Tribal Governments & Transportation

Safety Data

Report by: Federal Highway Administration

Federal Lands Highway

Office of Tribal Transportation

Primary contributors: 

Adam Larsen, Federal Highway Administration and Greg Piland, Federal Highway 

Administration 

With significant input from the Tribal Transportation Safety Management System Steering 

Committee
Report to Congress: Tribal Governments & Transportation Safety Data Page 2 of 42

I. Executive Summary

The American Indian and Alaska Native population is disproportionately represented in fatalities 

and crash statistics in many States (Washington, 2013). Motor vehicle crashes are the leading 

cause of unintentional death for American Indians and Alaska Natives (AI/AN) ages 1–44 

(Centers for Disease Control and Prevention (CDC), 2014). This report demonstrates crash data 

is underreported, and if reported the statistics would be even higher. 

The circumstances contributing to the underreporting of crashes include but are not limited to 

privacy concerns, staffing limitations, and lack of equipment and training. This report 

investigates ways to improve the collection and sharing of crash data so that it is useful for 

identifying needed improvements to transportation safety in tribal areas. 

A survey developed by the Tribal Transportation Safety Management System Steering 

Committee was made available to all federally recognized Tribes and to the 35 States where 

these Tribes are located. The Committee received responses from 152 federally recognized 

Tribes and 22 States; these responses were analyzed to determine the quality of existing tribal 

transportation safety data, opportunities to improve data collection, options for paperless data 

reporting, and uses of crash data. This report also documents Federal funding opportunities 

available to Tribes for crash data improvement. 

Proposed action by USDOT agencies is documented below. Implementation of these 

recommendations will require significant partnership with other Federal agencies. Full 

implementation of the recommendations will produce safety data, especially crash data, that is 

useful for planning the programs and projects that will reduce the number of transportation 

related deaths and injuries in tribal areas. 

II. Summary of Recommendations

The following is a summary of the specific actions that USDOT agencies will take to improve 

the quality and availability of safety data in tribal areas.

• The Federal Highway Administration (FHWA) Tribal Transportation Program Safety 

Funds, available for federally recognized tribal governments to improve 

transportation safety, will continue to accept applications based on any form of safety 

data. However, applicants using data other than police crash reports will now be 

encouraged to provide a plan showing how the applicant will achieve higher quality 

data for the future. The process described in National Cooperative Highway 

Research Program (NCHRP) 788 is one method Tribes could use to assess traffic 

records.

• The National Highway Traffic Safety Administration (NHTSA) will revise the Traffic 

Records Assessments Procedures Manual to encourage better coordination between 

States and Tribes concerning traffic records.

• The FHWA will partner with the BIA Division of Transportation (BIADOT) to

investigate incorporating the National Tribal Transportation Facility Inventory 

(NTTFI) with the All Roads Network of Linear-Referenced Data (ARNOLD) which 

is being established as a result of the Moving Ahead for Progress in the 21st Century 
Report to Congress: Tribal Governments & Transportation Safety Data Page 3 of 42

Act (P.L. 112-141) (MAP-21). A Geographic Information System (GIS) based 

National Tribal Transportation Facility Inventory would generate roadway data that 

would be useful for transportation safety studies.

• The FHWA will assist States in communicating with BIA and Tribes when 

developing annual safety performance targets.

• The FHWA will establish a partnership with the BIA Office of Justice Services to 

work toward crash data in tribal areas that is more accessible and of higher quality. 

This partnership will benefit Tribes served by the BIA Law Enforcement Services and 

tribal police funded by the BIA OJS. This partnership could be in the form of a 

stand-alone Traffic Records Coordinating Committee or may be a duty of the already 

established Tribal Transportation Safety Management System Steering Committee. 

Some of the strategies that this partnership may pursue include the following:

o Using either the electronic DOI crash form in Incident Management Analysis 

and Reporting System (IMARS) or a MMUCC-compliant electronic State 

crash data system. Using State data systems will have advantages in many 

cases due to integration with other databases (such as location, driver, and 

vehicle data) and crash data sharing capabilities. 

o Encouraging tribal police to collect data in a format that is compliant with the 

Model Minimum Uniform Crash Criterion (MMUCC) to the extent possible. 

o Establishing sharing arrangements for crash data to be transferred on a regular 

basis to tribal and State governments for transportation safety planning 

purposes. Development of a central database for all DOI law enforcement 

programs that are using the DOI Crash form. This database could include 

quality assurance protocols and facilitate streamlined sharing of crash data 

with Tribes and States.

o Encouraging Tribal law enforcement agencies to share their crash data 

(excluding personal identifiers) with other departments of the Tribe and State

governments in addition to maintaining databases that are searchable and 

usable for transportation safety planning purposes. 

o Establishing procedures that ensure the completeness and quality of individual 

crash reports. 

o Establishing a national crash data clearinghouse for tribal police as an option 

for those Tribes with concerns about sharing crash data directly with State 

governments.

o Documenting guidelines for regular training or guidance to officers on the 

proper use of the DOI crash form or State crash form. 

o Providing Tribes with clear documentation of the process to establish sharing 

of motor vehicle crash data under the DOI-10 System of Records Notice. 

o Reviewing processes to centralize and streamline the collection and sharing of 

crash data. 

o Reviewing the process by which State governments may obtain crash data 

from BIA Law Enforcement Services for inclusion in the statewide databases

and the Fatality Analysis Reporting System (FARS).

o Documenting the procedures developed by State governments for crash reporting.
Report to Congress: Tribal Governments & Transportation Safety Data Page 4 of 42

Contents

I. Executive Summary ......................................................................................................................2

II. Summary of Recommendations....................................................................................................2

III. Acronyms......................................................................................................................................6

IV. Introduction...................................................................................................................................7

A. Under-reporting of motor-vehicle crash data............................................................................8

B. Under-reporting of off-roadway incident data ..........................................................................8

V. Existing National Safety Databases..............................................................................................9

1. Fatality Analysis Reporting System (FARS)........................................................................9

2. Incident Management, Analysis, and Reporting System (IMARS)...................................10

3. National Tribal Transportation Facility Inventory (NTTFI)...............................................10

4. Web-based Injury Statistics Query and Reporting System (WISQARS)............................10

VI. Safety data quality.......................................................................................................................11

A. Roadway Inventory Data Standards & Quality.......................................................................11

B. Crash Data Collection Standards ............................................................................................11

C. Crash Data Quality..................................................................................................................12

1. Federal Bureau of Investigation (FBI)................................................................................15

2. BIA Law Enforcement........................................................................................................15

3. Tribal Police........................................................................................................................19

4. State and County Law Enforcement ...................................................................................22

VII. Crash Data Collection and Sharing: Barriers and Opportunities ............................................24

A. Paperless Data Collection Options & Best Practices for Tribes .............................................24

B. Tribe-State Communication....................................................................................................26

C. Tribal Law Enforcement .........................................................................................................28

D. Resources for Crash Data Collection and Sharing..................................................................29

E. BIA Crash Data Sharing .........................................................................................................29

F. Tribal Transportation Safety Grants........................................................................................31

VIII. Uses of crash data ...................................................................................................................32

A. Enforcement / Adjudication / Legislation...............................................................................33

1. Adjudication & Insurance Companies................................................................................33

2. Targeting Law Enforcement Strategies...............................................................................33

3. Legislation...........................................................................................................................33

B. Funding and Resource Allocation...........................................................................................33

1. Safety Planning and Allocation of Resources.....................................................................33

2. Grant Applications..............................................................................................................34
Report to Congress: Tribal Governments & Transportation Safety Data Page 5 of 42

C. Promotion and Coordination...................................................................................................34

1. Communication with Leadership ........................................................................................34

2. Communication with other Governments...........................................................................34

3. Public Advocacy Campaigns..............................................................................................35

D. Research and Development.....................................................................................................35

1. TRB Subcommittee on Tribal Transportation.....................................................................35

2. Vehicle Safety Standards....................................................................................................35

3. Roadway Design and Traffic Engineering..........................................................................35

4. Driver Training and Testing................................................................................................36

E. Safety Improvement with Limited Crash Data .......................................................................36

1. Road Safety Audits.............................................................................................................36

2. Systemic Safety Improvement ............................................................................................36

3. Other Sources of Crash Data...............................................................................................36

IX. Funding for Improving Crash Data Collection ...........................................................................38

A. TTP and TTP Safety Fund (23 U.S.C 202(e)) ........................................................................38

B. HSIP (23 U.S.C 148)...............................................................................................................38

C. BIA Indian Highway Safety Program (23 U.S.C 402)............................................................39

D. State Administered NHTSA Highway Safety Plan Funding (23 USC 402 and 405(c)).........39

E. DOJ Coordinated Tribal Assistance Solicitation (CTAS) ......................................................39

X. Methodology...............................................................................................................................40

XI. Works Cited ................................................................................................................................41
Report to Congress: Tribal Governments & Transportation Safety Data Page 6 of 42

III. Acronyms

AI/AN American Indians and Alaska Natives

ANSI American National Standard Manual on Classification of Motor Vehicle

 Traffic Accidents

ARNOLD All Roads Network of Linear-referenced Data

BIA Bureau of Indian Affairs

BIADOT Bureau of Indian Affairs, Division of Transportation

BIA IHSP Bureau of Indian Affairs, Indian Highway Safety Program

BIA-OJS Bureau of Indian Affairs, Office of Justice Services

CDC Centers for Disease Control

CFR Code of Federal Regulations

CTAS Coordinated Tribal Assistance Solicitation

DOI Department of Interior

DOT Department of Transportation

EMS Emergency Medical Services

FAST Fixing America's Surface Transportation Act

FARS Fatality Analysis Reporting System 

FBI Federal Bureau of Investigation

FLH Office of Federal Lands Highway

FHWA Federal Highway Administration

FOIA Freedom of Information Act

FY Fiscal Year

EMS Emergency Medical Service

GIS Geographic Information System

HSIP Highway Safety Improvement Program

IMARS Incident Management, Analysis, and Reporting System

MAP-21 Moving Ahead for Progress in the 21st Century Act

MIRE Model Inventory of Roadway Elements

MMUCC Model Minimum Uniform Crash Criteria

NCHRP National Cooperative Highway Research Program

NHTSA National Highway Traffic Safety Administration

NTTFI National Tribal Transportation Facility Inventory

OMB Office of Management and Budget

RSA Road Safety Audit (also known as Road Safety Assessment)

SAFETEA Safe, Accountable, Flexible, Efficient Transportation Equity Act: 

 A Legacy for Users

SMS Safety Management System

SSP Strategic Safety Plan

TTP Tribal Transportation Program

TRB Tribal Research Board

TRCC Traffic Records Coordinating Committee

USC United States Code

US United States

USDOT United States Department of Transportation

VPSO Village Public Safety Officers
Report to Congress: Tribal Governments & Transportation Safety Data Page 7 of 42

IV. Introduction

Given the under-reporting of crashes in tribal areas that is described later in this report, one 

would expect the AI/AN population to be underrepresented in crash statistics. Unfortunately, the 

converse is true in many States. The limited data that is available often describes a 

transportation safety picture that has greater impacts on AI/AN than the rest of the United States’ 

general population. One such example is in Target Zero®, Washington State’s Strategic 

Highway Safety Plan, which describes “the traffic fatality rate for Native Americans is 3.9 times 

higher than for non-Native Americans.” (Washington, 2013) Fatal motor vehicle crashes touch 

nearly every tribal area (Figure 1 is a map showing the locations of fatal motor vehicle crashes in 

or near tribal areas from 2010-2016). Transportation safety is also a concern for Tribes with few 

or no roads where tribal members experience injury and loss of life while traveling on trails, 

winter trails, waterways, and other transportation facilities. 

