Petition to Congress -- HR 5734

:bump2::bump::bump2:

 

I'm a wordsmith. First off I'm unfamiliar with the legislation insofar as I have not read it. I have notes in italics with questions. First off, let's put in some paragraphs. Nobody likes a big wall of text.

Here's my suggestions:


We petition Congress to suspend action on H.R. 5734 "Pedestrian Safety Enhancement Act of 2008" until the National Highway Transportation Safety Administration (NHTSA) includes representatives from the hybrid owner community, with equal standing to the blind community, who will have to pay for the proposed changes to correct errors in the facts and data.
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You wanted to say that hybrid owners should have as many representatives as the blind community right? That's why the change and commas.

Breaking apart following paragraph statement by statement to make it easier to edit

In particular, claims of hybrid car hazards are not evident in accident statistics; Maybe instead, say "Statistics of pedestrian-vehicle accidents do not support the claim that hybrids are more dangerous to pedestrians than any other vehicle. (or whatever the statistics are)

insistence on making hybrids as deadly as the existing noisy vehicles instead of safer; does the legislation somehow make hybrids more dangerous than today? I'm confused.

focus on a solution that leaves the deaf, motorcyclists and other pedestrians at the same risk as today; Is that what the legislation does?

and other errors in facts and data.

Paragraph break here

No further meetings, hearings or actions should be taken until the hybrid owners have a fair seat at the table to work for effective solutions to reduce pedestrian deaths and injuries. The hybrid representatives should have demonstrated, open communications with hybrid owners.

Other than that, looks good. I'm off to work now, but if you have suggested changes I'll check them out when I get home.

EDIT: You might also send a call to your congresscritter and ask what an effective petition would contain.

 

wouldnt you get more participation with an online petition?

 

I think this link should take you to the Library of Congress with the text of the Bill:

Search Results - THOMAS (Library of Congress)

 

Response to SheepDog:

According to Snopes.com, Internet petitions rarely work:

snopes.com: Internet Petitions

 

Unless I have grossly missed something, I "assume" (and sometimes that gets me into trouble), the intent of the olegislation is to simply have vehicles travelling on public roads emit some sort of sound so that people who are blind can hear the approach.

I do not think this is unreasonable. I own an experimental electric car and even when it is simply rolling around a parking lot a person needs to keep their eyes on it as they cannot hear its approach.

If the intent is simply to provide for some sort of sound to prevent accidents going forward then I have no problem with legislation such as this.

Is this the intent of the legislation?

I suspect the volume of hybrid and electric cars on the road to date is still too small to have an accurate statistical representation of the risk factors associated with their silence. I would hope we don't need to run a few people over in order to be pro-active in our approach to safety.

If I am wrong please let me know.

 

I'll be the heavy here and disagree. This law is being made in the total absence of facts or evidence, and based entirely on anecdote. It's exactly how laws should not be made.

First, there's the "run down" phrase, which I assume means significant bodily injury. That's typical of the discussion, and elsewhere has been put pretty much as "does some blind person have to die before they'll change this".

Aside from the existing facts that I've summarized elsewhere (no US blind pedestrian has been killed by a hybrid; a Prius is no more likely to kill a (sighted) pedestrian than any other car; the vehicle most commonly involved in a blind pedestrian death is pickup truck, currently there are about 5 deaths and 40 hospitalizations per year for blind pedestrians in traffic accidents, which produces a per-capita injury rate much lower than for the US adult population as a whole), the problem is that hybrids are "silent" only at very low speeds. Once you get some speed up, you have tire, motor, and wind noise.

So, fundamentally, we are talking about the existing harm being limited to more low-speed impacts, due to hybrid "silence" at low speeds. Or, at least, we talking about people who have not bothered to quantify that threshold before taking action. (As a point of reference, the average speed at impact for pedestrian deaths is about 40 mph, at which point the entire hybrid issue is moot.) Most of the discussion -- and I'm sure the testimony -- will provide overt or veiled references to deaths and significant injury. To the contrary, I think the factual discussion of the topic should be based on whether or not hybrid "silence" does or does not result in more low-speed (read: minor injury) impacts.

Second, a lot of modern cars are quiet at low speeds. If there is some objective threshold below which low noise is an issue in real-world situations with ambient noise (e.g., a parking garage), then I contend the following: A) Higher minor accident rates should already have appeared for quiet-running traditional cars, Bee) Nobody has even bothered to test the spectrum of existing cars against that objective noise threshold to see how many vehicles on the road right now are "silent" at low speeds, and C) My speculation is that, if one were to establish a real-world audibility threshold and measure the cars on the road, hybrids are a small part of the putatively dangerous "silent" cars, but they are noticeable so they have become the lightning rod.

In other words, this public debate somehow assumes that low-speed noise levels of vehicles are somehow binary. There are hybrids and there's everything else. I don't think that's right, and I wish somebody would gather and release the data first before passing the law. I think the existing car fleet has a continuum of noise levels. I'd bet (and I wish there were data available to show) that for any given objective threshold for minimum noise level, we had hundreds of thousands or millions of such vehicles on the road, making that level of noise, before the Prius was even introduced.

That's obviously speculation on my part, but it's certainly a piece of the evidence you would like to have.

