Adrain Tymes - Comments

This proposal is about making EVs less attractive, not pedestrian safety. Added sound when backing up is acceptable. When stationary or traveling slowly forward, it is simply embarrassing. Some quick surveys show that as many as 35% of would-be EV or hybrid vehicle drivers would, all else being equal, pass on EVs or hybrids in favor of ICE vehicles if they always made the proposed sound at low speed. Your proposal states, "We believe that [the higher rate of EVs involved in low-speed accidents] is mostly attributable to the pedestrians’ inability to detect these vehicles by hearing them during these maneuvers", but then fails to justify this link, only the sound profile. It is also based the data on accidents including when the EV is going in reverse - where a sound like this is already required. When showing that EVs generate less noise than ICEs, you claim that tire noise is less than engine noise up to 18 mph - with EVs, tire noise is often dominant at 5 mph or less. You also fail to control for factors like the use patterns of EVs vs. ICE vehicles: more ICE vehicles are used for high-speed, long-range travel, so a lower fraction is involved in low-speed anything. I draw your attention to Britain's Red Flag act of 1865, which mandated that motor vehicles could not proceed without someone walking ahead waving a red flag. This legislation destroyed the motor vehicle market in Britain for years, because it was not practical to make use of motor vehicles. As with this regulation, the concern was for pedestrian safety. As with this regulation, the concern proved unfounded and unnecessary - and was ultimately a sop to the existing transport industry, letting it survive in the face of obsolescence for a few more years. The horse and buggy whip industry might no longer be dominant, but the primary effect of this regulation will be to make ICE vehicles comparatively more palatable to the driving public. How many pedestrians will choke on the extra pollution?