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Proposed Minimum Sound Requirement Rule for Hybrids and EVs - Please comment

Proposed Minimum Sound Requirement Rule for Hybrids and EVs - Please comment

Here are is the article published by the NHTSA about their rule proposal for noisemakers on Hybrids and EV's. The proposal was sent for publication in the Federal Register yesterday. After publication in the Federal Register there is a 60 day public comment period. You will find a link to the proposal at the bottom of the article. Instructions for submitting comments are in the document.

http://www.nhtsa.gov/About+NHTSA/Press+Releases/DOT+Proposes+New+Minimum...

I would encourage thoughtful comments on this proposal. Personally, I think that the requirements are excessive and I am not convinced that it will have any impact at all on their safety goals. I think that constant noisemaking at speeds of 18 mph and below will just add to the problem by increasing ambient noise and confusion making it even more difficult to identify moving Hybrids and EV's.

I think that they can do much better.

andrigtmiller | 8 janvier 2013

They should just leave it alone. We don't need more regulations. It's just going to make the cars more expensive (it may be small, but all these things add up over time), and probably won't do anything for public safety. When I drive around my neighborhood most of the people have head phones on. They don't hear ICE cars either.

Captain_Zap | 8 janvier 2013

Please submit a comment by using the instructions in the rule proposal. Public comments are taken into consideration can make a difference. That is our only hope at this stage of the game.

stevenmaifert | 8 janvier 2013

Another example of our government fixing a non-problem. If regulators feel they must do something, then require EVs & Hybrids be equipped with a short range transponder that will trigger an alert in an earpiece worn by anyone who feels they are at risk. No more noise please! Captain_Zap - Thanks for the heads up. I will send them a comment.

welockett | 8 janvier 2013

The Docket Number of this proposed rule is: NHTSA-2011-0148

The rule is 248 pages long and it appears compliance would begin on 1 Sep 2015, if the final rule is published on 4 January 2014. It has a three year phase in period and would apply to vehicles manufactured on or after 1 Sep 2015. I haven't found any requirement to retrofit early manufacturee vehicles yet.

I would agree @andrigtmiller, most folks I see these days have ear buds in and they wouldn't hear the car noise anyway, but I do understand the concern for visually impaired individuals that do rely heavily on their hearing as teh get about.

I would encourage EV users to read the proposed rule, and provide thoughtful and specific comments. Your comments can make the rule requirements much more useful for all parties affected.

Sudre_ | 8 janvier 2013

I have already written an email to my Senator about house retarded this is. They will require ONLY automobiles with electric drive only under 18mph to make a noise of the manufactures choice. How wrong can that be.

I've was hit /clipped twice last year while walking trails in Castlewood park by rude bicyclers zipping along trails. I don't think there should be a law but they are far more dangerous since they are in places where pedestrians frequently walk and many time going faster than 18 mph.

I live in the city and already find the large amount of noise to be annoying at times. When I get up at 6am it is usualy nice and quiet. People driving their ICE cars at 5-10mph down the alley behind my house can slip off to work without waking anyone up. Soon legally some brat who wants to be a jerk will get up and drive his EV around with his own custom sound, "BEEP BEEP BEEP" or whatever. OR the cop with an attitude will pull over EV driver and write them applification tickets during noise curfew time which my city has. Don't say they won't one guy in CA already got a ticket for no muffler. This is going to be a nightmare.

Lets add to that every single car can have it's own custome noise maker. They will probably set a db limit. Now when I sit out on my back porch instead of just drowning out the car engine noise which I am used to I will have to wear ear plugs because it will spund like the Las Vegas strip everywhere. . . just a little queiter.

DouglasR | 8 janvier 2013

Note that this rule is pursuant to a statute passed by Congress; it was not something initiated by NHTSA. If you want to modify the proposed rule, submit a comment to NHTSA. If you want NO rule, don't comment to NHTSA; write to your congressperson.

JZ13 | 8 janvier 2013

We need facts before we can form an educated opinion. How many documented incidents are there of a pedestrian being injured by an EV or hybrid due to the lack of sound from the car? If I had to guess it is a minute number. And if that is the case, then this regulation would be unwarranted.

DouglasR | 8 janvier 2013

Read the long PDF that is on the NHTSA site (and that I linked in the other thread on this subject). The studies are described there.

JZ13 | 8 janvier 2013

Can you summarize?

Anthony H | 8 janvier 2013

(Reposting)
If the current Model S doesn't have an external speaker, this is all moot. (Not mute.)

