To put it bluntly, you are very wrong there.

In very few states is the value of a totaled bicycle high enough to trigger a requirement for a PAR report, and the damage that a bicycle does to a car is unlikely to either.

Second, one of the *specific* injuries we are worried about, a loss of consciousnesses which might indicate a TBI, is not captured by the data. I don't know how you imagine that this number is not relevant.

Third, in a large number of jurisdictions, absent a triggering property loss, only if at least one injury is "severe" enough is there are requirement for a PAR. I don't know how you imagine that this number is not relevant.

Fourth, a significant number of bicycle crashes on the road don't involve motor vehicles, which is not captured by the data. I don't know how you imagine that this number is not relevant.

Fifth, a significant number of bicycle crashes don't take place on the road. Now, while you might decide that *you* are only worried about accidents that happen on the road, others might not agree.


You've presented your analysis as "worst case" numbers, yet you've dramatically UNDERSTATED the numerator. (We aren't talking by a few percent here.)
(That's before we even get to your overstating the denominator in your "worst case" estimate.)

-mr. bill