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Document Sample
Regulatory Impediments to Neighborhood
Electric Vehicles: Safety Standardsand
Zero-Emission Vehicle Rules
Timothy E L~pmaa
Kenneth S. Kurani
Daniel Sperling
Reprint
UCTC No 458
TheUn/,rersily of California
Transportation Center
of
Urdversi~’F Caltfornia
Berkele CA
7, 94720
Regulatory Impediments to Neighborhood Electric Vehicles:
Safety Standards and Zero-Emission Vehicle Rules
Timothy E Lipman
Kenneth S. Kurani
Daniel Sperling
Institute of TransportatmnStudies
Umvers~ty of Cahfomla
Davis, CA95616
Reprinted from
Transportatmn Research Record 1444
UCD-ITS-RP-94-40,pp I0-15 (1994)
UCTCNo. 458
Transportation Center
The University of Cahforma
at
University of Cahfomla Berkeley
RP-94-40
10 RL",IARCtt RL( ORD
FI(AN~I’ORTATION 1444
Regulatory Impediments to Neighborhood
Electric Vehicles: Safety Standards and
Zero-Emission Vehicle Rules
TIMOTHY E LIPMAN, KENNETH S KURANI, AND DANIEL SPERLING
the
The California A~r ResourcesBoardmandated production of zero- sumptlon, dependence on formgn oli supphes, and greenhouse gas
em~sslon vehlcles (ZEVs)stamng m 1998 Other states may follow emissions They would be used primarily m urban areas and
the
Among types of vehicles that maysatisfy the reqmrements th~s of would not, m general, be intended or designed for freeway travel
mandateare small, neighborhood electric vehicles (NEVs) that would
be u,,ed murban areas and on collector andarterial streets for a w~de Thmroperating environment would be urban and suburban arte-
range of short raps AlthoughNEVs hold the potential for large en- rials, coliector streets, andalleys
ergy and environmental benefits, their introductionis hinderedby two of
Many the pohcy ~ssues confronting the introduction of NEVs
institutional barriers Thefirst of these Is the federal safety standards can be grouped into the following broad categories
designed for fulI-s:zed, gasohne-powered automobilesThe secondis
the CahfomtaZEV regulations that may not award ZEV credits to ¯ Modification of regulations and standards to ehmmate insti-
manufacturers for alI vehicles certified as ZEVs,pamcularlyvery
tutional barriers to the sale and operation of NEVs,
small NEVs Also there are unportant inconsistencies m the vehicle
definmons used mthese and other regulations and vehicle codes This of
¯ Development incentives to stlmuiate manufacturers to pro-
has created confusion with regard to their apphcabdttyto various duce NEVs and for consumers to purchase them, and
small vehicle designs The history of legislative rule makingas it ¯ Coordinationbetweenlocal, state, and federal agencies to de-
relates to small vehicles ~s explored,andpossible strategies for over- velop the infrastructure and traffic control measures wherenec-
comingthese regulatory bamers to the productmnand sale of NEVs essary to provide an appropriate operating environmentfor NEVs
are chscussed
This paper addresses two underlying mstltuhonat barriers mthe
Persistent nonattammentof ambient mr quality standards m many first category NHTSA federal motor vehicle safety standards
U S reties and the continued almost 100 percent rehance of the and
(FMVSSs) language mexisting air quality and energy legis-
transportation sector on petroIeum have prompted nev, federal, lation (such as the definmons of ZEVpromulgated by CARB),
state, and local m~tiat~vesto introduce altematlve transportation which maynot formally recognize these vehrcles as "passenger
fuels, Oneof the most far reaching of these requirements for new cars " This paper examinesthe recent hlstory of rule makangby
vehicle technology has been enacted by the Cahfomla Air Re- as
NHTSA it relates to small vehicles The extstmg procedures
sources Board (CARB)Section 1960 1 of Title 13 of the Cah- under which vehicles that do not conform to the panoply of
forma Code of Regulations requires that 2 percent of newcars are
FMVSSs sent to market and the potential for obtaining ex-
dehvered for sale by major automakers in Calfforma m 1998 be emptions for or amendingproblemattc standards are described
zero-emlsslon vehicles (ZEVs) These propomons increase to The paper then discusses the potential for the creation of a new
percent m 2001 and 10 percent m 2003 On February 1, 1994, 12 vehlcle category and proposes a vehicle definmon scheme that
states m the Northeast requested permIssmnfrom the Env~.ron- would accommodatethe speciahzed needs of NEVsFinally the
mental Protection Agency(EPA)to adopt sxm~lar rules paper explores &screpanoes m vehicle defimtlons m various
Battery powered electric vehicles (EVs) represent the only codes and regulations, including the ZEV mandate, as they affect
available technology that currently meets the ZEV definmon Be- the regulatory treatment of NEVs
cause of their zero tallpipe emissions and flexibility of energy