Elon commented on this; when asked when the car will emit a noise, he replied something to the effect of, "Not until the government makes us."

GoTeslaChicago | 8 janvier 2013

"The standard also requires, as mandated by the PSEA, that all vehicles of the same make, model and model year emit the same sound."

No need to worry about user chosen sounds.

DouglasR | 8 janvier 2013

@JZ13 "Can you summarize?"

Silence kills.

kevincwelch | 8 janvier 2013

I filled out a comment on the site regarding this proposal. This proposal is based on weak evidence. Weak evidence to support EV/HV cause increased injury. Weak analysis based on poor penetration of EV/HV when compared to ICE vehicles. Weak data demonstrating injury is directly related to sound absence. Weak data demonstrating that introduction of sound to EV/HV reverses "statistically significant" increase in injuries related to EV/HV. Selection of sounds rides on threshold of normal hearing for many adults and at frequencies unlikely to be heard my many older adults. Waste of time and money...but that's Congress.

jackhub | 8 janvier 2013

I've almost been hit in cross walks by turning ICEs with quiet engines. It is not just an EV thing!

Getting Amped Again | 8 janvier 2013

I understand the need for visually handicapped pedestrians. How about a frequency that's outside the human audible range but discernible to guide dogs, and they are trained to not enter the crosswalk when hearing it?

Then put a $25 tax on every EV sold and use that money to provide more guide dogs to those who need them (and for whatever reason can't get one otherwise).

I agree that for non-handicapped pedestrians, it's likely that most injuries occur because of their inattention (looking at their smartphone). I'd like those devices to pick up the high-frequency tone and issue an alert to the user, both audibly and on the device's screen.

I'm not being flippant here, just trying to really solve the problem without infringing on my right to have a quiet vehicle or the rights of others who would prefer that their world be quieter than it is now!

jat | 8 janvier 2013

My LEAF has a pedestrian warning noise below 25mph. I don't notice it, and can only hear it if the windows are down and there is some surface that reflects the sound back, and then it is a high-pitched whine.

I drove a Camry Hybrid for 5 years, and only once did I have someone start to step out in front of me when I was running on just the battery. The horn makes the car decidedly non-silent, so I don't see it as a problem at all -- the driver already has to be paying attention, so it isn't any different.

Brian H | 8 janvier 2013

GAS;
like the guide dog tone idea. Supplement: EMF directed emmission to produce loud squeal in headphones and earbuds up to 50' ahead!

DTsea | 8 janvier 2013

Jat, the proposal says the Leaf's noise is non-compliant because it is too high pitched.

Without hearing the noise they want, it is hard to judge. The part that is weird is that they single out EVs and HVs. Rather, it should (if the requirements is really necessary) be for ALL CARS. Many ICEs are going to have idle-stop engines to save fuel- one of the requirements is that cars make noise at idle!

The guide dog idea is not going to fly. Lots of visually impaired people do not have, or want, guide dogs. Probably guide dogs can just SEE the cars anyway!

This is a law from Congress. Globally- here, Europe, and Asia- the groups representing blind people are really worried about quieter vehicles. Logic (bicycles are quiet, etc) doesnt seem to enter the discussion, unfortunately.

Captain_Zap | 8 janvier 2013

@kevincwelch

Thank you for submitting your comments to the NHTSA. The comment period is short so there is very little time to do any substantal research. Submitting any and all insights are helpful.

dubaty | 8 janvier 2013

I am trying to come up with constructive comments, but am stuck on the flimsiness of the data, at least as presented. The document admits that when looking at pedestrian accidents involving EVs and hybrids that the sample size is small, yet they go on to say that the incidence is greater than with ICE peers. To compare two rates with populations of such dramatically different sizes, it is rather poor form to leave out an analysis of statistical significance. Without that, I really don't know if the incidence of accidents is greater with EVs and hybrids. Did I miss this buried somewhere in the document? Did anyone see a more detailed analysis of the suggested problem?

Brian H | 9 janvier 2013

The new fashion seems to be to treat 90% confidence as "likely", and 95% as "very likely". This weasel-wording suggests about 80%. Statistically, of course, all of those barely mean "worth a second look".

murraypetera | 9 janvier 2013

Wow this was hard to find.

Link to make comments.

http://www.regulations.gov/#!submitComment;D=NHTSA-2011-0148-0049

GregZw | 9 janvier 2013

This is totally stupid. Bicycles and Segway's go 18 MPH, do they have this requirement? The average running speed of a person is 15-18 MPH.