Improved collection and sharing of safety data, especially crash reports, in tribal areas would 

facilitate more effective transportation safety planning and would afford Tribes improved access 

to State and Federal funding opportunities to address transportation safety problems. Better 

quality safety data will enable enhanced analysis of the nature of safety challenges and more 

effective selection and implementation of transportation safety strategies. 

Figure 1. Map showing fatal crash locations reported to the Fatality Analysis Reporting 

System (FARS) for 2010-2014 within six miles of tribal areas

The Fixing America's Surface Transportation (FAST) Act, enacted on December 4, 2015, 

directed the Secretary of Transportation to complete this report about tribal governments and 

transportation safety data. The report was developed in consultation with representatives of the 

Secretary of the Interior, the Secretary of Health and Human Services, the Attorney General, 

tribal officials, and others in accordance with the requirements of FAST Act Section 1117(b).

The FAST Act further directs the Secretary of Transportation to develop a second report that 

identifies and evaluates options for improving safety on public roads in tribal areas. The second

report is described in Section 1117(c) and is due by December 2017. The second report will

build upon this report relative to transportation safety data and tribal governments of Section 

1117. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 8 of 42

The content of this report:

• Describes the quality of existing safety data.

• Recommends improvements to the collection and sharing of crash data that can be 

used to recover damages to tribal property, identify trends in crash data, and allow 

Tribes to more successfully compete for funding opportunities.

• Identifies electronic crash reporting options available to tribal governments.

• Identifies Federal transportation funding for safety data improvement.

A. Under-reporting of motor-vehicle crash data

State and national crash databases are often used to drive policy, program, and project decisions 

by State and Federal Governments. Analysis of these databases leads to the selection of roadway 

safety improvements through the Highway Safety Improvement Program (HSIP), an annual 

funding program, which made $2.1 billion dollars available to States in Fiscal Year (FY) 2016

(FHWA, 2016). Unfortunately, many Tribes are not adequately represented in these State and 

national databases because crash data collected by some BIA Law Enforcement Services agency 

offices and tribal law enforcement is not shared with State governments for a variety of reasons 

including privacy concerns and inadequate resources. In addition, some incidents go completely 

undocumented. This report further describes the evidence of under-reporting in the section on 

data quality.

Previous studies have identified concerns about motor vehicle crash data collection and sharing 

for tribal areas in specific States. One study found that the South Dakota statewide crash 

database was severely lacking in tribal areas where tribal and BIA police were not sharing crash 

data. The underreporting was so significant that the study recommended the State of South 

Dakota not pursue further safety analysis for tribal areas in the State until data sharing 

arrangements could be made (Drake, Sparks, & Thomaz, 2005). The Washington Traffic Safety 

Commission provided documentation showing that from 2004-2015, only 4 of the 29 federally 

recognized Tribes in Washington State consistently reported crash data. 

For crashes that are reported to State and national databases, the identification of ethnicity is an 

additional concern. For fatal crash victims, this information is usually obtained from a death 

certificate or as identified by next of kin when available. There is concern that American Indians 

and Alaska Natives are occasionally incorrectly identified as another race, reported as mixed 

race, or reported as unknown race. This limitation affects national level research on 

transportation safety in tribal areas. A research proposal about the identification of race in crash 

reports is underway by the Transportation Research Board (TRB) subcommittee on Tribal 

Transportation. 

B. Under-reporting of off-roadway incident data

While the focus of this report is on motor vehicle crashes on roadways, it is important to note 

that many Tribes, primarily those located in Alaska, make significant use of other transportation 

facilities such as trails, snow machine trails, board roads, and water routes. For these Tribes,

transportation safety focuses on different topics than roadway safety but is just as important; 

these safety efforts can also be enhanced through the collection of incident data. Often there is 

no method in place by which incident data is collected for off-roadway events. The majority of 

Tribes in Alaska do not have tribal law enforcement, there is no BIA law enforcement presence 
Report to Congress: Tribal Governments & Transportation Safety Data Page 9 of 42

in Alaska, and the Alaska State Troopers are spread very thin with significant logistical concerns. 

Alaska State Troopers place peace officers known as Village Public Safety Officers (VPSO) in 

some villages. When VPSO and/or tribal police are present in a village, they do not usually 

complete crash reports for transportation incidents. If a crash report is completed, it is often the 

same report form available to any member of the public to report their involvement in a crash 

where law enforcement was not on scene, rather than the Alaska State law enforcement crash 

report form. 

Some tribal governments have developed filing systems to record incidents at a local level for 

safety planning and grant application purposes. There is no system in place for these record 

systems to be shared on a statewide basis. An example is the Native Village of Napaimute. The 

Tribe’s transportation department has coordinated with search and rescue crews in the area who 

respond when an individual traveling between villages does not arrive as expected. When such 

an incident occurs, the transportation department gathers information in a narrative format, 

includes any pictures or news articles, and keeps the information in a filing cabinet for future 

use. 

V. Existing National Safety Databases

Safety data includes many different data types, each of which can enhance data analysis 

capabilities. This report focuses on crash data with some consideration of roadway and traffic

volume data which can then be used to analyze the crash data. Several national databases are 

discussed in the remainder of this report; a brief description of these national databases is set 

forth below. 

Databases on drivers, injuries, vehicles, and citations are all examples of safety data which may 

or may not exist in national database or be linked to any individual crash database. These data 

sources are beyond the scope of this report. 

1. Fatality Analysis Reporting System (FARS)

The NHTSA developed a national database, known as FARS, to collect information from 

multiple State data sources about deaths that occur within 30 days after motor vehicle traffic 

crashes. This information is used at all levels of government to inform public policy, provide 

statistical information, evaluate vehicle designs, and influence decisions on projects and 

programs to improve transportation safety. The FARS data is available at http://wwwfars.nhtsa.dot.gov/. 

While FARS is generally regarded as being the best available and most complete information on 

fatal crashes, the research conducted to develop this report found evidence of gaps in this 

database in tribal areas. All State governments voluntarily submit fatal crash data to FARS. 

However, Federal agencies and Tribes are not required to share their crash data with State

government or FARS. The sharing of fatal crash reports by tribal police varies from Tribe-toTribe. The crash reports completed by law enforcement departments under the DOI including 

BIA Law Enforcement, are usually only included in FARS on a case-by-case basis when the 

State requests information from the DOI or when the BIA Law Enforcement are notified because 

the responding BIA agency office is completing State crash forms. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 10 of 42

The NHTSA funds a FARS analyst in every State who is responsible for populating fatal crash 

information into the FARS database. The FARS analysts use multiple data sources to obtain 

information when they learn that a crash has resulted in a fatality. This includes direct contact 

with tribal and BIA Law Enforcement. 

2. Incident Management, Analysis, and Reporting System (IMARS)

The DOI has implemented a records management system known as IMARS. This system is 

intended to be used to document all law enforcement actions by the DOI, not just motor vehicle 

crashes. The IMARS has the capability to document crashes through a narrative report or the 

DOI crash form. Attachments can be added to either of these formats and some BIA Law 

Enforcement Services agency offices are completing State crash forms and attaching those to 

their IMARS entry. 

3. National Tribal Transportation Facility Inventory (NTTFI)

The BIA maintains a national inventory of public transportation facilities eligible for 

expenditures from the TTP to fulfill the requirements of 25 CFR 170. These surface 

transportation facilities include roadways, trails, board roads, and marine terminals. This 

inventory includes State, county, city, tribal, and BIA routes of interest to tribal governments. 

Roadways in this inventory are required to be open to public travel. Geolocation of the 

inventoried routes is currently not available but would greatly improve the usability of this data 

for safety studies. Additional information about the NTTFI can be found at 

https://itims.bia.gov/reports.shtml. 

4. Web-based Injury Statistics Query and Reporting System (WISQARS)

The CDC’s WISQARS is an online, publicly accessible database of fatal and non-fatal injuries 

and violent deaths caused by a variety of reasons, including motor vehicle crashes. The 

WISQARS uses the 10th revision of the International Statistical Classification of Diseases and 

Related Health Problems medical diagnosis codes to classify injuries. For transportation injuries,

these codes provide collision type and whether the injured person was a vehicle occupant, 

pedestrian or motorcyclist. Death data comes from a national mortality database compiled by 

CDC's National Center for Health Statistics. This database contains information from death 

certificates filed in State vital-statistics offices and includes causes of death reported by attending 

physicians, medical examiners, and coroners. It also includes demographic information about 

decedents reported by funeral directors, who obtain that information from family members and 

other informants. American Indian and Alaska Native injury data is found in WISQARS 

features for fatalities and is available by national, State, and county levels. The WISQARS 

allows users to sort, search, and review the data and create reports, charts, maps and graphics. 

The WISQARS data is available online at http://www.cdc.gov/injury/wisqars/. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 11 of 42

VI. Safety data quality 

A. Roadway Inventory Data Standards & Quality

Roadway and traffic data provide useful information for transportation safety analyses. Using 

comprehensive crash reporting in combination with adequate roadway and traffic data would 

enable proven study methods, such as those found in the Highway Safety Manual, to be 

effectively conducted for tribal areas. 

Some Tribes have adequate data to conduct roadway network screening for safety issues but 

those studies are limited to the Tribe and cannot be conducted on regional or national scales. 

Tribes that are interested in developing a roadway inventory should consider the Model 

Inventory of Roadway Elements (MIRE). This roadway inventory standard was established by 

FHWA in 2010. MIRE describes the elements needed to support advanced safety analysis using 

analytic tools such as those found in the Highway Safety Manual. More information about 

MIRE can be found at http://safety.fhwa.dot.gov/rsdp/mire.aspx. 

At a national level, the most comprehensive roadway inventory that would indicate a Tribe’s 

transportation interest in specific roadways is the NTTFI. Facilities in the NTTFI are eligible for 

expenditure of TTP funding. The NTTFI includes several data elements about each roadway. 

Traffic volumes are included, but they are incomplete for older routes and are not frequently 

updated. Unfortunately, this data does not include geospatial information necessary to conduct a 

national-level safety analysis.

Another effort that may prove useful for national-level analysis is the ARNOLD. When

completed, ARNOLD will be a complete Geographic Information System (GIS) capable network 

of all public roadways, including those on Indian Reservations, with the exception of some 

gravel roadways. The MAP-21 required the Secretary to establish a subset of the Model 

Inventory of Roadway Elements (MIRE) that is useful for the inventory of road safety under the 

Highway Safety Improvement Program (HSIP). The FHWA issued a final rule on March 15, 

2016, establishing the minimum subset of MIRE roadway data elements to be collected. This 

data could be useful in combination with NTTFI, ARNOLD, and crash data for conducting 

national, regional, and tribal safety studies. There may be opportunities for the NTTFI and 

ARNOLD data sets to be integrated. If a link is established between the data sets, then GIS-based

safety studies could focus on the roads that are of interest to Tribes. The FHWA can partner 

with the BIADOT to investigate opportunities to link these databases. 

B. Crash Data Collection Standards

The MMUCC is a guideline that presents a set of data elements that should be used for 

describing a motor vehicle crash. The MMUCC Guideline is based on two other data standards, 

American National Standard Manual on Classification of Motor Vehicle Traffic Accidents 

(ANSI) D16 (for classifying motor vehicle traffic crashes) and ANSI D20 (for promoting 

uniformity in the transmission of records between jurisdictions) (MMUCC, 4th Edition, 2012). 

The use of MMUCC data elements generates data that can be employed to make more informed 

decisions which will lead to improvements in safety at the national, State, local, and tribal levels.

States and Tribes are encouraged to adopt as many recommended MMUCC data elements as 

possible when they next update their Police Crash Report forms. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 12 of 42

Through MAP-21 implementation, all States are now required to report serious injury crashes 

using a single, national definition and coding convention titled “Suspected Serious Injury (A)” as 

defined by MMUCC 4th Edition. This is the only mandatory MMUCC data element. 