My hard prediction is that if they go through with this, they are going to get a surprise after the fact. Given vehicle makers' strenuous efforts to control vehicle noise in the last decade, I bet they are going to find that this "hybrid" law will place noisemakers on far more traditional cars than it will on hybrids. Mostly nice, upscale cars. They are going to find that we have been secretly living with a fleet of millions of these "dangerous" quiet cars. And hey, nobody noticed until hybrids came along. At which point, as lawmaking and rulemaking go, tough luck, the train has left the station, and we'll install noisemakers on millions of cars that nobody even cared about prior to the legislation. And will be required to have those for as long as cars are used in America.

The Prius has been on the road close to a decade now. Hybrids are still less than 1 percent of the fleet. Believe it or not, we have the time to do the research first, before we pass the law. There's no rush. The data suggest no uptick in deaths or minor accidents. Then sensible thing would be to postpone this by a year, get the information in hand, and proceed with an informed decision. But the proposed legislation does not do that. It does not ask DOT to address whether or not there is a problem, it assumes a problem and requires that DOE act to address it.

Now, it is possible that somebody at DOT or elsewhere has already done the research, but I've looked and found nothing. If they have, I sure wish they'd release it. If the facts change, I'll change my mind. But I object to foisting noisier cars onto all future generations of Americans just because we couldn't wait a year to get the fact in hand before deciding what to do.

No, it's not a make-or-break issue, no, it will not diminish America's status in the world. No, it won't prevent me from buying a hybrid. I just think it's an irritatingly stupid way to go about this. We can always think of things that might cause harm. And we continually have media, industry, and particularly the advocacy association industry pressing the case about things we need to fear. But before we spend (say) $100 per vehicle to address that possible harm, it's just plain foolish not to spend $0.50 per car to figure out whether or not that harm is real.

My apologies to DOT staff if such research exists, but I certainly haven't seen it.

Addendum: Let me put a little more information here. The Prius is a quiet car even with the engine on. The only research apparently publicly available was a test performed at the request of a blind advocacy organization, which compared recordings of a Prius to other cars. Adn we know know how advocacy research works. If it doesn't help the advocate it does not see the light of day. Not knowing the cars and not knowing the test conditions, but knowing that the Prius seems quieter than the average car even with ICE running, I'd wager that much of the effect they measured was due to the fact that the Prius is simply a quiet car, even with ICE running.

BOB WILSON, MAYBE WE NEED TO DO THE FOLLOWING:

But here's another approach. Suppose we (somebody!) could record the sound level of a Prius, moving at (say) 7 MPH, with ICE on versus ICE off. This would quantify the impact of the hybridization of the vehicle. Nobody can object to a hybrid with the ICE running, because then it's just a car. Or at least, that changes the debate a lot. And if the difference in noise level is small, that does two things.

1) It argues that much of what the (unpublished) research by the blind advocacy organization did is not a valid test of hybrids, even within its own highly constrained framework (ie, all it did was compare to a few other cars. It did not show the level at which the lower sound would cause harm, nor did it see how many other cars are (nearly) as quiet as the Prius.) The research did not show that the Prius is quieter than average because it is a hybrid. It merely showed that it is quieter than average, while running in electric mode. I'd wager that it is quieter than average even with the ICE running.

2) If the difference between ICE-off and ICE-on modes is small, that argues against the entire premise. In other words, if the Prius is nearly as quiet with ICE on, it's not the hybrid effect.

So, anybody out there have a decibel meter and care to perform the analysis?

What prompts this is the following bit of research I found:

http://www.inrets.fr/ur/lte/publications/publications-pdf/Lelong-publi/emission_synthese.pdf

Those measurements are not ideal, but they suggest that at (say) 7 MPH, the ICE-on versus ICE-off difference for "a hybrid" is around 5 decibels, if I have read that right. I know little about acoustics, not even enough to say whether that is a large or small difference. All I know is that Wikipedia, without citation as to source, say hybrids as 15 to 25 decibels quieter at low speed. Now that is a huge difference.

Noise mitigation - Wikipedia, the free encyclopedia

And, oddly enough, that 15-25 DB is exactly the difference between the hybrid and non-hybrid vehicles in the first citation above. That's not the hybrid effect, that's almost entirely the effect of the Prius being first and foremost a quiet convention car (the first 20 db), followed by the quietness of the electric motor over the ICD (the final 5 db).

Of course, I'm not even sure what that hybrid vehicle is.

Wait, these guys would have the data, except they are measuring noise at acceleration at wide open throttle:

Home Page

And they didn't test a Prius in 2007.

I give up. The data I would like to see do not appear to be available.

 

All I know is when I drive my electric car, people do not move out of the way when I approach them due to the silence. As long as a ice is operating, quiet or not, people generally seemed tuned to the sound of a moving vehicle.

In my limited experience, the generation of some sort of external sound at least in situations such as parking lots and urban zones, might very well prevent problems if... And I agree..... We can study and quantify the effect.

However it does not take a study to conclude that on a clean roadway with no ice operating, that an all electric vehicle is going to be signficantly more quiet. All it takes to understand this is to take a zap truck around a parking lot for a few minutes and anyone can see what I am talking about.