Maybe they should have the sound requirements so I can make sure I don't hit them since my car is quite enough so I can hear them.

pilotSteve | 9 janvier 2013

Thanks for the heads-up, comment submitted.

Gist of my comment: the driver/operator of the vehicles needs to be in control of the sound(s) produced lest the mandated sound become more noise pollution and ignored much as idling car engines and beeping crosswalks are today.

I suggest if anything be required it be two or three operator-controlled sounds (one is the standard horn and two more with decreasing volume/intensity) that can warn of approaching vehicle. Key point: keep the operator in control not "less than xx MPH".

lph | 9 janvier 2013

I agree that there is too much noise pollution. The freqency of the sound can make a big difference to how annoying it is. I would suggest something around 40 - 50 hz? and have user variable volume. This would be somthing like an ICE car at idle.
....Going to submit my comment.

george210 | 9 janvier 2013

I drive a 2012 Prius V which does make a sound when traveling on battery power at low speed. I have not heard it inside the car but people outside the car do notice it. It seems like Toyota has done good work on this, and I am glad the car is audible.

Captain_Zap | 9 janvier 2013

I was wondering if an awareness campaign amongst the sight impaired community may be more effective than any soundmaking rule. Even without soundmaking rules an education program would seem prudent and there may be far greater potential for having an influence. It makes sense to make the community aware that EV's will be more common and for them become familiar with the sounds that come an EV. There definitely is tire noise and other sounds even at low speeds.

Some sight impared people rely on a more quiet environment for echo-location of objects. It seems as if more noise will interfere with that. I can only imagine what a large parking garage will sound like with a bunch of noisemakers going at the same time. It seems as if a noisemaker would make it difficult to sort out all the noises and their origins in any environment.

I know that I am very cognizant about bicyclists, pedestrians and the like not yet being familiar with the existence of EVs on the road when I drive. I pay extra attention at intersections and in congested areas to make sure that I am seen. I look for eye contact and I wait if I don't get it.

BYT | 9 janvier 2013

This is SUPER LAME, counter productive and with all government BS, hard to navigate the site quickly to find where I can post how IDIOTIC this is. I posted on the sounds thread that I don't want my EV to make any noise, that is one of the MANY reasons I purchased an EV, STOP noise pollution, don't artificially add it? I don't know why I am so upset about this, can't put my finger on it, but I am!!

I'm not opinionated at all!! :)

petero | 9 janvier 2013

Darn. Just when someone invents and markets a better mouse trap (the Model S) the bureaucrats want to impose 19th Century rules. Kind of reminds me of 'The Locomotives on Highways Act 1861', 'The Locomotive Act 1865' (or 'Red Flag Act') and the 'Highways and Locomotives (Amendment) Act 1878'

http://en.wikipedia.org/wiki/Locomotive_Acts

Sad to say, something’s don’t change!

BYT | 9 janvier 2013

I wonder what the fine would be if they do impose and enforce the installation of the NOISEMAKER if I then "Yank" the damn thing out?

Brian H | 9 janvier 2013

If there must be a sound, a low rumble is a bad idea. Low sounds give poor direction clues; the wavelength is too large for the ears and brain to detect a difference between arriving waveforms. Mid-tone NON-COMPUTER GENERATED complex waves work best. (Computer waveforms are identical, also preventing ear and brain from distinguishing one from another. Why modern phones etc. are so hard to locate when "ringing".)

Mtlord | 9 janvier 2013

They claim a study which says that this law would prevent something like 35 deaths per year. But it seems to me that if all cars were silent, then pedestrians might pay more attention, and wouldn't that save more than 35/year?

petero | 9 janvier 2013

It is hard to pay attention to sounds car make, when you are busy walking, texting, and listening to music on your iPod.

jbunn | 9 janvier 2013

Stupid idea. I'm looking forward to a day when all vehicles are silent and electrical. Less noise polution, not more.

What next? Should my Tesla make a smell so people behind it know it's on?

Ever see one of those massive dump trucks pulling a second dump box on a long boom? They call them a transfer dump truck or sometimes a truck and pup. They are common here. The boom is perhaps 30 feet long seperating the two parts of the vehicle. One of my company's best and brightest was texting and stepped off the curb after the truck went by, only to be run over by the box a split second later. He could see but he wasn't paying attention. He could hear, but he had headphones on. And these trucks are loud enough that you can feel them through the soles of your feet.

Sometimes, bad stuff happens. But noise polution is not the answer. As the driver you need to be alert, non-distracted, and aware of your surroundings. It's YOUR responsibility to manage the safety of pedestrians.