The fourth edition of the MMUCC guidelines is the most current available version. This 

standard includes 77 crash factors that should be recorded on-scene. Another ten data elements

can be derived from the on-scene information. Finally, it is recommended by MMUCC that 23 

additional data elements be obtained through linkage with other databases. 

C. Crash Data Quality

The USDOT defines the quality of crash data in six attributes: timeliness, accuracy, 

completeness, uniformity, integration, and accessibility. An assessment of an individual 

database should consider these six factors. This report will address these six items in general 

terms based on the survey responses but it is important to note that the crash data situation for 

each Tribe will be unique. Each of the six data quality attributes are defined as follows:

• Timeliness: Information should be available within a specific timeframe to allow for 

meaningful analysis of the current status of the issue under investigation (e. g., the 

number of injury crashes at a specific location within a limited timeframe). 

• Accuracy: Information within the database should be correct and reliable in describing 

the data element it purports to describe. Accuracy is typically enhanced through the 

practice of conducting consistency checks and validations on the data being entered into 

the database. 

• Completeness: Information within the database should be complete in terms of all 

reportable instances of the event/characteristic being reported and available within the 

database, and all required data elements within the record should be completed with 

appropriate responses. Completeness is also typically enhanced through the practice of 

conducting consistency checks and validations on the data being entered into the 

database. 

• Consistency/Uniformity: Information collected should be consistent among all reporting 

jurisdictions using the same reporting threshold and reporting the same information on a 

standard data collection form(s). Ideally, information will be reported using nationally 

accepted and published guidelines and standards such as the MMUCC. 

• Integration: By using common data elements, information in one database should be 

capable of being linked with information from other databases. Common examples of 

integration are the linkage of crash data with roadway linear referencing systems (maps), 

driver’s license databases, and vehicle databases. 

• Accessibility: Information within the database should be readily available to all eligible 

users of the information. Without the sharing of crash data between government entities 

it is difficult to obtain a complete data set. This is particularly true in areas where 

multiple enforcement agencies may report on crashes. (NHTSA, October 2015) (Pollack, 

Boodlal, J.Emery, & Souleyrette, 2010)
Report to Congress: Tribal Governments & Transportation Safety Data Page 13 of 42

This report finds that the quality of crash data readily available to tribal governments is generally 

poor. However, the agency which is reporting crash data greatly influences the quality of the 

data obtained. Table 1 summarizes crash data quality for the most common crash data collection 

scenarios in tribal areas. 

A tribal government may have law enforcement services provided by multiple entities. Law 

enforcement jurisdiction in tribal areas can be complex and may vary depending on road 

ownership, political boundaries, or tribal enrollment status of the individuals involved. It is 

important to understand the variety of law enforcement providers because each entity may 

handle crash data in a different manner and various agencies may report crashes to separate 

databases for any one tribal area. 

One of the determining factors for law enforcement service providers in tribal areas is the status 

of each Tribe under Public Law 83-280 (P.L. 83-280) which transfers jurisdiction over criminal 

and civil matters from the Federal Government to some State governments. This law was 

enacted in 1953 and at the time only applied to most Tribes located within five States. Since that 

time, additional Tribes have entered into P.L. 83-280 status or had a similar transfer of civil 

and/or criminal jurisdiction from Federal to State government. The P.L. 83-280currently applies 

to at least some of the Tribes in 23 of the 35 States with tribal areas. The P.L. 83-280 currently 

does not apply to any Tribes located in Wyoming, Virginia, South Dakota, Oklahoma, North 

Carolina, New Mexico, Mississippi, Michigan, Louisiana, Arizona, Nevada, and Alabama 

(Good, 2016). Traffic collisions are typically a civil matter covered under P.L. 83-280 but can 

become a criminal matter when vehicular assault, vehicular homicide, or other criminal charges 

are involved.

Although Federal jurisdiction is transferred to States by P.L. 83-280, Tribes continue to have 

concurrent jurisdiction over civil and criminal matters for tribal members. As a result Tribes in 

P.L. 83-280 States also have the authority to develop courts and law enforcement departments. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 14 of 42

Timeliness Accuracy Completeness Consistency 

Uniformity Integration Accessibility

BIA Law 

Enforcement

IMARS

narrative only

Immediate in 

IMARS; 

significant 

delay for 

State

databases

While the 

information is 

accurate it will often 

not include desired 

details; Location 

accuracy often 

difficult to ascertain. 

Does not capture all 

desired data

Standard data 

elements often 

not captured

No integration Very difficult to 

access or search

BIA Law 

Enforcement

IMARS

with DOI Crash 

Form

Immediate in 

IMARS; 

some delay 

for State

databases

Accuracy typically 

not evaluated

Completeness not 

typically evaluated

MMUCC 

Compliance

DOI crash forms 

will be linked to 

IMARS where 

additional 

information about 

an event may be 

housed. 

Not yet accessible 

but DOI project 

will add this 

capability. DOI 

intends to share 

data with FARS; 

Uncertain of 

sharing with State

databases. 

BIA Law 

Enforcement

IMARS

with State Crash 

Form

Immediate in 

IMARS; 

normal delay 

for State

databases

Accuracy typically 

not evaluated; State

may ask for 

corrections if report 

does not pass 

validation

Completeness may 

be checked if State

software is being 

used. 

MMUCC 

Compliance

Optimal use of 

IMARS because 

of full integration 

with State data; 

may include 

linkage to road 

and injury data. 

Typically 

accessible 

through State

Tribal Law 

Enforcement 

using Tribe's 

Database

Typically 

some lag due 

to supervisor 

review

Varies

Varies; standalone 

databases are often 

incomplete as they 

do not capture 

crashes reported by 

other agencies 

(State, county, city)

Varies Varies

Varies; Tribe 

typically has 

access but others 

do not. 

Tribal Law 

Enforcement 

using State

Crash Form

Typically 

some normal

lag due to 

supervisor 

review; often 

no sharing 

with State

databases

Typically supervisor 

checks completeness 

and must pass 

database validation

Typically supervisor 

checks completeness 

and must pass 

database validation

MMUCC 

Compliance

Integrated if tribe 

shares reports 

with State; use of 

State form does 

not obligate 

sharing. 

Typically 

accessible 

through State or 

tribe

State and 

County Law 

Enforcement

Typically 

some normal

lag due to 

supervisor 

review

Typically supervisor 

checks completeness 

and must pass 

database validation

Typically procedures 

in place to evaluate 

completeness but 

often willing to 

accept partially

complete reports as 

long as critical 

details are provided. 

MMUCC 

Compliance

Typically reports 

are submitted 

directly to the 

State database

Typically 

accessible 

through State

Table 1. Summary of Data Quality by Data Source
Report to Congress: Tribal Governments & Transportation Safety Data Page 15 of 42

1. Federal Bureau of Investigation (FBI)

For some Tribes in non-P.L. 83-280 States, the FBI may conduct an investigation when a crash 

appears to result in serious injury or death. When the FBI conducts an investigation, it does 

produces a detailed narrative report. However, FBI is not usually the first responder and is not 

always on scene to investigate. Thus, completing a standard crash report form would still be the 

responsibility of the other responding law enforcement agency (BIA or tribal police). This is 

similar to the way in which many State police operate. The primary crash form is completed by 

the responding officer but further investigation may be conducted by a crash reconstructionist or 

investigator and documented in a separate report. A long-standing Memorandum of 

Understanding exists between BIA-OJS and the FBI that determines which entity will generally 

be assigned an investigation. 

2. BIA Law Enforcement

Several survey respondents indicated that BIA did not share crash data with the State or Tribe 

except on a case-by-case basis for ongoing investigation or adjudication. Others report that some 

BIA Law Enforcement Services agencies are using a State crash form and submitting that 

document to both the State crash database and IMARS. 

While nationwide studies on crash data availability are limited, one study conducted on the Wind 

River reservation identified a significant lack of crash sharing between BIA Law Enforcement 

Services and the Wyoming DOT. The study determined that data was only available on six 

roads on the reservation. Further, the study shows 32 percent of the reported crashes did not 

have sufficient information to determine the crash location. (Shinstine D. S., 2013)

While crash data available from BIA-OJS may be adequate for law enforcement purposes, many 

Tribes and States have had difficulty gaining access to that data and have found the reports may 

not be of the necessary quality to be useful from the perspective of engineering and planning 

studies. The BIA law enforcement officers are required by BIA-OJS to record all incidents with 

an incident description in IMARS. 

The process for crash reporting varies from one BIA Law Enforcement agency office to 

another. There are three known practices in place: IMARS narrative only, IMARS using DOI 

Crash Report form, or IMARS using State Crash Report form. The data produced by each of 

these BIA IMARS practices differ in quality according to the six FHWA/NHTSA crash data 

quality attributes that were introduced previously. Each of the three known crash data collection 

practices utilized by BIA Law Enforcement Services will be discussed separately below.

a) IMARS Narrative Only

For some BIA Law Enforcement Services agency offices, the policy is to only complete a 

narrative incident report in IMARS. These reports contain several standard attribute fields that 

are applicable to a police report for any type of incident, with the rest of the documentation being 

purely narrative. Among the three BIA crash data collection methods examined, this is the least 

useful for safety planning purposes because there is no consistency and conclusions on crash 

trends would be very difficult to extract. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 16 of 42

Data from IMARS narratives is not available in any crash database unless another agency also 

responds and completes a report or significant post-processing is done to transfer the report to a 

crash database. It is common for BIA Law Enforcement to call on another agency, typically 

State law enforcement, to assist in investigation and reconstruction of fatal and serious injury 

crashes. This results in more complete reporting of fatal and serious injury crashes to State and 

national databases than those that are less severe (Huft, 2008). 

The Standing Rock Sioux Tribe realized the importance of sharing crash data with the North and 

South Dakota State DOTs. The BIA is the primary enforcement agency on the reservation and 

uses a different electronic crash reporting system than the States. The BIA's narrative crash 

reports in IMARS are not readily compatible with the States' Traffic and Criminal Software 

(TraCS) systems, and to release the reports, the BIA also needs an approved Freedom of 

Information Act (FOIA) request. The Tribe partnered with BIA Law Enforcement and the State

Highway Safety Offices to arrange transfer of the IMARS reports into TraCS. The process 

involved the Tribe writing a FOIA Routine Use Agreement for the release of the reports, BIA 

Law Enforcement staff printing each of those reports and releasing them to the Tribe's Traffic 

Safety Coordinator, and the Tribe's Traffic Safety Coordinator manually translating them into the 

TraCS system. The States provided the TraCS software and offer training and technical support 

to the Tribe’s Traffic Safety Coordinator. While the procedure could be more efficient, the effort 

is laudable to ensure complete crash data is then available in a format that is useful for safety 

programs and analyses. 

As stated previously, the process for crash reporting varies from one BIA agency office to 

another. The data produced by when only IMARS narrative reports are used to record crashes is 

evaluated below according to the six crash data quality attributes previously identified.

• Timeliness 

o Reports are submitted directly into IMARS when an officer completes them. The 

reports are available to BIA in IMARS almost immediately. Incidents are tracked 

from initial entry through final investigation. 

• Accuracy, Completeness, and Consistency/Uniformity. 

o The interviews and surveys completed for this report did not identify any 

procedures by which BIA IMARS narrative reports are being checked for 

accuracy or completeness. 

o When the incident is recorded only by narrative, the accuracy and completeness 

cannot be evaluated because there is a limited set of information being collected. 

In addition, it is extremely difficult to integrate narrative reports into a usable 

database format. The uniform information collected in this format usually 

includes: incident time/date, reported time/date, people involved (name, gender, 

birthday, address, driver's license number), addresses involved, vehicles involved 

(year, make, model, registration, VIN), and type of accident i.e., (property

damage only, injury, or fatality). All additional information is in the form of a 

narrative written by the reporting officer and the dispatcher. 

o The Standing Rock Sioux Tribe recently evaluated 2015 data collected by BIA 

Law Enforcement in an effort to share that data with the State of South Dakota’s 

database. The comparison between the BIA narratives and the State crash report 
Report to Congress: Tribal Governments & Transportation Safety Data Page 17 of 42

form concluded that many elements must be marked “unknown” in the State

system. 

