MRF Submits /commets to NHTSA on FARS
The Motorcycle Riders Foundation (MRF) recently submitted formal public comments to the National Highway Traffic Safety Administration (NHTSA) in response to the agency’s request for input on the Fatality Analysis Reporting System (FARS) and the Non-Traffic Surveillance (NTS) system. These systems form the backbone of how federal and state agencies track roadway fatalities and serious crashes. The MRF emphasized the importance of these systems to the motorcycling community.
In its comments, the MRF reaffirmed that FARS is an indispensable tool for understanding motorcycle fatalities and developing effective safety strategies. Because motorcycles differ significantly from passenger vehicles in terms of exposure, performance, visibility, and rider behavior, aggregated crash data often fails to capture trends that uniquely affect motorcyclists. Accurate, consistent and detailed motorcycle-specific data is essential for identifying patterns, targeting safety resources, evaluating training programs and guiding sound policymaking.
The MRF also urged NHTSA to ensure that any modernization of FARS, particularly efforts to improve the timeliness of data release, does not compromise data integrity or year-to-year consistency. For a relatively small but high-risk group such as motorcyclists, even minor changes in data definitions or collection practices can distort long-term trend analysis. Transparency and public engagement, the MRF noted, must remain central to any substantial changes in how data is collected or coded.
“FARS is not simply a database for motorcyclists, it is the yardstick by which progress is measured,” the comments stated. From rider education and training to infrastructure investment and regulatory decisions, nearly every motorcycle safety initiative depends on reliable fatality data. The MRF concluded by urging NHTSA to prioritize continued funding, accuracy, consistency, and accessibility of FARS, while ensuring that the unique characteristics of motorcycle crashes remain visible in the nation’s most important traffic safety dataset.
The MRF will continue to engage federal agencies to ensure that motorcyclists are fully represented in national safety data and that policies are based upon accurate information, not assumptions.
Here are the comments:
Comments of the Motorcycle Riders Foundation
Docket No. NHTSA-2025-0721
Agency Information Collection Activities; Notice and Request for Comment;
Fatality Analysis Reporting System (FARS) and Non-Traffic Surveillance (NTS)
The Honorable Jonathan Morrison
Administrator
National Highway Traffic Safety Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
Re: Docket No. NHTSA-2025-0721
Dear Administrator Morrison:
On behalf of the Motorcycle Riders Foundation (MRF), we appreciate the opportunity to provide
comments on the National Highway Traffic Safety Administration’s notice and request for
comment regarding the Fatality Analysis Reporting System (FARS) and Non-Traffic Surveillance
(NTS).
The Motorcycle Riders Foundation is a national advocacy organization representing the interests
of millions of motorcyclists across the United States. For over four decades, MRF has worked to
advance public policy that improves rider safety while protecting the freedoms and rights of
America’s motorcycling community.
The Fatality Analysis Reporting System is indispensable to the work of NHTSA and to
organizations such as ours that seek to reduce fatalities through education, training, and
informed policymaking. For motorcyclists in particular, FARS serves as the critical standard by
which we are able to understand how, where, and why fatalities are occurring within our
community.
Motorcycles are fundamentally different from passenger vehicles in terms of exposure,
performance characteristics, conspicuity, and rider behavior. These unique factors mean that
trends affecting motorcyclist safety are often masked when aggregated with data for other
roadway users. Without a robust, accurate, and consistent FARS dataset, it becomes nearly
impossible for rider organizations, researchers, states, and federal agencies to identify
meaningful patterns, target resources, and evaluate the effectiveness of safety interventions.
We recognize that FARS is not without its challenges, including the delay in the certification and
public release of annual datasets. While we support efforts to modernize the system and improve the timeliness of data availability, any changes must preserve the integrity, accuracy,
and year-to-year compatibility of the data. For motorcyclists, even small shifts in data definitions
or collection practices can significantly distort trend analysis in a relatively small but high-risk
population.
MRF strongly encourages NHTSA to seek public input on any substantial changes to FARS data
elements, coding practices, or system architecture. Transparency in these decisions is essential
to maintaining the trust and utility of this foundational safety resource.
FARS is the primary tool used by NHTSA to evaluate safety countermeasures and guide
regulatory action. It is also the backbone of motorcycle safety research used by state motorcycle
safety programs, rider training organizations, public health officials, and nonprofit advocates.
Knowledge is a powerful tool: accurate fatality data leads to better education, improved training
curricula, smarter infrastructure investments, and ultimately, lives saved.
In short, FARS is not simply a database to the motorcycling community—it is the yardstick by
which progress is measured. The Motorcycle Riders Foundation urges NHTSA to prioritize the
continued funding, accuracy, consistency, and accessibility of FARS and to ensure that the unique
characteristics of motorcyclist crashes remain clearly visible within the nation’s most important
traffic safety dataset.
Thank you for the opportunity to submit these comments and for your continued commitment
to roadway safety for all users.
Respectfully submitted,
Kirk “Hardtail” Willard
President
Motorcycle Riders Foundation
Join the MRF at www.mrf.org
