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(O'Toole claims that intercity buses are far safer than rail, calculating that bus services see only 0.3 fatalities per
billion passenger-miles to Amtrak's 1.4 fatalities per billion passenger miles. However, these figures drastically
overstate the number of bus passenger miles traveled while minimizing the number of bus fatalities incurred to
arrive at an incorrectly low fatality rate. Complicating this picture is the absence of a universal definition of "intercity bus." The source
O'Toole cites for intercity bus fatalities uses the relatively narrow definition provided by the National Highway Traffic Safety Administration's
Fatality Analysis Reporting System, which considers only those buses making cross country or intercity journeys. Even this modest figure is
known to severely undercount the number of fatalities incurred by this small category of buses. To count passenger
miles, O'Toole uses the American Bus Association's 2005 Motorcoach Census, which counts passenger-miles
logged by intracity...
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