The effort found that although officers are trying to be descriptive, they often 

leave out details that are not intuitive if the form does not prompt them. This 

includes information such as latitude/longitude, relation to roadway, intersecting 

street names, harmful event info, weather conditions, light conditions, road 

conditions, driver behaviors, occupant protection use, and other data elements that 

would be captured on a MMUCC compliant crash form. 

• Integration 

o No integration currently exists between the BIA IMARS narrative reports and any 

other data sets. 

• Accessibility

o According to the surveys and interviews that were conducted, crash data collected 

by the DOI is generally not accessible by other organizations or can only be 

obtained after following an arduous process. This topic is discussed further later 

in this report. 

o Narrative reports are filed using general categories that do not serve well when 

trying to retrieve data. The BIA provided 2014 crash data from IMARS where 

each individual event was categorized by either crash severity or contributing 

factor, not both. For example, one crash might be categorized as "Accident 

investigation – Injury” while the next is categorized with no mention of severity 

as “Accident Investigation – DWI.”

b) IMARS using DOI Crash Form

The IMARS recently added the ability to collect uniform 

crash criteria using the DOI Investigator’s Traffic Crash 

Report form (herein “DOI Crash Report”). A copy of this 

form is included as Appendix A. Although the DOI crash 

report can be used, it is not mandatory for all BIA law 

enforcement officers. Some agency offices are requiring 

officers to use the report while others are not. A coding guide 

for the form was not immediately available, but the crash 

criteria being collected appear to be at least partially 

compliant with MMUCC standards. 

Below is an evaluation of the data produced by the DOI Crash 

Reports according to the six crash data quality attributes 

previously identified. 

• Timeliness 

o Reports are available in IMARS immediately 

after being completed by an officer. 

• Accuracy

o The interviews and surveys completed for this report did not identify any 

procedures by which DOI crash reports were checked for accuracy. A guidebook 

or training could be developed to assist officers in understanding the intended use 

of the crash form. 

Figure 2. DOI Investigator’s Traffic Crash 

Report Form (see Appendix A)
Report to Congress: Tribal Governments & Transportation Safety Data Page 18 of 42

• Completeness

o All fields are optional on the form. However, use of the form is anticipated to 

produce much more complete descriptions of the incidents than the narrative 

method previously described because the officer is being prompted to report on 

uniform crash criteria. 

o The report does allow for a narrative description of the incident and the creation 

of a crash diagram. 

• Consistency/Uniformity

o The DOI crash form uses uniform crash criteria that are substantially compliant 

with the MMUCC standard. This should result in some uniformity between State

data and BIA data. However, when different forms are used by different agencies,

the result can be that the same criteria is interpreted differently when it is intended to 

collect the same uniform data. The continued use of State crash report forms may be 

preferable to the DOI crash form and States may be able to write software that 

provides regular updates to the DOI database if that is desired. 

• Integration 

o The DOI crash form is not integrated with other data sets such as driver, vehicle, 

or linear referencing systems.

• Accessibility

o Crash data collected by the DOI is generally not readily accessible by other 

organizations. This topic is discussed further later in this report. 

o The BIA-OJS indicated that no database is currently available which would 

assemble the uniform data fields from all crash reports into a tabular format. 

o The BIA-OJS also indicated that no integration between the DOI crash report 

form and state crash databases currently exists.

o Institutional barriers and staff availability to retrieve crash data may still need to 

be addressed to permit timely sharing of crash data with Tribes and States.

c) IMARS using State crash form

Some BIA Law Enforcement Services agency offices complete a State crash report form and 

then simply upload an electronic copy as an attachment to their entry in IMARS. Using this 

approach to crash data collection allows the BIA to share crash data with the State database 

while simultaneously fulfilling the requirement to report in IMARS. This approach currently 

results in the highest quality crash data collection by BIA Law Enforcement. 

It is unclear if this method of crash data collection will continue to be allowed or if all BIA Law 

Enforcement Services Agencies will be required to transition to using the DOI crash form.

At this time, this is the best practice available for the collection and sharing of crash data by BIA 

Law Enforcement in a way that is available for safety studies. 

Finally, the data that is produced when BIA Law Enforcement officers use a State crash form is 

evaluated below according to the six crash data quality attributes that were previously identified. 

• Timeliness 

o As with the other IMARS methods, the data is available immediately in IMARS.

If State crash forms are being provided to the State then normal delay would 

occur in validating or entering the information into the State database. Additional 
Report to Congress: Tribal Governments & Transportation Safety Data Page 19 of 42

delay can occur if the State rejects a report or requests clarification due to 

incompleteness or validation issues. 

• Accuracy

o Typically BIA officers submit their data to IMARS without supervisory review.

However, State DOTs have completeness and data validation procedures in place 

to ensure that the crash reports contain sufficient and logical information. 

• Completeness

o As mentioned there are benefits of the State database checking for completeness 

of the required fields on individual reports. In addition, the use of the State crash 

form enables the statewide databases to be complete with reports from all law 

enforcement entities. 

• Consistency/Uniformity

o All State crash forms collect crash criteria that are at least partially compliant with 

MMUCC. When all reporting law enforcement agencies use the same form, there 

are additional enhancements to the consistency. 

• Integration

o Integration with other data sources (such as driver’s licenses, vehicle databases, 

and linear referencing) should typically be available if BIA Law Enforcement

officers are able to use the State’s crash reporting software. For example, many 

State electronic crash reporting systems are integrated with a mapping solution 

that allows precise identification of crash locations and may even aide in the 

development of a crash diagram. In some instances, BIA Law Enforcement 

Services agency offices have been unable to benefit from integrated State

software due to information technology security protocols. 

• Accessibility

o All 18 State governments that responded to a survey question asking about tribal 

access to crash data in the statewide database indicated that there is a process by 

which Tribes can obtain data from the statewide database. Some States also 

indicated that they have analysis tools which Tribes could use. Some of these are 

computer systems that the Tribe can access directly via a website or software.

Others require a written request be sent to the State. In some cases, automated 

reports can be generated for Tribes from a State database on a regular, reoccurring 

basis. Tribes with BIA Law Enforcement that are using the State crash report 

form should be able to obtain crash statistics for the tribal area from the State

crash database or BIA. 

3. Tribal Police

Tribal governments most commonly establish police departments through a self-determination 

contract (Public Law 93-638) with BIA-OJS. Others in law enforcement are employed directly 

by the Tribe. Tribes create police departments for many different reasons and in some cases the 

responsibilities of these officers do not cover motor vehicle crashes. However, many tribal

police departments do respond to and report on motor vehicle crashes. The methods used by 

Tribes to collect crash data vary greatly. The observations below are the results of the survey 

that was conducted for this project. This does not necessarily represent all tribal police 

departments. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 20 of 42

Seventy-two of the responses to the survey indicated that the responding Tribe had a tribal law 

enforcement department. Of these, 63 percent indicated that they do not share crash reports with 

the State DOT. Some respondents indicated that crash reports are only shared with the State

when the crash occurs on a State-owned road. 

Some tribal police departments indicated that they do not have a crash reconstructionist on staff 

and rely on other law enforcement agencies (typically State police) to conduct the crash 

investigation when a fatality or serious injury occurs. This can result in higher severity crashes 

being more likely to be reported to statewide databases than lesser severity crashes. Several 

Tribes further indicated that they intend to train officers in crash reconstruction so that all crash 

investigations could be handled in-house. 

Tribal police may have limited authority for various reasons. In the optimal situation, law 

enforcement officers are cross-deputized with tribal, State and county law enforcement which 

provides the authority to also enforce State and local laws. In addition, a cross-deputized officer 

can take action with traffic law violators regardless of tribal membership or reservation 

boundaries, and may be able to more readily utilize State crash reporting systems. Several 

survey participants indicated that tribal and BIA police are unable to enforce traffic law 

violations with individuals who are not members of a Tribe. One tribal police department 

provided this comment: “[Tribal police are] not allowed to pursue offenders beyond the 

reservation boundaries. Offenders know this now and run recklessly and at high speeds for the

reservation line.”

Tribal police departments are not required to share crash data with any other government and 

often avoid sharing data due to a variety of concerns which are addressed later in this report. 

The result is that the State and national databases which drive policy, program, and project

decisions are incomplete in tribal areas. Without complete data sets, it is difficult for State and 

Federal programs to make informed decisions about programs and projects which have the

potential to improve transportation safety for tribal governments. State-managed Federal

funding sources, such as the Highway Safety Improvement Program (HSIP), require a datadriven process be followed to identify programs and projects to be implemented. The HSIP 

specifically requires the inclusion of tribal roads in the data-driven process. However, if crash 

data is not shared with the State, then safety data in analyzed tribal areas inaccurately appear to 

have the safest roads in the State and therefore may be overlooked when program and project 

decisions are made. 

One example of crash data not being shared occurs on the Salt River Indian Reservation in 

Arizona. The Salt River Police Department collects all crash data unless the incident occurs on a 

State-owned roadway. The Salt River Police Department does not share crash data with the State

of Arizona. A comparison of fatal crash dates and locations between FARS and data provided 

by tribal police confirmed that between 2010 and 2014, six fatal crashes occurred on the 

reservation that were not recorded in FARS. 

Similar significant under-reporting of fatal crashes occurred on the Colville Indian Reservation 

in Washington. A study looked at fatal crash locations between 2007 and 2013 to determine 

completeness of crash reporting on the reservation. Sixteen fatal crash sites were identified by 
Report to Congress: Tribal Governments & Transportation Safety Data Page 21 of 42

the study, with six of those fatal crash sites being undocumented in FARS, State, and tribal 

police crash databases. Interviews were conducted with the families of the crash victims to 

obtain an understanding of what occurred in these six cases and to confirm that the crashes 

occurred during the study time period. (Amundson, 2015)

As a third example, from 2011 to 2013 the Rosebud Sioux Tribe Law Enforcement Services 

recorded 421 injuries and 18 fatalities from motor vehicle crashes. During the same time period,

the South Dakota DPS database shows 12 injuries and one fatality resulting from motor vehicle 

crashes. These differences in data highlight the lack of data sharing that is occurring between the 

Tribe and the State of South Dakota. (KLJ, 2014)

As done previously with other sources of crash data, the following is an evaluation of crash data 

collected by tribal police according to the six FHWA/NHTSA data quality attributes.

• Timeliness

o Crash data can be available in a database as soon as an investigation has 

concluded. 

o Some tribal governments have a supervisor review or data entry process that must 

be completed before their crash reports are entered into a database. 

o For Tribes that have opted to use software provided by State governments, the 

availability of crash reports can be delayed if a report is returned to a Tribe 

because it is incomplete. 

o Some Tribes do not utilize any type of crash report database. 

• Accuracy

o Tribes were asked about the training provided to officers on crash reporting. The 

majority of Tribes indicated that basic training had occurred through a police 

academy, on the job training, or regular trainings regarding completing the State

crash form. Some Tribes have officers who have received advanced training in 

crash reconstruction, while several other Tribes indicated an interest in training 

their officers in crash reconstruction. In many cases, State law enforcement is 

called when a crash involving serious injury or fatalities occurs. In these cases

the Tribe usually does not have a crash reconstructionist on staff to handle the 

investigation. The level of crash investigation training can influence the accuracy 

with which crash forms are completed. 

o Tribes were asked if a process was in place to evaluate the accuracy and 

completeness of crash data in the crash database. While 45 percent of the Tribes 

with police departments responded that they were uncertain on this question,

another 38 percent indicated that some method was in place. 

o In addition, for the Tribes that share crash data with State governments, the crash

report often undergoes additional checks for completeness and accuracy. 

