TMC Call to Action - Make Your Comments Re: EV Noisemakers - NOW (please)!

I'm torn on the noise issue myself. I don't like noise, it causes problems of its own, and it is rarely needed.

That said, tomsax went to a conference where blind people described how they used it, and it did seem extremely useful to them (I think he posted info on that in these forums, although it was quite a while ago). Plus existing noisemakers are pretty darn unobtrusive, especially from inside the cabin.

So I didn't comment on whether or not there should be noise. I just noted that if quiet cars are a problem, then any rules should apply to quiet cars. There is no sense to applying a noise rule by powertrain. Some luxury ICEs are extremely quiet, and some EVs have loud fans and such.

I commented on the regulation website.

We need less noise pollution not more. This solution is nothing more than a symptom of an arms race to be the loudest...

I commented too. Adding noise to electric vehicles is adversely going to impact sales when the administration's stated goal is to increase sales. I also said we need less noise pollution as opposed to more, especially in areas where cars move at low speeds, such as rush hour traffic and the inner city.

I commented against.

I agreed with Bonnie: ALL cars must have the same noisemakers.

If that were the case, the bill would be dead in the water. All large premium quiet ICE car makers and owners would squawk.

I just scanned over the attached PDF. It was a presentation from mid last year with some charts outlining how loud and of what type the sounds should be.

So we're commenting on a 6-8 month old presentation. The presentation indicates the noisemaking is a foregone conclusion.

The proposed standard, Federal Motor Vehicle Safety Standard No. 141, would fulfill Congress' mandate in the Pedestrian Safety Enhancement Act that hybrid and electric vehicles meet minimum sound requirements so that pedestrians are able to detect the presence, direction and location of these vehicles when they are operating at low speeds.

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The comments being solicited are for what reason? Are constructive comments simply to specify what kinds of noises are required?

Maybe if we all simply asked that the noises be defeat-able; IE something that one could turn off.

I also commented against.

I'd be curious to know what Tesla has up their sleeve related to this. Clearly, there must be some R&D going on. If anyone can come up with a clever, organic solution, it would be Tesla. I would even consider some aural feedback inside the Model S —driver adjustable— to give better sense of speed when driving at higher velocities.

I submitted a comment. Here's what I wrote:

I do not agree that cars operating under electric power should be singled out to have artificial noise required outside the vehicle. The proposal is intended to ensure that quiet cars are heard at slow speeds. In most circumstances, internal combustion engines are just as quiet as a car under electric power at slow speeds, especially when coasting (i.e., when the gas pedal isn't pressed). So either all cars should have these noise requirements, or none, but it makes no sense to have EVs singled out in this way.

At slow speeds, the most noise created by any normal car are from the tires on the road, not the engine. Please reconsider the proposed rule because it unfairly burdens cars running on electric power when we should be making it as easy as possible for such cars to be purchased and to become more prevalent on the road.

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After reading and researching, I am even more upset with our federal government. I now wish the sequestration was larger.
http://www.nhtsa.gov/staticfiles/rulemaking/pdf/Quiet_Cars_Draft_EA.pdf
This 114 page Environmental Assessment was enacted by our congress.
It is to further the Pedestrian Safety Enhancement Act of 2010.
http://www.gpo.gov/fdsys/pkg/PLAW-111publ373/pdf/PLAW-111publ373.pdf
The bill’s sponsor was Sen John Kerry and was signed by Obama in January 2011. It authorized the NHTSA to spend $2,000,000 to study the laws impact.
The bills main purpose is to
“(1) establishing performance requirements for an alert sound that allows blind and other pedestrians to reasonably detect a nearby electric or hybrid vehicle operating below the cross-over speed, if any; and
(2) requiring new electric or hybrid vehicles to provide an alert sound conforming to the requirements of the motor vehicle safety standard established under this subsection.”


But really this was a make-work project for the NHTSA. They said so on page 17 of the EA.

