shown that
changes in 3FS data values for the same population are statistically parallel with
changes in the data values obtained from analyses of real alcohol-related occurances.
(See: Douglass, R.L., L. D. Filkins, and F. A. Clark. The Effect of Lower Legal
Drinking Ages on Youth Crash Involvement. Ann Arbor: The University of Michigan,
Highway Safety Research Institute, 1974.)

A more appropriate analogy than "apples and oranges" would be: comparing changes
in the number of headlights installed, with changes in numbers of engines installed
in different auto production plants to determine differences in their total automobile
production.

Williams, like Dunham, misrepresents the years given in Table 3 to be the actual
study periods in the three states and criticizes comparisons of changes occuring
in different years. As stated in the column heading, the figures given are for
"Change Years". These were the only years during the period 1977-81, in which
there were statistically significant decreases in alcohol-related crash involvement
among younger drivers relative to non-alcohol crashes among the same driver
age group and no change in trends for crashes of any kind among older drivers
in the states studied.

Williams further states that our study "overlooks the fact that in 1981 fatalities dropped in virtually all states." Here again, Williams is wide of the mark. Our study makes no mention of the general, nationwide decrease in fatalities because it was found to be entirely irrelevent. That is, there was no corresponding statistically significant decrease in alcohol-related fatalities among younger drivers in the comparison states in 1981.

Williams has overlooked the data provided in Table 1, and conveniently failed to
mention that the nationwide reduction was equally distributed in terms of alcohol
versus non-alcohol-related crashes among age groups as were those in Illinois
and Michigan, but not Wisconsin, in 1981.

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