Eighteen States indicated that a data quality process was in place for the State

crash database. Most States indicated that reports submitted to their database 

undergo a validation check to ensure that critical fields are completed and that the 

coded information passes logical tests. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 22 of 42

• Completeness

o Survey responses indicated that 70 percent of the respondents with tribal police 

departments had a policy in place for supervisors to review crash reports to ensure 

all data elements were completed. 

• Consistency/Uniformity

o In some cases (20 percent of survey respondents) no crash report form is used and 

a narrative incident report is completed in the same fashion as would be done to 

document any other law enforcement incident. 

o Many Tribes (80 percent of survey respondents) are using a partially MMUCC 

compliant crash report form that is the same or similar to the crash report used by 

a State law enforcement agency. 

• Integration

o Tribes were not surveyed on integration with other data sets. It is known from the 

State survey responses that Tribes using electronic State crash reporting systems 

are able to take advantage of integration with other data sources such as driver 

licensing databases, vehicle records, and linear referencing systems (maps). 

• Accessibility

o A question was asked on the survey “Does your Tribe share crash data with the 

State?” In nearly equal proportions, Tribes indicated that they share no data, 

share all data, or share some data with a State. (42 percent do not share, 20

percent share some data, and 38 percent share all crash reports). Common 

barriers to crash data sharing are covered later in this report. 

o Another study conducted in 2015 found that only 25 percent of the participating 

Tribes shared crash data with a State agency. (Noyce, 2015)

o Tribes that are sharing only some data indicated that crash data sharing occurs in 

one of two situations. The first is when a State or county road is involved. The 

second is when a crash appears to be a serious injury or fatal crash and an expert 

crash reconstructionist is needed. 

o Tribes that share all crash reports may still redact some portions of the report such 

as enforcement action and personal identifiers. 

4. State and County Law Enforcement

State or county law enforcement are sometimes responding to crashes in tribal areas either as a 

routine part of their duties, because a crash occurred on a State or county roadway, or when

invited by BIA or tribal law enforcement to participate in an investigation of a crash that appears 

to be resulting in serious injury or fatality. 

All State governments have a central database where crash reports are housed. In most cases,

county law enforcement follows the crash reporting procedures established by the State. All of 

the States that responded to survey questions about crash data collection indicated that county 

law enforcement reports to the statewide crash database. This report assumes that county law 

enforcement crash reporting is similar to the State procedures. 

As done previously with other sources of crash data, the following is an evaluation of crash data 

collected by State and County Law Enforcement according to the six FHWA/NHTSA data 

quality attributes.
Report to Congress: Tribal Governments & Transportation Safety Data Page 23 of 42

• Timeliness 

o During the survey, most States indicated there was a policy in place which sets a 

timeframe for the submission of crash reports but that there is no penalty for late 

reports. The timeframe varied from 24 hours to 30 days. The most common 

policy is to have crash reports submitted within 10 days of the incident. 

• Accuracy

o State law enforcement agencies typically have an officer trained in advanced 

crash reconstruction and also conduct regular refresher training on crash reporting 

for all officers. 

o All States responding to the survey indicated that quality assurance and quality 

control procedures are in place to ensure the accuracy and completeness of crash 

reports. 

• Completeness

o Many States indicated that their officers are using crash reports which require 

critical fields to be completed, thereby ensuring at least a minimum level of 

completeness. 

o In some States, reports are not recorded in the statewide database when they occur 

in tribal areas, but are instead treated as if the crash occurred on private property. 

• Consistency/Uniformity

o All States have a crash report that prompts officers to complete uniform crash 

criteria fields that are at least partially compliant with MMUCC. 

• Integration

o Although not specifically reviewed by the survey some States did volunteer 

information indicating that their crash reporting software is integrated with 

driver’s licensing databases, vehicle records, or linear referencing systems (maps). 

• Accessibility

o Most States indicated on the survey that there was a process by which tribal 

governments (and other governments) could request crash data from the statewide 

database. In some cases, there is software available that a tribe could obtain to 

view crash data. In other cases, State crash data is available on a public website 

with personal identifiers removed. No matter the procedure, in all cases there is a 

process by which a Tribe could obtain crash data reported by State police for the 

tribal area. 

In California, a P.L. 83-280 State, absent a specific contract or request, the California Highway 

Patrol (CHP) investigates collisions on Federal tribal lands only if the collision occurs on State

or county maintained roadways within Federal territorial boundaries. Collisions occurring on

State or county maintained roadways on Federal tribal lands are classified by CHP policy as 

reportable and subject to regular collision reporting requirements. Collisions occurring on 

federally maintained roadways are classified as non-reportable collisions and are not subject to 

regular collision reporting requirements. 

When non-reportable collisions are investigated, the Primary Collision Factor is coded as Other 

Improper Driving unless the driver is under the influence of alcohol or drugs. A solution to this 

gap in collision data will soon be deployed whereby CHP Commanders will consult with each 

tribal government and offer to document future collisions through a formal traffic collision 
Report to Congress: Tribal Governments & Transportation Safety Data Page 24 of 42

report. Data generated from collisions occurring on federally maintained roadways would be 

collected and archived by the CHP and separated for future discretionary use. Non-reportable 

collision data would be stored in a CHP database and not forwarded to the Department of Motor 

Vehicles for administrative purposes. 

Alaska is also a P.L. 83-280 State where motor vehicle crash response is a concurrent 

responsibility of the State. However, the vast roadway network and sparsely populated areas 

present challenges for law enforcement coverage by the Alaska State Troopers. A Road Safety 

Audit of Alaska’s Elliott Highway that was conducted in 2013 identified through a public 

meeting that the community was aware of a fatal crash site which was not documented in the 

statewide crash database. It is unknown how many other motor vehicle crashes go unreported in 

Alaska. In addition, many Alaska Native villages face unique transportation safety issues related 

to winter trail, board road, marine, and ice road travel for which data collection systems do not 

currently exist on a statewide basis. 

VII. Crash Data Collection and Sharing: Barriers and Opportunities

In the previous section there are several references to the sharing of crash data with statewide 

crash databases. All of the States that responded to the survey indicated that a process was 

available whereby tribal and BIA law enforcement could share data with the statewide database. 

However, as stated previously, in many cases tribal police and BIA law enforcement do not share 

crash reports with the State. Without high quality crash data collection and analysis, it is 

difficult to determine the most effective projects and programs to implement and even more 

difficult to acquire funding for these activities.

The Gila River Indian Community of the Gila River Reservation developed a transportation 

safety plan in 2014 and has established a crash data sharing process. Because crash data has 

been shared with the State of Arizona, Gila River’s planning efforts were able to benefit from a 

detailed data analysis performed by Arizona DOT at no cost. The data analysis helped the Tribe 

determine the crash factors that should be addressed by the plan (Gila River Indian Community 

Department of Transportation, 2014).

Despite the benefits of crash data sharing, there are several barriers that were identified by Tribes 

and States which inhibit the sharing of crash data between some Tribes and States. These 

barriers include tribal-state communication, resources required to collect and share crash data, 

and Federal policy for crash reports. 

A. Paperless Data Collection Options & Best Practices for Tribes

There are a variety of options for paperless reporting of crash data. Various software packages 

offer the ability to submit crash reports electronically from mobile or desktop computers to a 

central database. In many cases, these software packages may be available from a State agency 

under a statewide license that allows use by all law enforcement entities within a particular State

at no software cost to a Tribe. 

For some Tribes, electronic crash reporting may not be practical if there are a low number of 

crashes occurring on a small roadway network. This data is still critical to collect, but the 

method must be appropriately scaled for each situation. In cases where elaborate electronic 
Report to Congress: Tribal Governments & Transportation Safety Data Page 25 of 42

crash reporting systems are not practical, it may be possible to coordinate with a State

government to complete paper crash report forms, submit them to the State, and then obtain the 

crash data electronically from the State at a later date. This can have the added benefit of 

obtaining crash information from the State database which was entered by law enforcement 

entities other than tribal police. 

The specific solution that a Tribe should select depends on a number of factors. Tribes interested 

in improving crash data collection and/or sharing is encouraged to develop an action plan using 

the self-assessment method described in NCHRP Report 788. The action plan can then guide the 

process, assist in establishing communication with safety partners such as State and local 

governments, and be a basis for requesting funding assistance from the grant sources identified 

later in this report. The guide can currently be found at 

http://onlinepubs.trb.org/onlinepubs/nchrp/nchrp_rpt_788.pdf

Some electronic crash report collection software allows the user to perform various data analysis 

tasks with relative ease. Many statewide databases have these analysis capabilities built-in and 

the tools are often freely available to the governments who are reporting data using these 

electronic solutions.

Arizona is making efforts to have all law enforcement agencies send crash data electronically to 

the State. The State has purchased access to the TraCS software that they can share with all law 

enforcement agencies within the State of Arizona. The software is available to governments at 

no cost. Use of the TraCS Program software does require the tribal and local law enforcement to 

cover costs for computer hardware and staffing capacity to oversee management of the crash data 

collection and sharing processes before it is transferred to the State database. Although complete 

reports are preferred, tribal governments and local agencies can redact personal identifier 

information from their crash reports. To help in this effort, the Arizona DOT Traffic Records 

Section developed a template of the State crash report form that highlights the data elements 

(less personal identifiers) that represent the minimum data that a report must contain so that it 

can go into the State database. 

Similarly, Nevada is implementing a new electronic crash reporting system known as Brazos. 

The State has a five-year plan to make the system available to all law enforcement agencies in 

the State. Tribes will be invited to use and share their data as part of the new system. The State

is planning to provide all required hardware and software but will consider prioritizing those 

enforcement agencies that offer to purchase their own computer hardware. One Tribe has 

already been successfully set up in the new electronic crash reporting system. This Tribe has 

agreed to share all crash data with the State and has the ability to use analysis tools available in 

the State system. 

Currently, Tribes may opt to develop their own crash report databases and not share the 

information with other governments. In these cases, it is still advantageous to collect MMUCC 

compliant crash data because the data elements that are collected ensure high quality data that 

can be used by the Tribe for a variety of reasons. In addition, for a complete picture of the crash 

history, the Tribe may need to combine its data with crash information from overlapping 
Report to Congress: Tribal Governments & Transportation Safety Data Page 26 of 42

jurisdictions. This is most readily accomplished when both agencies are collecting the same set 

of standardized data elements. 

When a solution for electronic crash reporting is chosen by a Tribe, the following factors may be 

evaluated: 

• Accessibility for combining with State and local data – both for sharing and analysis.

• Ability to query all crash data in a tabular format.

• Ability to pull individual reports at the Tribe.

• Ability to redact data elements before sharing, if desired.

• Consideration of staff time to manage database.

• Availability of training opportunities.

• Ability to record data offline if connectivity is an anticipated issue.

• Collection of standardized data elements (consider MMUCC standard).

• Diagraming capabilities for officer’s in-field.

• Quality control capabilities that allow supervisor review and logical validation (for 

example, if rain is present and pavement cannot be dry).

• Analysis capabilities.

B. Tribe-State Communication

The most common reason provided by Tribes and States to explain why crash data is not shared 

is tribal sovereignty. As sovereign nations, tribal governments are not required to share crash 

data with State government agencies. However, many tribes have found ways to ensure tribal 

sovereignty is respected while still benefiting from the sharing of crash data. While tribal 

sovereignty allows Tribes to choose what data they are willing to share, the reasons for not 

sharing crash data are often more complex than asserting tribal sovereignty. Instead, several 

survey participants indicated that sovereign status is used to prevent sharing of crash data 

because of a lack of communication about how the data will be stored and used, concerns about 

privacy and adjudication for tribal members, and uncertainty in how the Tribe can benefit when 

crash data is shared. 

