May 15, 2006


Richard Wagoner
Chairman and Chief Executive Officer
General Motors Corporation
300 Renaissance Center
Detroit, MI 48226

Chet Huber
President
OnStar
400 Renaissance Center
Detroit, MI 48226



Dear Mssrs. Wagoner and Huber:

We are writing to request that you immediately stop advertising unsafe driving practices in connection with your OnStar telematics system and that you reengineer OnStar to disable its two-way communications features while a vehicle is in motion.

OnStar radio commercials airing right now promote OnStar’s ability to function like a hands-free cell phone, enabling drivers to place a phone call while keeping “their hands on the wheel and eyes on the road.” Even more troubling in one commercial is the inclusion of an actual OnStar user, who proudly admits that she uses the hands-free calling service and states that, “I don’t believe in cell phones when I’m driving, so this is my salvation.”

Promoting OnStar hands-free calling in this way dishonestly portrays hands-free calling as a safe activity to engage in while operating a motor vehicle. In fact, a 2001 study by David Strayer and William Johnston of the University of Utah showed that conversing on a cellular telephone—whether using a handset or not— doubled the failure rate to detect simulated traffic signals and slowed reaction times to traffic signals that were detected at all.¹

In 2003, another University of Utah study examined the effects of driving while conversing on hand-held and hands-free cell phones and concluded that “cell-phone drivers may actually exhibit greater impairments (i.e. more accidents and less responsive driving behavior) than legally intoxicated drivers.” Comparing the degraded performance of drivers who used hand-held versus hands-free phones, the study noted that “no significant differences were found in the impairments to driving caused by these two modes of cellular communication.”²

Driving while talking on a hands-free cell phone is just as dangerous as driving while talking on a hand-held cell phone because the two-way conversation, not the task of holding the phone, causes a cognitive distraction. This distraction induces an “inattention blindness” that inhibits drivers’ abilities to detect changes in the road condition. The published literature is quite clear on this issue.

This problem has not been observed with one-way communications, such as when a driver is listening to the radio or to a conversation between others.

Based on this evidence, it is clear that OnStar poses a safety hazard when a driver of a moving vehicle uses the service in any two-way communication mode, whether as a hands-free cell phone or simply as a cellular link to an OnStar operator.

Accordingly, we request that you cease airing any advertisement which portrays the use of or encourages drivers to use OnStar in a two-way communications mode while driving. Furthermore, we ask that you immediately alter the design of OnStar systems installed in new vehicles, disabling two-way communication modes while the vehicle is in motion.

We are not denying the safety benefit of OnStar as it was originally conceived—to notify emergency services after a crash. However, your increasing emphasis on frivolous and even dangerous applications of OnStar while driving downplays the important role telematics systems can play in post-crash emergency response. By placing profits over safety, your attention to unnecessary OnStar features has sidetracked your implementation of better post-crash notification.

For example, the Advanced Automatic Crash Notification (AACN) segment of OnStar devices currently being installed in GM vehicles records the crash delta V, the principal direction of force (PDOF), and whether the crash is a rollover—but does not communicate this information to emergency responders. With this knowledge, emergency responders could tailor the level of post-crash response in proportion to the severity and type of crash. Tragically, OnStar is collecting potentially life-saving information but not using it to save lives.

We hope that you consider your responsibility to motorists’ safety paramount and will therefore remedy these problems promptly.




Sincerely,



Ralph Nader
P.O. Box 19312
Washington, D.C. 20036

Rob Cirincione

Clarence Ditlow
Executive Director
Center for Auto Safety
1825 Connecticut Avenue, NW
Washington, D.C. 20009

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1. Driven to distraction: Dual-task studies of simulated driving and conversing on a cellular telephone, David L. Strayer, William A. Johnston, Psychological Science, vol. 12, no. 6, November 2001, pp. 462-466.
2. Fatal distraction? A comparison of the cell-phone driver and the drunk driver, David L. Strayer, Frank A. Drews, Dennis J. Crouch, in the Proceedings of the Second International Driving Symposium on Human Factors in Driver Assessment, Training, and Vehicle Design, Park City, Utah, 2003, pp. 25-30.