U.S. Transportation Secretary Elaine Chao on Tuesday designated October as Pedestrian Safety Month, and the National Highway Traffic Safety Administration set right to work producing press releases and workbooks for communities around this new month of heightened safety awareness. Pedestrian traffic deaths have been on a dramatic rise for years now, and NHTSA has a possible solution for bringing fatalities down.

It just chooses not to.

First, let’s go way back in time to April when the “NHTSA Needs to Decide Whether to Include Pedestrian Safety Tests in Its New Car Assessment Program.” NCAP is, of course, the federal five-star rating system initiated to inform consumers of a vehicle’s safety performance, which does not currently require crash-safety considerations for people outside the vehicle.

The GAO report kicks off with the sobering statistic that an average of 17 pedestrians died each day in 2018. That’s roughly one every 84 minutes. From the report’s findings:

In 2015 NHTSA proposed pedestrian safety tests for its New Car Assessment Program (NCAP), but NHTSA has not decided whether it will include such tests in the program.

NHTSA has reported that crash avoidance technologies could lead to a decrease in pedestrian fatalities. Nine automakers that GAO interviewed reported that NHTSA’s lack of communication about pedestrian safety tests creates challenges for new product development.

NHTSA has also not documented a clear process for updating NCAP with milestones for decisions. NHTSA officials said that updating NCAP involves many actions and can take years. However, absent a final decision on whether to include pedestrian safety tests in NCAP and a documented process for making such decisions, the public lacks clarity on NHTSA’s efforts to address safety risks.

Then, over the summer, the Federal Highway Administration on pedestrian safety. Among the recommendations, such as redesigning city streets to be more pedestrian-friendly, there were ridiculous technology solutions. My favorite was an app that lets pedestrians send out a digital notification that they are about to cross a street to any drivers in the area.

How simple! Of course, the driver would need to also be running and checking the app for this to work, which you shouldn’t be doing at all, especially in an area where there are potentially pedestrians:

Pedestrian fatalities have increased a staggering 53 percent in the last decade, according to the , even while in-vehicle deaths have decreased thanks to advanced safety technology and thorough crash testing. So while we’re playing around with ridiculous apps and begging cities to undo a hundred years of development around the car, we’re not doing the simplest thing we can to keep people safe: crash testing cars with pedestrian impacts in mind.

NHTSA has that it needs to be crash-testing cars for pedestrian safety, as is done under the European NCAP program. But it hasn’t. Instead, we continue to build bigger and bigger vehicles. And a small study by the found what common sense probably could already tell you:

SUVs were more likely than cars to throw pedestrians forward and nearly twice as likely to cause severe hip and thigh injuries. These injuries were mainly caused by impacts with the bumper, grille or headlights. That’s likely because the high point of the front profile or “leading edge” of most new SUVs is still considerably higher than that of the average car.

In a crash with a traditional, block-front SUV, the grille strikes the pedestrian’s pelvis or chest split seconds after the bumper hits the lower extremities, transferring more energy to the pedestrian’s body. It’s possible that a more sloping profile could do less damage.

In 2019, light trucks (which include SUVs) made up 72 percent of the market, according to . That’s up from 57 percent just five years ago. They just keep getting bigger and more numerous. I mean, have you seen what truck designers are fantasizing about building in the coming years? Does this look to you?

Hey, General Motors Design? How’s it going, buddy? Man, I still sure love what you did with that…

Nevermind that there are trucks on the market that are already high-speed battering rams screaming down the road. Our own Jason Torchinsky is currently driving his Changli around in a Ford F-250, and his head barely clears the grille. That’s not even Ford’s largest truck! A driver could easily miss even shorter people and children beyond the hood of that enormous vehicle.

NHTSA even investigated in 2018 and applied those metrics to some American vehicles. They found pickups and SUVs did not score well at all. NHTSA’s own promotional materials admit that, while safety technology inside the vehicle has improved leaps and bounds, pickups and SUVs are more likely to injure or kill anyone outside of them.

To literally add insult to serious injuries, much of the material from NHTSA around Pedestrian Safety Month center on what pedestrians need to do to keep themselves safe, rather than what drivers can do. Here’s their advice for pedestrians:

Walk on a sidewalk or path. If neither is available, walk facing traffic and as far from cars as possible. Cross streets at marked crosswalks or intersections whenever possible; this is where drivers expect pedestrians. If neither is an option, locate a well-lit area, wait for a gap in traffic that allows you enough time to cross safely, and continue to watch for traffic as you cross.Be alert. Walkers wearing headphones or using a cell phone might not hear a car horn, or could miss a traffic signal at a crosswalk. Know walking while impaired is dangerous. An estimated 33% of fatal pedestrian crashes in 2018 involved a pedestrian who was drunk. NHTSA offers tips for other ways to safely get home. Never assume drivers see you; they could be distracted or impaired. It’s best to make eye contact with drivers to make sure you are seen. Make yourself visible by wearing brightly colored clothing during the day. At night, wear reflective materials, or use a flashlight.

While people who are walking need to keep a clear head, make meaningful eye contact with every driver (and try not to fall in love every time) and carry an extra set of reflective clothing with them, NHTSA advice for drivers boils down to follow driving laws you should already be following (but probably aren’t, because holy shit have you seen the pedestrian death rates?)

Look for pedestrians everywhere. Pedestrians may be walking in unexpected areas, or may be hard to see — especially at night, in poorly lit areas, or in bad weather.Follow pedestrian safety laws in your state or local area — always stop or yield for pedestrians in the crosswalk.Never pass vehicles stopped at a crosswalk. They might be stopped to allow pedestrians to cross the street.Stay alert where children may be present, like in school zones and neighborhoods.Slow down and carefully adhere to posted speed limits, particularly in urban and pedestrian-heavy areas. Lower speeds are one of the most important factors in pedestrian crash survivability.

Week two of Pedestrian Safety Month comes with two press releases centered on distracted driving and walking, and drunken pedestrians. NHTSA really focuses on the estimate that 33 percent of fatal pedestrian crashes in 2018 involved a pedestrian whose blood alcohol measure was over the legal limit for a driver, versus the 16 percent that involved a driver who was drunk. While drunken driving rates are in decline, drunken walking is up, which seems to be a natural outcome of less drunken driving.

But these are still fragile human bodies who made the decision to not get behind the wheel. NHTSA also doesn’t go into the causes of the 33 percent who were killed. While drunks do tend to make bad decisions, pedestrians can be drunk and still legally walking down the street and get hit by a car. Their death wasn’t caused by the alcohol, but by a car not tested to keep that human life safe.

NHTSA can fiddle with tech bro-style solutions and hand out all the reflective vests it wants, but the problem is not going to go away by wishing on an app and admonishing drunken walkers. The only way is to make car companies give a damn about the people outside of their vehicles, rather than just making sure their customers inside are totally protected, is to crash test. This is the job of a regulatory body, but after a decade it seems to be a job NHTSA is just not up for.