These barriers can be addressed if Tribes and States better establish two-way communication 

about transportation safety and crash data improvements. These discussions can start at the staff 

level with tribal employees and State employees assessing the current situation and determining 

what future improvements would be beneficial. Then the State government employees could be 

invited by tribal staff to speak with leadership about their concerns and the benefits of crash data 

sharing. 

Several Tribes who do share crash data with the State indicated that personal identifiers and 

citation/conviction information is redacted from crash reports before they are provided to the 

State. Several States identified that communication with tribal governments has resulted in 

modification of policies such that personal identifiers, citations, and conviction information are 

not shared. Other States indicated that redacted reports could be received if communication 

occurred identifying the barrier. The survey response from one State indicated:

“This [State agency] will accept any electronic [crash data] from any tribal agency because the 

information is critical to people’s well-being and safety.”
Report to Congress: Tribal Governments & Transportation Safety Data Page 27 of 42

Through communication, additional concerns that Tribes may have about the sharing, storage, 

and use of crash data can be identified and incorporated into Memorandums of Agreement. For 

crash analyses that are critical to safety planners, program managers, and project engineers, it is 

not critical to identify individuals involved in crashes but rather to understand the factors which 

contribute to the occurrence of crashes. 

As part of the communication with tribal leadership, it is imperative that the benefits of sharing 

crash data be conveyed. Some of these benefits include: 

• State-provided crash data analyses to support the Tribe’s safety plans, projects, and 

programs.

• Availability of information to support tribal grant applications.

• Enabling the State to include tribal areas in funding programs that require datadriven decisions such as the federally funded Highway Safety Improvement 

Program.

• Improved ability to retrieve reports when attempting to recover damages to tribal 

property.

• Acquiring assistance from the State in analyzing crash contributing factors and 

problem locations.

• More effectively identifying and addressing transportation safety issues.

• Enabling the generation of regular reports to tribal council on crash trends.

• Crash report quality control and data validation procedures established in the State

reporting software and database.

• Inclusion in complex statewide analyses.

One tribal DOT in Arizona worked with the local council of governments to compare crash data

available from tribal law enforcement with the statewide database. Upon realizing how 

incomplete the statewide database was for the reservation, the tribal DOT began conversations 

with tribal leadership and the State to improve the sharing of crash data collected by tribal law 

enforcement. As a result, the tribal DOT is now implementing several million dollars of grants 

(from the State-managed Federal program known as High Risk Rural Roads) in cooperation with 

the State DOT to address critical safety needs on the reservation with the expectation that fatal 

and serious crashes will be reduced significantly in coming years. 

Also, strategic planning efforts for 2016, the Washington Traffic Safety Commission’s Tribal 

Traffic Safety Advisory Board determined its number one priority was improving data in Indian 

Country. As a result, the Advisory Board produced a 10-minute video, Recording Our Past, 

Protecting Our Future, which encourages tribal data collection and sharing: 

http://wtsc.wa.gov/programs-priorities/tribes/ or 

https://www.youtube.com/watch?v=VDrTQNLH2-g . Another project was the establishment of 

a Work Group, comprised of tribal and State representatives, to make contractual and technology 

changes to Washington’s electronic ticketing and crash reporting system that will meet the 

Tribes’ needs regarding sovereignty issues. Additionally, this prioritization of tribal data in 

Washington led to a significant expansion in the “Tribes and Target Zero” chapter of Target 

Zero®, Washington’s Strategic Highway Safety Plan. The chapter update, led by tribal 

representatives, has one of Target Zero’s more complex data schemas. (FHWA, 2016)
Report to Congress: Tribal Governments & Transportation Safety Data Page 28 of 42

In addition, Tribe-State communication in Wisconsin has been effective at changing the way in 

which Tribes are asked to share data with the State. Tribes now provide crash data to a third 

party, the University of Wisconsin. The university purges personal identifiers from the crash 

data before sending it to the statewide database. This provides additional separation between the 

raw crash data and the statewide databases. This additional separation adds assurance that State

agencies cannot use the personal identifiers contained within the raw crash data in a negative 

way. 

States are now required to collect and submit performance measure information to FHWA on: 

number of motor vehicle crash-related serious injuries and fatalities; and serious injuries and 

fatalities per vehicle miles traveled (VMT); and number of fatalities serious and injuries of nonmotorized users. A final rule was published in the Federal Register on March 15, 2016, that

requires States to establish and report on annual targets for each performance measure. States

that do not meet or make significant progress toward meeting their targets must develop an 

implementation plan and must use a specified amount of HSIP funding only for HSIP projects. 

The rule also requires all States to report serious injuries using a single, national definition and 

coding convention: “Suspected Serious Injury (A)” as defined in the MMUCC 4th Edition. The 

key to States establishing safety performance targets is for stakeholders to work together to share 

data, review strategies and understand outcomes. States are encouraged to communicate with 

BIA and Tribes regarding efforts to improve the collection and reporting of fatality and serious 

injury data as well as efforts to improve data sharing. By working with BIA and Tribes, State

DOTs can include BIA and tribal efforts in their considerations when establishing data-driven 

safety performance targets. The FHWA will work with State governments so they collaborate 

with BIA and Tribes and consider the impact of data that was not previously recorded in FARS 

and statewide data systems when establishing performance targets. 

USDOT action will also be taken to encourage State governments to initiate or continue 

discussions with tribal governments concerning crash data sharing. The Traffic Records 

Coordinating Committees (TRCCs) are the NHTSA-led teams review State safety data on a 

regular basis (usually every 5 years or as requested by States). These reviews follow the 

Procedures Manual for State Traffic Records Assessments which contains 391 questions used to 

evaluate the safety databases of a State government. The manual does not contain any 

information about tribal governments and does not include assessment of tribal records (NHTSA, 

October 2015). The manual does mention local governments and individual States may have 

included Tribes in their assessment following the sections of the manual about local 

governments.

While Tribes are sovereign nations and public authorities they are not local governments. The 

Procedures Manual for State Traffic Records Assessments is expected to be updated in 2017 and 

the NHTSA will add consideration for tribal governments including evaluation of

communication between the State and Tribal governments concerning traffic records. 

C. Tribal Law Enforcement

Tribal law enforcement is encouraged to collect crash data using a crash report form with 

uniform crash criteria based on the MMUCC standard. In addition, Tribal law enforcement is 
Report to Congress: Tribal Governments & Transportation Safety Data Page 29 of 42

encouraged to share crash data with State crash databases directly or via a national 

clearinghouse, if established. 

Because Tribes are sovereign nations and not sub-units of State governments, some Tribes may 

reject sharing crash data, even if personal identifiers are redacted, with State governments.

When discussing traffic records improvements, FHWA and BIA OJS could discuss 

establishment of a national crash data clearinghouse which would give Tribes the option of 

reporting crash data to the clearinghouse in lieu of reporting to State crash databases. Similar to 

the arrangement in Wisconsin (see previous section), any crashes submitted to this national 

clearinghouse would be shared on a regular basis with State governments and FARS after 

personal identifiers and citation information were removed. 

D. Resources for Crash Data Collection and Sharing

Once a tribal government has made the decision to share crash data, additional challenges may 

need to be addressed. These may include: 

• Cost of software and hardware to collect electronic crash data. 

• Cost of hiring staff to oversee crash data collection, management, and sharing. 

• Inconsistency in crash report forms among tribal, county and State law enforcement. 

There are several funding sources where Tribes may obtain the necessary equipment, software, 

and staff to collect and share crash data. Funding opportunities for crash data improvements are

addressed later in this report. In addition, many States indicated that they would provide 

software and, in some cases, hardware to Tribes in support of crash data collection. 

The MMUCC standard for crash data collection is described later in this report. Tribes are 

encouraged to review this standard when revising their police crash report forms and to consider 

the data elements being collected by enforcement agencies with overlapping jurisdiction. 

Developing a crash form that contains the MMUCC elements will help to facilitate safety 

analyses by planners and engineers as well as crash data sharing. 

One State provided this anecdotal information: “Unfortunately, tribal law enforcement may be 

using crash report forms that are not consistent with the State crash report form and they may often 

provide data in narrative format versus a codified format. Due to the time required to 

decipher/transfer that type of data into the database, not to mention the potential for error in 

transferring the information, the State may not be able to accept certain reports. ”

E. BIA Crash Data Sharing

The crash data collected by and shared with State governments is critical to effective 

management of Federal funding programs which could benefit tribal areas. Many comments 

were received from States about the difficulty of obtaining crash data from DOI. The DOI-10 

Privacy Act Statement for IMARS does allow sharing of crash data for “routine use” or under a 

FOIA request as long as personal identifiers are removed. However, even when “routine use 

agreements” have been established it can be very difficult to obtain the crash reports from BIA 

Law enforcement offices mainly due to staff availability to produce the reports. The survey 

received numerous statements from States and Tribes demonstrating that the lack of crash data 
Report to Congress: Tribal Governments & Transportation Safety Data Page 30 of 42

sharing from BIA Law Enforcement has been detrimental to Federal, State, and Tribal 

transportation safety programs. The following are direct quotes from the survey (redacted for 

privacy): 

• From a State DOT: We have been unsuccessful in getting ... crash data that is 

managed and documented by the BIA. . . . For [one Tribe the State DOT] has 

requested [BIA] crash data to assist in support of seeking a traffic signal warrant ... 

The Tribe has been unable to provide tribal crash data to [the State DOT]. 

• From a State DOT: [Tribes] want to do this [share crash data] but have been limited 

by the BIA. 

• From a tribal DOT: Our local [BIA] office, for example, is very short-staffed, so even 

though we have this [routine use agreement] in place, it is sometimes hard to get 

printed copies of reports in a timely manner. 

• From a tribal DOT: Tribe does not have access to any crash data gathered by BIA 

Law Enforcement Services. 

• From a tribal DOT: BIA crash data should include the same information as the 

[State] system does, and redacted data should be exported to other agencies on a 

monthly basis. 

• From a State governor’s highway safety office: A huge sore point for FARS analysts 

is the low level to zero cooperation we receive from the FBI, BIA officers, and 

national park rangers. FARS is owned by a Federal agency and, it’s infuriating that 

Federal law enforcement agencies refuse to give us crash reports. FARS analysts 

have to submit FOIA requests and eventually received heavily redacted reports. 

For Tribes that have crash data collected by BIA Law Enforcement Services, the barriers to crash 

data accessibility are different than with tribal police departments. Communication is 

encouraged between BIA Law Enforcement Services, affected Tribes, and the State to arrange 

crash data sharing. In some cases the BIA, Office of Justice Services, Operations Directorate 

may need to be involved to assist with arranging crash data sharing agreements. 

A few barriers to crash data sharing were identified which may be resolved through clarifications 

of existing policy or BIA Office of Justice Services policy changes. The issues identified were 

information technology policies at DOI, inconsistent crash reporting policy, variations in 

interpretation of the Privacy Act, and staffing levels. 

One barrier to the sharing of BIA crash data is the use of only narrative reports to collect crash 

information instead of using a crash report form with uniform crash criteria recorded for each 

crash. When crash data is received by States from the DOI, it is often in this narrative format 

and may not include enough information to be entered into the State database. 

The information technology (IT) barriers primarily pertain to the use of State crash data 

collection software on Federal Government computers. Current BIA IT policy prevents the use 

of State crash reporting software on Federal Government computers. Use of State crash 

reporting software can have many benefits for database integration, crash data sharing, and 

safety data analysis.
Report to Congress: Tribal Governments & Transportation Safety Data Page 31 of 42

Another identified barrier is that the interpretation of the Privacy Act requirements seems to 

differ from one BIA Law Enforcement Agency office to the next. In some cases, Tribes and 

States reported that BIA Law Enforcement has interpreted current policy to mean that they may 

not share crash data with tribal governments for planning purposes. In other cases, including the 

interpretation of the Operations Directorate at BIA-OJS, routine use agreements can be 

established between the BIA and Tribes or States. These agreements enable the sharing of crash 

data without personally identifying information on a regular basis. The collection of crash data 

on a standard crash form, such as the DOI crash form or State crash reporting software, would 

enable BIA-OJS to more readily provide the desired crash data and more quickly redact personal 

identifiers. 

