Application of Behavior Change Theory to the Development

DISCUSSION
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BEHAVIOR CHANGE THEORY
Fifty years of traffic safety research has established the efficacy and efficiency of
exploiting the power of language to regulate the behaviors of negligent drivers
(Campbell, 1959; Kaestner, et al., 1965; McBride & Peck, 1970; Epperson & Harano, 1975
and, Jones, 1997).
Although traffic safety researchers have been identifying components necessary, if not
sufficient, for an effective warning letter (Campbell, 1959; Kaestner et al., 1965; McBride
& Peck, 1970; Epperson & Harano, 1975; Ayers, 1980; Li, 1980; and, Jones, 1997) for a
half century, Hayes’ (1969) comment about warning letter improvement being an art,
not a science, is apparently still true today. The important contributions of the
aforementioned researchers notwithstanding, the positive traffic safety results
associated with warning letters arguably result from strong research designs and, to a
lesser degree, official contact from a regulatory agency, not from the specific contents of
the letter.
McBride & Peck (1970) and Jones (1997) demonstrated the potential that warning letters
promise under controlled conditions but institutionalized negligent operator treatment
and evaluation systems operate quite differently. In California, the Negligent Operator
Treatment and Evaluation System (NOTES) was fortunate to have been managed by a
top echelon researcher who designed an experimental research protocol that included
randomization, no-contact controls, and temporality. From 1985 to 1995, Marsh
demonstrated the cost effectiveness of the NOTES program in spite of the fact that the
contents of many warning letters were weak and the issuance of new warning letters
with different contents was not coordinated with the research agenda (Appendix A-6).
In a quasi-experimental environment, strong treatment letters and control over changes
in and issuance of warning letters will become paramount considerations.
The contents of past warning letters used in NOTES were changed quite frequently, at
times more than once per year. Individual negligent drivers within one study period
may have received one of six or more different warning letters issued over the subject
selection period. Nevertheless, the strength of the research design was usually
sufficient to detect differences due to the official contact made by the Department of
Motor Vehicles with the negligent driver. Unfortunately, it is impossible to tease-out
the effects associated with the individual letters.
Regrettably, California’s NOTES program was terminated in November 1994 after the
Department of Motor Vehicles ended the use of untreated control groups, thereby
eliminating the ability to conduct rigorous experimental research (Marsh & Healey,
1995). Researchers felt that under this policy NOTES quality would be compromised to
such an unacceptable extent that research results could become unreliable.
In 2001, an effort began to look critically at the content of warning letters to determine
the feasibility of developing a method both to evaluate the relative strength of a broad
sample of warning letters and to identify a method to strengthen their effectiveness.
More powerful treatments were thought to be an essential component of an enhanced
negligent operator treatment and evaluation system (ENOTES) that would need to be
operationalized in a quasi-experimental environment.