“NHTSA issued a report in October 2009 entitled “Research on Quieter Cars and the Safety of Blind Pedestrians, A Report to Congress” (NHTSA 2009). The report briefly discussed the issue of vehicle noise and implications for pedestrians, how NHTSA’s research plan addressed the issue, and the agency’s progress on implementing the research plan. In an effort to evaluate the problem of EV and HV crashes with pedestrians, NHTSA examined the incidence rates for crashes involving hybrid-electric vehicles and pedestrians under different circumstances, using data from 12 states, and compared the results to those for ICE vehicles (Hanna 2009). This study, while based on a relatively small sample size, found an increased rate of accidents involving pedestrians with hybrid-electric vehicles compared to their peer ICE vehicles.”

“NHTSA’s research determined that when operating under all conditions, such vehicles are 1.19 times more likely to be involved in a collision with a pedestrian than an ICE vehicle and 1.44 times more likely to be involved in a collision with a pedalcyclist.”


That’s all the data needed for why it’s being implemented. The rest of the report is a study on implementation and its effects.

Here are my comments

If there should be a sound specification on a vehicle because its lack of noise is a safety issue, then that sound specification should apply to any vehicle that is a safety issue on those grounds. There would be a lot of vehicles manufactured today that are just as quiet at 8-10 mph as an electric vehicle. It concerns me that a regulatory authority would single out one power-train. The issue I have is that the data you have to support this is in itself biased. All vehicles that are powered by an electric motor at low speeds are quiet. Some vehicles powered by petrol are comparably quiet, but all all. So when you measuring one subset against another you will get a statistical difference, whether you are just measuring noise or the incidence of collisions with pedestrians or cyclists.

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In Italy there are still no rules on this matter. My idea is, since both EV and ICE cars are very quite at low speed, to implement on ALL cars an artificial generated noise that can be switched on by the driver.
It shouldn't be like a honk but a nice sound warning the pedestrians that a car is getting close. Best thing would be that this artificial generated noise would be the same all over the world.

How about all white canes have a transponder. All cars sense this if within X distance and make an appropriate sound. Transponders available separately to those needing tham.

When I read the rulemaking announcement the first thing that came to my mind was a parking garage or major intersection with dozens of noisemakers of all kinds making their miscellaneous noises at the same time. It seems that it would be difficult to determine the source of the noises and the direction that they were coming from rendering the noisemakers a useless nuisance.

When I read the study behind the rulemaking I really was not convinced that a noisemaker on a vehicle was the best answer to the issue. I am not convinced that their "answer" would have an impact on the number of incidents either. Is the number of events that are reported are statistically significant enough to be accurately attributed solely Hybrid and EV's low noise levels? If it is, then is it a temporary rise due to a learning curve because there is a lack of awareness that quieter vehicles are on the road? Is this something that public education or a PSA could handle?

I am cognizant of the fact that pedestrians and the sight impaired are not yet familiar with the sounds made from vehicles that do not have loud starters or engines so I use extra care when navigating pedestrian areas and make sure that they look at my car’s movement or make eye contact. That just makes sense. If they have ear buds in, a phone in hand, proceed without hesitation or look the other way, I just wait.

With more quiet vehicles on the road it seems that not only will our hearing become more keen, but our mental noise filters will learn and adapt as well. I almost got hit by a bicycle travelling at high speed when they started to hit the streets all of a sudden. Now I am aware that I need to look out for them as well. But do they need noisemakers too? What agency governs them?

To top it off my ICE car was just as quiet when the engine was running as my Model S is.

In the end I see this as a knee jerk response or quick patch to soothe or quell concerns. I do not think that it is the right answer to the concerns at hand.

Thanks for listening and responding to the NHTSA's rule.

Thumper said:

How about all white canes have a transponder. All cars sense this if within X distance and make an appropriate sound. Transponders available separately to those needing tham.

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Better to equip all quiet cars below a set db with a transmitter. Blind people would carry a vibrating warning device.

The same bogus hysteria that spawned the proposal that all horseless carriages have a person walking in front waving a red flag. (I always heard it 'small boy', but that is sexist & sizeist!). Unfair to donkey carts also.

My S is non-tech-pkg but I would assume any tech pkg worth its salt would include a mic input on dash & outdoor PA speaker. For such free-speech occasions like approaching group of tailgaters: "You're all under arrest!!". Or when shopper is sashaying down parking lane in front of you: "Ok lardass, sometime today". You know, that personal touch so often missing in our day to day existence.
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