Finally, staffing levels at many BIA Law Enforcement Services offices are low. The retrieval of 

crash reports may not be a priority for staff because of the multitude of other issues that law 

enforcement must address on a daily basis. Here again, use of State or DOI crash forms could 

enable staff at a State or central DOI office to address all crash data requests. 

F. Tribal Transportation Safety Grants

The FHWA Tribal Transportation Program Safety Funds, available for federally recognized 

tribal governments to improve transportation safety, will continue to accept applications based 

on any form of safety data. However, applicants using data other than police crash reports will 

now be encouraged to provide a plan showing how the applicant will achieve higher quality data 

for the future. The process described in National Cooperative Highway Research Program 

(NCHRP) 788 is one method Tribes could use to assess traffic records. Other options for 

assessing traffic records may be available by contacting the appropriate NHTSA region.

In 2001, a series of traffic records assessments were conducted at four reservations by the 

NHTSA Technical Assessment Team using a procedure similar to that used when assessing State

traffic records. Each of those assessments produced a document that the Tribe could use to work 

toward higher quality safety data sets. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 32 of 42

VIII. Uses of crash data

In general, complete and accurate data are needed to raise awareness about the magnitude of road 

traffic injuries, and to convince policy makers to support interventions that effectively address 

the highest priority needs for action. Reliable and accurate data are also needed to correctly 

identify problems, risk factors, and priority areas, and to formulate strategy, set targets, and 

monitor performance. Ongoing, data-led diagnosis and management of the leading road traffic 

injury problems enables appropriate action and resource allocation. Without complete data on 

where crashes are occurring and the factors contributing to the crash causation, we cannot be 

sure that investments to improve roadway engineering, enforcement, emergency medical 

services, and driver education are being applied where they will have the greatest impact. 

Without being able to analyze the causes of crashes, we cannot be sure that well-intended 

improvements in policy or public education programs will actually address the root of the

problem. In other words, without better use of data, there will be no significant sustainable 

reductions in exposure to crash risk or in the severity of crashes. 

Data relevant to road safety are collected every day in most countries, but for this data to be 

useful for informing road safety practices, it must be properly coded, processed, and analyzed in 

a computerized database system. (World Health Organization, 2010) In addition, there is a need 

for more capacity-building for data collection, data sharing, and data analysis at the tribal and 

local (county) level. In fact, the highest-quality crash data is typically found at the local level. 

Since this is the site of the original crash location and typically a local investigator takes the 

report, firsthand knowledge of the crash area and details are known and familiarity with the 

circumstances improves the ability to provide valuable intervention strategies. However, the 

agency that provides emergency response or does law enforcement may not be well connected 

with the agency with primary responsibility for improving the roads. In that case, there will be a 

gap between collecting the data and responding to it. 

The information flow may not be working if another government is the emergency responder, or 

even between units inside a government. Tribes should seek to improve their access to crash 

data and improve and use the databases maintained by their departments and departments of the 

State(s) where they are located prior to seeking information from national databases as this 

firsthand knowledge provides for a more accurate evaluation of the problem. It also provides the 

autonomy to institute policies and programs at the grass roots level which allows any actions 

taken to be culturally and situationally appropriate and tested locally. The national databases are 

necessary but should be more useful in national-level studies and policymaking than for safety 

analysis by any one Tribe. 

An illustration comes from a survey response from a Tribe in Arizona. It affirms the value of 

good data analysis for cost-effective interventions, but also points to the need for staff training 

and support:

“[The Tribe] in the past has not used crash data in this manner, because road 

maintenance was the responsibility of the BIA. [The Tribe], through the Office of Grants 

and Contracts (A 638 Program), has now developed a Strategic Safety Plan (SSP) and 

integrated the SSP in the [Long Range Transportation Plan] () Plan and update. We 

understand the importance of not just collecting crash data, but analyzing that data and 
Report to Congress: Tribal Governments & Transportation Safety Data Page 33 of 42

targeting crash reduction strategies. Doing all of these things costs money and time. 

Staffing and knowledge in these areas needs to be developed within all tribal 

governments and the appropriate funding levels to accomplish these goals needs to be 

made available.”

Road safety related data are used by a variety of stakeholders –law enforcement, transportation

departments, health facilities, and insurance companies – as well as policymakers and 

transportation planners. Reliable data can be important in making traffic injuries a priority issue. 

This data can also be used to make the general public more aware of changes in behavior that 

will improve their safety. Road traffic crash data are crucial to identifying risks, developing 

strategies and interventions to address those risks, and evaluating the impact of interventions. 

Analysis of complete and accurate crash data is extremely effective in providing strategies for 

the reduction of needless roadway crash fatalities and injuries. The following “data use” 

categories provide a summary but are not to be considered totally comprehensive. 

A. Enforcement / Adjudication / Legislation

1. Adjudication & Insurance Companies

The most obvious use of crash reports is for adjudication for parties involved in an individual 

incident. Police, courts, insurance companies, and the involved parties all depend on an accurate 

account of the event in a police crash report. 

2. Targeting Law Enforcement Strategies

Some law enforcement agencies conduct regular review of crash data. These reviews enable a 

focus of efforts in traffic safety enforcement to address any trending problems (i.e., speeding, 

drinking and driving, driver distraction, and seat belt usage) and to locate enforcement activities 

in the needed areas. 

3. Legislation

Data is needed that can identify the causes and magnitude of road traffic crashes and assist in 

prioritizing remedial action. This is particularly relevant in relation to risk factors that can be 

reduced by legislation and its enforcement (i.e. distracted driving, impaired driving, speeding, 

motorcycle helmet usage, seat belts, and child restraint usage). 

B. Funding and Resource Allocation 

1. Safety Planning and Allocation of Resources

Crash data can be used to identify trends in the factors involved in transportation crashes. Many 

State and Tribal governments have used this information to develop transportation safety plans. 

These plans help to forge partnerships between departments and focus on common goals. At the 

time of this writing, the FHWA has provided funding through the Tribal Transportation Program 

Safety Fund to over 50 percent of federally recognized Tribes to develop safety plans and has 

published a toolkit to assist tribes in the development of safety plans at 

https://flh.fhwa.dot.gov/programs/ttp/safety/stsp-toolkit.htm. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 34 of 42

Also, some governments develop partnerships between departments where a regular report on 

transportation safety trends is developed and distributed for leadership review and action. These 

transportation safety reports are commonly distributed to leadership, law enforcement, 

transportation, and injury prevention departments. Often these reports must aggregate data for 

three to five years to avoid over-emphasis on a topic based on the occurrence of a single event. 

2. Grant Applications

Most transportation safety funding opportunities offered by Federal and State governments to 

tribal governments and local public agencies require crash data to justify any funding request. 

The typical information required for an infrastructure improvement project is site-specific crash 

data detailing the types of collisions that have occurred at the site and any contributing factors 

that can be derived from the police crash reports. Applications for behavior modification 

projects (law enforcement, education, and etc.) need to show trends in crash data contributing 

factors from year-to-year. These data needs are easily fulfilled when all of the crash data is in 

one uniform format or database. However, these data needs become complex quickly when 

multiple databases are used by various law enforcement agencies. 

In many cases, the required crash data is found in police reports which are available in a 

statewide database. One notable exception is the TTP Safety Fund which encourages eligible 

applicants to justify their funding requests using the best available data, to include first responder 

call logs or citizen testimony about past incidents. 

C. Promotion and Coordination

1. Communication with Leadership

A well-functioning safety management system will involve regular updates on transportation 

safety trends. Such reports are typically aligned with a transportation safety plan to track 

performance measures that are identified by the plan. These leadership reports also establish 

some accountability among the various departments that are charged with implementation of a 

transportation safety plan. 

2. Communication with other Governments

Adequate crash data in a useable database also allows communication among all stakeholders. 

The first way that this communication occurs is when statewide assessments of crash data are 

conducted in support of data-driven safety programs such as the Highway Safety Improvement 

Program and the NHTSA programs. These assessments identify high-risk locations and trends in 

comparison with all other areas in a State. When crash data is collected by tribal or BIA Law 

Enforcement and not shared with the State, the result is that the tribal governments are at a 

disadvantage for statewide assessments. 

The second form of communication that can occur with good crash data is the development of 

data-driven transportation safety plans by tribal governments. These plans establish a means of 

communication with State and local governments about the priorities of the tribal government. 

This written form of communication by the Tribe establishes a need that is adequately 

documented based on crash data and can now be considered by State and local governments as 
Report to Congress: Tribal Governments & Transportation Safety Data Page 35 of 42

they program resources. The FHWA strongly encourages tribal governments to develop 

transportation safety plans. Funding and a toolkit for developing safety plans are available 

through the Tribal Transportation Program in the FHWA Office of Federal Lands Highway

(FLH). 

3. Public Advocacy Campaigns

An aware and informed public can better request responses from the appropriate government

entity. Advocacy campaigns can also influence widespread beliefs and attitudes that affect 

people’s behavior on the road. For example, data collected from Minnesota about key roadway 

safety risks on reservations indicates that front-line law enforcement officers are extremely 

concerned about texting and other cell phone use by drivers, which suggests this, is a priority for 

public advocacy in the area (Narváez & Quick, 2016). Advocacy and awareness campaigns can 

address public misconceptions, such as the belief that it is less important to use seat-belts when 

travelling in rear seats in cars. Campaigns that accompany the introduction of new laws and 

policies can enhance their effectiveness. 

D. Research and Development

1. TRB Subcommittee on Tribal Transportation

One of the many institutions that use crash data to conduct research is the Transportation 

Research Board (TRB). As with any research, the quality of available data influences the quality 

of the end product. The TRB committee on tribal transportation is aware of several research 

topics that will be proposed for 2017 including: 

• Accuracy and completeness of race data in FARS.

• Effectiveness of driver education tribal communities.

• Human factors and tribal transportation safety.

• Traffic codes in tribal areas.

2. Vehicle Safety Standards

Federal Motor Vehicle Safety Standards set minimum performance requirements for those parts 

of the vehicle that most affect its safe operation (brakes, tires, and lighting) or that protect drivers 

and passengers from death or serious injury in the event of a crash (air bags, safety belts, child 

restraints, energy absorbing steering columns, and motorcycle helmets). These Federal standards 

are applicable to all vehicles and vehicle-related equipment manufactured or imported for sale in 

the United States (including U.S. territories) and certified for use on public roads and highways 

(NHTSA, 2011). 

3. Roadway Design and Traffic Engineering

Crash data can help to identify hazardous routes and road design problems. When partnered with 

the use of a GIS, crash data analysis can be especially effective in achieving visible, short term 

results. Network screening and the systemic safety approach are two examples of crash data 

analyses that require the availability of crash data (FHWA, 2014). 

Crash data is also used by engineers when designing or evaluating a specific section of roadway. 

Crash reports can help the engineer understand how drivers are interacting with the roadway. 

Crash data may also play a role in determining if a roadway design will vary from standards. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 36 of 42

4. Driver Training and Testing

Many driver training programs have begun or are being enhanced following the review of crash 

data. These reviews can uncover trends which can assist in enhancing training and testing for 

not only the general population of drivers but also can target specific groups of drivers. 

E. Safety Improvement with Limited Crash Data

Safety measures can be implemented without the availability of formal crash data. However, the 

effectiveness of safety decision-making processes is greatly enhanced when crash data is 

available and is considered. Several methods that have been used to identify safety 

improvements when crash data is inadequate or unavailable are summarized in this section. 

When Tribes submit grant applications for safety improvements, it may be beneficial to 

demonstrate to the funding agency that efforts are underway to improve crash data in the future. 

