Dear Accident Compensation Corporation,

I am appending the conversations I had with one of your employees and she has been ignoring my question for more than 2 weeks.

I initially asked her to explain how the same vehicle can have two different safety ratings just because they have two different badges.

Now I want to find out whether the data used to derive the safety rating was actually legitimate and statistically sound.

Please provide full data used for analysis of the safety ratings of the Hyundai Tucson and the Kia Sportage, all model years from 2005 onwards.

Thank you

PS, I am attaching my conversation with ACC and Nancy Robbie, Senior Advisor.

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From: D Kim <[email address]>
To: Government Services <[email address]>
Sent: Wednesday, 22 July 2015 5:22 PM
Subject: Re: Vehicle Risk Rating - Kia Sportage

Hi Nancy,

Whilst you did address groupings of different model years within the same model, you didn't address the discrepancies between the Hyundai Tucson/ix35 and the Kia Sportage.

Like I mentioned in the original email, they are exactly the same vehicles with the same safety features with the same equipment levels.

Then, how is it possible they can have two completely different safety ratings?

I mean you might have used TSSI to assess the real life crash results, but that can be biased due to differences in sample sizes between different models.

It is like saying someone buying a Holden Commodore then put a Chevrolet badge to suddenly make it safer (or less safe).

As you would expect, nothing will change because it's just a superficial change.

The two vehicles (Tucson and Sportage) are the same vehicles with different badges just like the Holden and Chevrolet example.

They are basically produced in the same factory with the same material (Hyundai has its own steel mill and its subsidiary, Mobis, source most of parts) to the same dimensions by the same people (or robots), albeit some degrees of cosmetic differences.

Could you please address this issue since you didn't answer it?

Thanks and probably a faster response would be appreciated as your answer was a just plain standard answer you probably give out to everyone. I thought you were doing research on the Tucson and Sportage model years and specifications but obviously nothing was mentioned here at all.

D KIM

From: Government Services <[email address]>
To: "'[email address]'" <[email address]>
Sent: Wednesday, 22 July 2015 4:15 PM
Subject: Vehicle Risk Rating - Kia Sportage

Good afternoon Mr Kim

Thank you for your email regarding the rating of the Kia Sportage 2006.

ACC has calculated which band most vehicles should be in based on the year they were first registered and compared that to real world crash data collected by Monash University in Melbourne. ACC risk rating draws on real crash data from 5.5 million police reported road crashes across Australia and New Zealand, extending back as far as 1987 using a system called the Total Secondary Safety System (TSSI).

ACC needs three and a half years of crash data to calculate the right levy band for a vehicle. For vehicles that were first registered from 2012 onwards, there is not enough information available. In these cases a laboratory-based testing system like ANCAP (Australian New Car Assessment Programme) star rating has been used to assign a levy band. A vehicle may perform really well in these tests but not do as well in real crash scenarios.

That does mean that the same vehicle manufactured in different years could potentially be in different levy bands. But once there’s enough crash data, the band a newer vehicle is in may change.

One of the reasons for a difference between NCAP ratings and the TSSI is that while the NCAP system looks at how the vehicle protects drivers in simulated crash tests, the TSSI rates the relative performance of vehicles in protecting both their own drivers, other drivers and other road users by measuring and integrating two sets of vehicle safety data:

• aggressivity measures the risk of fatalities and injuries to the driver of another vehicle and unprotected road users such as pedestrians, cyclists and motorcyclists struck by the vehicle being measured

• crashworthiness is about how the vehicle structure will protect the driver of the striking vehicle during and after impact.

This sometimes creates a difference in NCAP and TSSI ratings.

An example of this could be where you have a large solid SUV type vehicle which does a good job of protecting the driver in a crash when undergoing NCAP testing. However, that same vehicle, because of how solid it is, causes severe injuries to other road users (pedestrians, motorcyclists) when involved in a crash.

While it appears that the Kia Sportage 1996-2011 has been treated as one group, this is not the case. There were distinct groupings within these years based on the TSSI results. ACC has reviewed the crash data for the Kia Sportage and believes it correctly states the outcomes of crashes for these vehicles. For the Sportage the real world crash results do not seem to reflect the laboratory tests that the ANCAP rating are based on. The Sportage (possibly due to its size and weight) seems to be less forgiving to pedestrians than other vehicles. Also the protection inside the vehicle in real world crashes is less than expected from the ANCAP results.

Yours sincerely

Nancy Robbie

Nancy Robbie, Senior Advisor, Government Services, ACC
PO Box 242 / Wellington 6140 / New Zealand / www.acc.co.nz

ACC cares about the environment – please don’t print this email
unless it is really necessary. Thank you.

From: D Kim [mailto:[email address]]
Sent: Thursday, 2 July 2015 10:55 a.m.
To: Business Service Centre
Subject: Motor Vehicle Levy

Hi,

I am writing to you to reconsider the vehicle levy band for the Kia Sportage.

I watched Fair Go last night and a few vehicles had their levy bands reassessed due to inadequate analysis on ACC's part.

I believe my vehicle is in the same category and I hope what I am about to give you is a logical and reasonable assessment for you to reconsider the levy band.

I currently own a Kia Sportage 2006 model.

This model came out in 2005 ran until 2011, then the new model came out in 2012 with a complete redesign.

In your levy booklet, earlier generations from 1996 were banded together with this generation and it has been given band 1.

However, I see the Hyundai IX35/JM/Tucson 2004 to 2010 is in Band 3.

In fact, the Hyundai Tucson from 2004 share the exactly same platform with the Kia Sportage.

Kia usually comes out with a new model with one year delay to avoid cannibalising sales of Hyundai. They are both owned by Hyundai Motor company and most of their cars share the same platforms. This is what is usually called Badge-Engineering to lower their development costs and this is a very common practice among car manufacturers. You can observe this with the VW Golf and the Audi A3 and the Skoda Octavia or Peugeot & Citroen or the Ford Ranger and the Mazda BT50 and the list goes on.

FYI, My Kia Sportage has 6 airbags, ABS, TCS and Stability control.

With this information provided I believe Kia Sporage 2005-2011 should be given Band 3, the same band as the Hyundai Tucson with comparable model year 2004 - 2010.

Thank you

Do kyun KIM

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Yours faithfully,

Do Kyun KIM