Sudre_ | 9 janvier 2013

The study is seriously messed up. 35 deaths? at 18 MPH because of lack of sound. That is what I find hilarious. What probably really happened is someone ran over a pedestrian and crushed something important with the tire. Again NOISE isn't going to do much if the driver is texting while executing maneuvers on the sidewalk.

Here is the real kicker. I guess they interviewed the dead person and they said they didn't hear the car.

So you are driving 40 mph in a 15 mph. The cop asks the dead guy how fast you were going. The dead guy say he didn't hear the car. The cop asks you how fast you were going.... what do you answer? "Oh officer I was speeding... like 45-50 mph. I am so sorry." or "I was only going 15 mph in this school zone and the kid just JUMPED right out in front of me."

Brian H | 9 janvier 2013

Such extrapolations from thin data are a curse. They can be hyped to justify damn near anything. It's almost always pure bafflegab.

Robert22 | 9 janvier 2013

The studies are non-scientific and unsubstantiated. Not that this matters to congressman who wish to provide a solution to a problem that doesn't exist. The morbidity and mortality data for "quiet" cycling would seem to be a more compelling target. This has lobbyist written all over it.

DTsea | 9 janvier 2013

Comment submitted. Gist of my comment is that if the rule is really required for safety, then ALL vehicles should be required to meet it. Including ICE cars with idle stop, or quieter ICE cars. This will 1) level economic playing field and 2) avoid need for followon rulemaking as ICE cars get quieter.

Also I commented that the noise level should be different in quiet environments (neighborhood) than noisy ones (city) to avoid noise pollution.

DTsea | 9 janvier 2013

BTW the proposed rule making is very clear that this is about blind people and their ability to detect cars. Generally I have not seen blind people texting or with earphones- they depend on their ears to detect their environment.

Brian H | 9 janvier 2013

DTsea;
It is notable that the Associations for the Blind are NOT pushing for it. Just busybodies, "on their behalf".

SSL161 | 10 janvier 2013

This is a usual waste of time.

People get hit by cars because someone isn't paying attention (cars hitting motorcycles, cyclists, pedestrians). This happens in quiet rural towns just as much as in noisy cities.

I nearly get hit by NY Taxi all the time; most are ICE cars. I take my share of the responsibility for it and accept the risk as a fact of life.

If technological solution is to be mandated, I prefer to put control where it is going to do the most good - in the hands of the driver. I'd prefer to build in an alert system. Perhaps something like parking sensors on steroids; when an obstruction is detected an alert is emitted to alert the driver (coded sound for Front, Rear, left, right).

As stated by other in this forum, the world is plenty loud enough; there is no need to make it any louder.

DerekS | 10 janvier 2013

There should not be noise pollution added. There are already protections in place. There are sounds at crosswalks telling the very small number of visually impaired when to cross, and drivers are legally required to give way to active crosswalks. More noise pollution neither indicated nor desired. We are harming society by continuously bringing everyone down to the lowest common denominator.

petero | 10 janvier 2013

I 'almost' got run over by a bicycle. I didn't hear a thing!

SSL161 | 10 janvier 2013

I need to retract my suggestion.

We don't need more regulations. It's already illegal to run people over with vehicles. The safety onus is already on the driver.

This society has gone nuts and is drunk on Big Government.

Sudre_ | 10 janvier 2013

I think I have decided that I will upgrade to the performance so I won't have to hang around the noisy <18mph speed for more than half a second. The solution to this problem with just be speeding from <18 mph school zones and parking lots. Problem solved.

I am guessing that just sitting in the driver seat of a Model S will require the car to squeal since you never know when the death machine will start running over the blind people.

:-)

BYT | 10 janvier 2013

I giggle happily while driving my Model S, can I just roll down my windows and that will suffice as sound??

DTsea | 10 janvier 2013

BYT, you only need to giggle below 18mph according the NHTSA!

Brian H | 11 janvier 2013

Embedded automated peashooters. Pelt the offenders from 50 yds!

ChristianG | 11 janvier 2013

while I don't like this 'law' in any way, what I do miss on silent cars is something like bycicle bell. I only have my horn, so if someone walks on the street befor me talking to each other they might not hear me, pushing the horn would probably kill them by a heart attack. opening the window and shouting a is kinda weird ^^

Timo | 11 janvier 2013

Horn doesn't scare me, bicycle bell causes rapid heartbeat every time. Some less powerful horn sound could be useful though assuming the initial one is like some foghorn. (I have installed a better horn in my friend car once, the factory installed one had very anemic "meep meep" -sound, very much like some moped horn)

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