1. Road Safety Audits

A Road Safety Audit (RSA) is the formal safety performance examination of an existing or 

future road or intersection by an independent, multidisciplinary team. It qualitatively estimates 

and reports on potential road safety issues and identifies opportunities for improvements in 

safety for all road users. The FHWA works with State and local jurisdictions and tribal 

governments to integrate RSAs into the project development process for new roads and 

intersections, and also encourages RSAs on existing roads and intersections. 

2. Systemic Safety Improvement

The systemic approach to safety involves widely implemented improvements based on high-risk 

roadway features correlated with specific severe crash types. The approach provides a more 

comprehensive method for safety planning and implementation that supplements and 

compliments traditional site analysis. It helps agencies broaden their traffic safety efforts and 

consider risk as well as crash history when identifying where to make low cost safety 

improvements. 

While the systemic approach is most effective when implemented with good crash data, it is 

possible to infer high-risk roadway features based on the experience in nearby jurisdictions that 

do have adequate crash data. 

3. Other Sources of Crash Data

In its simplest form, a surrogate for crash data is the concept that a substitution for lack of actual 

crash data can be made to assist with an analysis of possible crash causes. Some suggest that 

these alternative data sources can also provide insights when good quality crash data is available 

(Jovanis, 2011). Crash data surrogates are a way to assess a situation to give another perspective 

on the problem at hand but it should not be used as the primary means of analysis over actual 

crash data, when it is available. 

The lack of crash data in a tribal area should not prevent a Tribe from beginning safety planning.

Safety plans that are developed in the absence of formal incident data should include an 

assessment of the available data and actions that will lead to improved data availability. As 

previously identified, one option for Tribes to conduct crash data assessment is by using the 
Report to Congress: Tribal Governments & Transportation Safety Data Page 37 of 42

process described in NCHRP Report 788: Guide for Effective Tribal Crash Reporting. Some 

Tribes have successfully started safety plan development using alternative sources of data. 

Alternative data sources can provide new views into the problem. It was mentioned above that 

road safety related data are used by a variety of stakeholders –law enforcement, transportation

departments, health facilities, and insurance companies – as well as policymakers and 

practitioners. Conversely, these stakeholders are also often invaluable, highly informed sources 

of new kinds of data that may reveal important safety risks that do not turn up in traditional crash 

reports. For example, the TTAP Circuit Safety Riders and injury prevention coordinators have 

information about safety restraint usage. Finally, brief social science surveys of residents at 

major community events can provide information about key areas of concern for pedestrians, 

children, and other vulnerable populations. The additional kinds of data mentioned above are 

robust and compelling, provided they are carefully collected (Narváez & Quick, 2016). 

The University of Wyoming’s Local Technical Assistance Program has developed a method for 

assessing roadway risk by evaluating the roadway features where crash data may be limited. The 

method has been deployed with several counties in Wyoming and at the Wind River Indian 

Reservation. This five-step process involves analyzing any data that is available, conducting 

field assessments of roadways, determining risks, countermeasure identification, and benefit-cost 

analysis. This process allowed recommendations for safety improvements on roadways where 

crash data was not available by inferring that the risks found on similar county roadways where 

data was available (Shinstine D. , 2014). 

Another Tribe used traffic citations to determine some of the most common behavioral risks 

(speeding, DUI, driving without a license). The Tribe now focuses its efforts in those areas until 

better data is available. This Tribe is also conducting an observational seat belt study and has

plans to conduct a qualitative roadway safety study. 

Other Tribes indicated that they have utilized citizen’s reports or surveys as well as the 

observations of staff such as maintenance and transit drivers to help inform the Tribe’s safety 

planning efforts. In some cases information on crashes was collected from the public and staff

by asking them to mark locations of risks and undocumented crashes using large maps. 

Some efforts have been made to use injury data collected by hospitals and clinics or the Indian 

Health Service to inform decision making related to transportation safety (Ragland, 2016). If 

this is the best available data or if the data is linked with crash reports, there is potential benefit 

of using this data. There is some concern over the validity of hospital/clinic data since it is selfreported by the injured party. An individual may claim their injury was caused by a vehicle 

crash to avoid legal ramifications of the actual event which caused the injury. Also, injury data 

typically does not record much information about the location or factors contributing to a crash. 

Where crash reports are scarce, some Tribes have successfully acquired grant funding using 

records from the Emergency Medical Services (EMS) provider. While EMS reports would help 

to document where crashes occur, they are unlikely to record contributing factors information 

since the EMS personnel must focus on treating the injured parties instead of determining the 

reasons why a crash occurred. The EMS personnel could make injured parties aware of the self-
Report to Congress: Tribal Governments & Transportation Safety Data Page 38 of 42

reporting requirements established by State governments although these duties would not be high 

on their priority list. In some States, it may be possible for EMS personnel to file the State report 

that is intended for parties involved in a crash where law enforcement does not respond. High 

quality crash records would establish a relationship between crash reports and EMS or injury 

reports. Further research could investigate the possibility of using injury data, especially the 

reports completed by EMS personnel, to provide more complete data coverage for injuries and 

fatalities caused by motor vehicle crashes in tribal and rural areas. 

IX. Funding for Improving Crash Data Collection

Several funding programs are available from which Tribes may obtain funding to implement 

improved electronic crash data systems. These budgetary resources are available from the DOT, 

the DOI, and the DOJ. 

A. TTP and TTP Safety Fund (23 U.S.C 202(e))

The Tribal Transportation Program is a formula-driven program that is available to federally 

recognized Tribes to assist in the construction, operation, and maintenance of facilities that have 

been accepted into the National Tribal Transportation Facility Inventory (NTTFI). Eligible 

activities for expenditure of TTP funds include all items eligible for the TTP Safety Funds

(TTPSF) and more. 

Each year under the FAST Act, 2 percent of the available TTP funds are set aside to address 

transportation safety issues through a competitive, discretionary grant program. Awarded 

annually, projects are chosen where outcomes will address the prevention and reduction of death 

or serious injuries in transportation related crashes. The TTP Safety Fund recognizes that traffic 

fatalities and injuries severely impact the quality of life in tribal areas. Statistics are consistently 

higher than the rest of the nation as a whole; they advocate the development of Strategic 

Transportation Safety Plans as a means for Tribes to determine how transportation safety needs 

will be addressed in tribal communities. 

It is the policy of the TTPSF that crash data improvements result in a system that allows the 

sharing of information on fatal crashes for the purposes of inclusion in the FARS, but these 

projects are only encouraged to share lesser severity crashes (FHWA-FLH). 

Projects eligible for the TTP Safety Fund are safety planning, infrastructure improvements, and 

safety data improvement projects as described in 23 U.S.C. 148(a)(4). Additional information 

about the TTPSF can be found at https://flh.fhwa.dot.gov/programs/ttp/safety/ttpsf.htm.

B. HSIP (23 U.S.C 148)

The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users 

(SAFETEA-LU), which was signed into law on August 10, 2005, (Public Law 109-59) 

established the HSIP as a core Federal-aid program administered by State DOTs. The overall 

purpose of this program is to achieve a significant reduction in traffic fatalities and serious 

injuries on all public roads through the implementation of infrastructure-related highway safety 

improvements. The SAFETEA-LU established extensive new resources and opportunities to 
Report to Congress: Tribal Governments & Transportation Safety Data Page 39 of 42

advance highway safety throughout the country in a comprehensive, strategic manner. The HSIP 

has continued with some modifications through MAP-21 and the FAST Act. Core requirements 

for the HSIP are that projects be data driven and consistent with the State’s Strategic Highway 

Safety Plan (SHSP) which is to be developed in partnership with State, tribal, and local entities. 

The requirements for the HSIP are codified in 23 U.S.C 148. Crash data improvements are an 

eligible item under 23 U.S.C 148. 

C. BIA Indian Highway Safety Program (23 U.S.C 402)

The Highway Safety Act of 1966, 23 USC 402, provides USDOT funding to assist federally 

recognized Tribes with implementation of traffic safety projects, including crash data 

improvement, in tribal areas of the United States. The program is administered by the BIA 

Indian Highway Safety Program (IHSP) under an agreement with NHTSA. 

D. State Administered NHTSA Highway Safety Plan Funding (23 USC 402 and 

405(c))

The State Highway Safety Program, commonly referred to as Section 402, was initially 

authorized by the Highway Safety Act of 1966 and has been reauthorized and amended a number 

of times, including most recently under the FAST Act. 

Section 402 supports State highway safety programs, designed to reduce traffic crashes and 

resulting deaths, injuries, and property damage. Section 405(c) supports the development and 

implementation of effective State programs that evaluate or improve safety data quality. A State

may use these grant funds only for highway safety purposes; at least 40 percent of these funds 

are to be used by or for the benefit of tribal governments and political subdivisions of the State to 

address local traffic safety problems. States are required to provide a 20 percent match for this 

funding. The program is administered by NHTSA at the Federal level and by the State highway 

safety offices at the State level. Crash data improvements are eligible under 23 U.S.C 402 and 

405(c). 

E. DOJ Coordinated Tribal Assistance Solicitation (CTAS)

Through the CTAS, federally recognized Tribes and tribal consortia are able to submit a single 

application for most of DOJ’s tribal grant programs. The DOJ designed this comprehensive 

approach to save time and resources and allow Tribes and DOJ to gain a better understanding of 

the Tribes’ overall public safety needs. The first coordinated tribal grant process was launched 

in FY 2010, through the collaborative efforts across many department components, bureaus, and 

offices. Tribal police could propose a CTAS project intended to improve records management 

systems, including electronic crash data reporting. Additional information can currently be 

found at http://cops.usdoj.gov/Default. asp?Item=2489
Report to Congress: Tribal Governments & Transportation Safety Data Page 40 of 42

X. Methodology

This report was developed by FHWA’s, FLH office. The Tribal Transportation Safety 

Management System Steering Committee (SMS Steering Committee) assisted in the 

development and distribution of a survey to support this project. The SMS Steering Committee 

was further involved in review and compilation of the final report. The SMS Steering 

Committee consists of representatives from four Tribes (Northern Cheyenne Tribe of the 

Northern Cheyenne Indian Reservation; the Zuni Tribe of the Zuni Reservation; the Karuk Tribe;

and the Cherokee Nation); a consortium of Tribes (the Association of Village Council 

Presidents); BIA Division of Transportation; FHWA-FLH; FHWA, Office of Safety; FHWA 

Resource Center; BIA Office of Justice Services Indian Highway Safety Program, Centers for 

Disease Control, Indian Health Service; NHTSA; BIA Indian Highway Safety Program; and,

Tribal Technical Assistance Centers. Although not a member of the SMS Steering Committee,

the DOJ’s Office of Tribal Justice was also involved in the development and review of this 

report. 

The OMB approval was obtained to conduct the survey under the Paperwork Reduction Act 

document control number 2125-0649. Tribal and State government officials were asked to 

respond to a set of survey questions asking about their crash data collection, sharing, and use. 

The survey was made available through a web-based form, an email questionnaire, and by 

inviting tribes to call FHWA’s TTP. Responses were received that represented 152 tribal 

governments and were primarily from tribal police, BIA Law Enforcement, and tribal 

departments of transportation. Also, 22 State governments responded to the survey. In addition, 

interviews were conducted with BIA-OJS Operations Directorate, the Federal Bureau of 

Investigation, and State government officials. 

All questions were optional so the total number of Tribes or States responding to any given 

survey question does fluctuate where the results are documented throughout this report. 

Although the surveys and interviews are the primary source of information for this report the 

authors also reviewed existing literature about tribal governments and crash data. Limited 

research has been conducted pertaining to crash records available to tribal governments on a 

national scale. However, some statewide studies have broached the topic. 
Report to Congress: Tribal Governments & Transportation Safety Data Page 41 of 42

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