engineers have suggested that motorcycles are too few, and will remain too few, to justify any special accommodation or legislative consideration, such as lane splitting. Unless it becomes likely that a very large number of Americans will switch to motorcycles, they will offer no measurable congestion relief, even with lane splitting. Rather, laws and infrastructure should merely incorporate motorcycles into normal traffic with minimal disruption and risk to riders. Potentially, lane splitting can lead to road rage on the part of drivers, who feel frustrated that the motorcyclists are able to filter through the traffic jam. However, the Hurt Report indicates that, "Deliberate hostile action by a motorist against a motorcycle rider is a rare accident cause." Lane splitting is not recommended for beginning motorcyclists, and riders who do not practice it in their home area are strongly cautioned that it can be risky if they attempt it when traveling to a jurisdiction where it is allowed. Similarly, for drivers new to places where it is done, it can be startling and scary. Responsibility and liability issues Another consideration is that lane splitting in the United States, even where legal, can possibly leave the rider legally responsible. According to J.L. Matthews in How to Win Your Personal Injury Claim: When the 2005 bill to legalize lane splitting in Washington State was defeated, a Washington State Patrol spokesman testified in opposition, saying that, "it would be difficult to set and enforce standards for appropriate speeds and conditions for lane splitting." He also said that officials with the California Highway Patrol told him that they wished they had never begun allowing the practice. the California Highway Patrol has lane splitting tips on their website. Similar guidelines were posted by the California Department of Motor Vehicles, but those guidelines were subsequently removed. Safety aspects California's DMV handbook for motorcycles advises caution regarding lane splitting: "Vehicles and motorcycles each need a full lane to operate safely and riding between rows of stopped or moving vehicles in the same lane can leave you vulnerable. A vehicle could turn suddenly or change lanes, a door could open, or a hand could come out the window." The Oxford Systematics report commissioned by VicRoads, the traffic regulating authority in Victoria, Australia, found that for motorcycles filtering through stationary traffic "[n]o examples have yet been located where such filtering has been the cause of an incident." In the United