Dmitri Panfilov - Comments

I am building Electric Kit Car, which will be used in California. I found it very disturbing that I can only drive it at top speed of 25 MPH unless it has things like advanced air bags, tire pressure monitors, and other "safety" intems which are of no use in slow city traffic. If I buy used 20 year old car, I will not have any such equipment, yet no one on either State of Federal Level will prohibit me from driving it every day! Other states and European countries permit electric MSV to have maximum speed of 35 MPH, which if far safer and more practical for daily use. I request that NHTSA reconsiders its ruling on MSV classification, and that NHTSA would define the MSV category, since already 5 States have done so on their own. This now creates an unresolved conflict between State and Federal Regulations. I believe that limiting "golf-car" like vehicles without doors, or bumpers or any safety features to 25 MPH is correct, but small vehicles with fully enclosed body and other safety features like windshield wipers and proper headlights, should be allowed to travel at 35 MPH so they can keep up with normal traffic flow in Cities. Since most electric MSV would travel less than 40 miles (20 to 30 miles is more likely) daily, it should be up to the local jurisdictions to determine if they should be allowed or prohibited in specific locality. People will not be traveling hundreds or thousands of miles in them to other locations like with conventional passenger cars. Citizens should be allowed to use ecological and practical as well as cost effective transportation like MSV in their home towns. NHTSA should not make a blanket prohibition for all of USA by not defining the MSV class. Clearly there is need for a vehicle class that is between LSV (almost no safety equipment) and motorcycle (even with 3 wheels and car like) with absolutely no safety equipment and a car with more than 100 Hp and capability of travel well in excess of 100 MPH.