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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. Wilhiine

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

AFW:sc

Enclosures

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

JUNE 18, 1983

Response to Dr. Williams....

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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lowa - where the Governor's Highway Safety Office reported an increase in

the first post-change year (deleted from Williams' study) followed by a
return to 1978 levels in subsequent years.

Massachusetts - where the Commissioner of Probation and the Registrar of

Motor Vehicles Report that alcohol related occurances increased among
those affected by raising the age.

Florida - where Morris recently found no significant change among drivers

of any age attributable to raising the age.

Maine where Wagenaar found no significant reduction in serious crashes

and officials of the state highway patrol report no change subsequent to
raising the age.

Minnesota - where crashes among 18 year-olds during the immediate post change

period (data for which were not included in Williams study) increased significantly and returned to pre-change levels in subsequent years.

Montana

where Williams' own study found an increase among those affected.

You don't need a Ph.D. to know that three out of nine is not a sure thing. Williams' "28% reduction" prediction was wrong in six of the nine states studied, and also wrong in Florida.

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. Dowdy. RESPONSE TO SEN

Nuis. Lightner, I want to thank you very much for CRITICISM OF T

ay. I also am aware of the great work which your orResponse to pnas done in bringing this issue to the forefront on a na

sis, and I think you are to be commended for that. I know Williams' ur organization has worked with the various State legislawith M' in the States where we do not have the minimum drinking Age of 21 years. Could you comment on that? Has your organization nade efforts in each of those States with the State legislatures to have them address this problem?

Ms. LIGHTNER. Yes, sir, they have in every single State we have a chapter in. We have 210 chapters in 40 States at the present time, so every State in which a chapter is located that does not have a drinking age of 21, our people have been trying their best to educate their legislatures to raise the drinking age to 21 in that State. Some States we were successful, others we were not, unfortunately. Texas was one of those, where I am now located.

Mr. Dowdy. What seems to be the primary reason? What does your experience show in these States where you have gone to the State legislatures and asked for a change in their State legislation? Why is there a reluctance on the part of the State legislatures?

Ms. LIGHTNER. I can only tell you what has been reported to me by my chapters, and that is, because they have had a tremendous amount of opposition from the liquor industry, such as the Beverage Association, the retailers, and what have you, who are a very powerful lobbying group, unfortunately. They have not been able to compete with those particular lobbying groups and convince the legislators that it is more important to raise the drinking age to 21. Mr. Dowdy. Thank you again for your testimony. I would yield back the balance of my time. Mr. Florio. The gentleman from New Mexico. Mr. RICHARDSON. Thank you very much, Mr. Chairman.

I have two questions, the first one more, I guess, a generic one. Why, Mrs. Lightner, do you think that the ideal age is 21 and not 20 or 19? I mean, is there a statistical basis to show that 21 would be a watershed age that would prevent-I see the statistics-well, that would help save substantially more lives than age 20?

Ms. LIGHTNER. I actually do not think the ideal age is 21, sir. I think it is much older, but you have to be realistic, and one of the things that we have learned within the organization is that sometimes you have to compromise and be realistic, and 21 is at least a realistic drinking age, and it also does save lives if you raise the drinking age to 21.

I think if you left it up to us, those of us who have suffered the way we do, we would much rather see the drinking age much higher, but you would never convince the general public of that. However, you can and have convinced the general public, such as the Gallup poll and other polls, to at least support a drinking age of 21.

Mr. RICHARDSON. So what you are saying is that 21 is better than 20 and 19?

Ms. LIGHTNER. Absolutely.

Mr. RICHARDSON. In a State like New Mexico, that I represent, we already have a 21-year-old drinking age. What would your orga

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nization do given the fact that some States already have such a drinking age? What could be done to educate the public more in this area?

Ms. LIGHTNER. Well, sir, our organization goes into the schools and works with community groups through speakers' bureaus and other programs to educate not only the general public as far as adults go but the youth on the responsibilities of drinking and driving.

Mr. RICHARDSON. I guess, not wanting to be the role of the devil's advocate-

Ms. LIGHTNER. Oh, that is all right. I am used to that.

Mr. RICHARDSON (continuing]. There is one aspect of this legislation that does trouble me, and

I am generally quite supportive of it, and that is, what do we tell those young men who are fighting in Lebanon or soldiers? We are telling people that they can go fight and die for the United States, and we are drafting them at a very early age, and then comes a law that says you cannot drink, and many of these young men that are fighting in Lebanon-I guess the President would not like me to say they are fighting, but what do you tell them?

I mean, does this legislation-should it apply to all military bases, too?

Ms. LIGHTNER. Oh, yes, sir.

Mr. RICHARDSON. There is an aspect that troubles me. We are asking men to die and we are telling them that somehow we have to restrict their drinking. That is one aspect that troubles me, and I would like to know how we can reconcile it.

Ms. LIGHTNER. Well, I think it is important at this time to remember that drunk drivers kill more Americans every 2 years than were killed in the Vietnam war, and if we are already asking them to die in Lebanon, and we have already asked them to die in Vietnam, why should we ask them to die in regards to drunk driving? There is already one war going on. There was already another war. Why should we have a third war, and that is the war of drunk driving?

I happen to believe it is like comparing apples to oranges: if you are old enough to fight, you are old enough to drink. I grew up in the military, and I have a real hard time with that analysis and that logic. Frankly, I do not think people at 18 are old enough to fight. I would like to see them raise the age to 21. That is a personal belief and not the belief of my organization. But I just do not think there is any comparison.

Mr. RICHARDSON. Well, I do, because I have heard some of these young officers and young men in the military that talk about things like this. Again, I am not saying that this is going to be a complete barometer for my not supporting this bill. I think we have got to recognize that that is a legitimate issue, that if we are giving men and women responsibility to fight for this country, and we are saying that you may die, you may be in a wartorn situation, and then we come back and say, well, but you cannot drink, you cannot have a beer. We are making a moral judgment, and I can see the chairman, and with all due respect, Mr. Chairman, I do think that this is something that just troubles me.

Mr. FLORIO. Would the gentleman yield?

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