Buck Joiner - Comments

One of the reasons for rejecting the request consideration for rulemaking for MSEV was because Sun City had a higher traffic death rate than Palm City. The NHTSA conveniently neglected the fact that the percentage of people over the age of 65 in Sun City is 80% while those over the age of 65 in Palm City is 27%. By ANY rational, the rate of death in Sun City will be higher than in Palm City for ANY cause. The NHTSA logic that there are more deaths in Sun City because of higher speeds or reckless drivers or whatever would appear to be unsubstantiated based on the incredibly older population of Sun City. http://suncityaz.areaconnect.com/statistics.htm http://palmdesert.areaconnect.com/statistics.htm Another NHTSA point is the number of deaths on roads with 45 MPH throughout the USA. This does not relate to the speed of the vehicle and whether it was a single or multiple vehicle accident. A drunk driver traveling 85 mph on a 45 mph roadway crashing into a concrete abutment has nothing to do with an electric vehicle with a maximum speed of 35 mph. The drunk may hit another regular car or a pedestrian or a kid on a bicycle or a baby carriage containing quadruplets. None of that has any relevance to the safety of a 35 mph electric car. On page 7 of the document, NHTSA states "Mirox claimed that quadricycles are an extremely safe method of transportation that is used extensively in Europe. The chief benefits of quadricycles is that they are easy to use (unlike motorcycles), easy to park, and consume far less fuel than even the smallest European passenger cars. Mirox requested that MSVs be defined in such a way that at least some European quadricycles can be legally imported as MSVs. While the petitioner claimed that quadricycles are extremely safe, Mirox did not provide any data to support this claim or to show that introduction of these vehicles into the U.S. would be consistent with the need for safety." While it is true that Mirox did not provide data to prove it’s point, neither did the NHTSA provide data from Europe to DISprove the point. Therefore the point remains unresolved. I reserve the right to make additional comments later. Buck Joiner Maui, Hawaii