supply, EVsare promising prospects But because of the high cost
and relatlvely poor energy storage characteristics of batteries, COMPLIANCE WITH FMVSSs
many market analyses conclude that few consumers would buy
EVs (1-3) Although other stu&es differ mthe conclusion (4,5), The National Traffic and Motor Vehicle Safety Act of 1966 em-
this uncertainty about the market for full-size battery-powered powered the U S Departmemof Transportation to set nahonal
EVshighhghts the need to explore other apphcations and designs safety standards for motor vehicles under ~he authority of the Na-
for EVs tional HighwaySafety Bureau, which later became NHTSA (6)
One new type of vehicle that could help meet environmental NHTSA’s primary mandate is to set safety standards that define
and energy goals Is the neighborhoodelectric vehicle (NEV)(see the minimum level of safety performance for motor vehicles (7)
paper by Sperhng, this Record) These efficient, clean vehmtes The standards promulgated by NHTSA generally fall into three
could play a valuable role mreducing air pollution, energy, con- categories crash avoidance (series 100), crashworthmess(series
are
200). and poslcrash (ser~es 300) Automakers responsible
Inst~ ate of Transportatmn
Studies, Umvers~ty Cahforn~a,
of DavisDav~s, "self-ccmfy,ng ’ their vehicles A second section of the FMVSSs
Cahi 95616 m 49 CFRaddresses the admnustratlve considerations that are
et
Ltpman al 11
rele~,ant to EVs, and th,s Includes NHTSA enforcement(Part 554) torcycles, may be viewed as unsafe, coupled w~th the mconven-
and temporary exemption (Part 555) (8) mnce to consumers of being reqmred to ab,de by helmet laws,
The FMVSSs were ortg,nally written for internal combustion would hkely result m a reduced potential market share, despite
engine veincles, but the recent resurgence minterest m gVs, cou- the relatlvety low cost of the vehicle A four-wheel design, clas-
pled with governmentregulatmns encouraging or mandating their sified as a passenger car, wouldhave to meet muchmore rigorous
to
use, has led NHTSA remvestlgate the potentml need for new standards, resulting m much higher costs (10)
to
or modified standards The willingness of NHTSA explore the One solution to the problem of NHTSA compliance for NEVs
develapmentof spemfic standards for EVssuggests that there may ts to define a newvehicle category that defnes standards that
also De potential for modifications mthe rules that would allow small, hghtwmghtvehmles must meet In fact m I967 the NHTSA
NEV,,to operate m specific environments An examination of the safety regulations included a general exemptionfrom motor ve-
rule
recen’ history of NHTSA makingwith regard to both three- Incle safety standards for four-wheel veincles that welghedunder
wheeled and hghtwmght veincles sheds light on the potential to 455 kg (1,000 lbs) The exemption was justified on the premise
create new rules that would allow the produchon and use of that it would be lmposslble for such "hghtwe,ght vehxcles" to
NEVs of
meet the standards imposed on full-s~ze cars The w~sdom this
demsmnwas qumkly challenged by the Center for Auto Safety,
winch argued that the exemptmn should be revoked
Safety Standards and Vehicle Classifications
the energy exchangema colhsmnbetweentwo vehlcles will
To demonstrate the interplay between rule making and vehicle for
result mmoredisastrous consequences the hghter of the vehi-
deslgn and to introduce the history of rule making regarding small cles Further delay ,n (hghtwmght) may
vehicle comphance create
vehicles, consider the case of three-wheel vehicles Underthe cur- and to
an unreasonable intolerable risk of harm the motoring pubhc
rent federal vehicle classtficaUon system, a small, three-wheel EV
(11)
woulcl be a "motorcycle," but a small four-wheel EV would be
considered a passenger car" As a result three-wheel designs On August 16, 1972, NHTSA issued a notme of proposed rule
woulcl be subject only to the mammal safety standards that apply makangto remove the genera1 exemptmn,cmng the growing in-
to motorcycles, whereas four-wheeI designs would face the much terest m hghtwmghtvehicles and declaring that the potential
safety hazard was an issue that needed to be addressed At that
more stringent standards apphed to full s~e passenger cars The
t~me NHTSA conceded that hghtwe,ght veincies might not meet
long mstor3’ behind these rules, pamcularly with regard to the
motorcycle definmon, provides some insight into the future po- all the safety standards, but emphasizedthat exemptionsfrom spe-
tent~a] of small EV classfficatmn strategies cific standards that could not be met might be possible Standards
On May16, 1973, NHTSA published a notice of proposed rule pertaining to structural strength and crush distance were deter-
makingthat examinedthe vehicle classlficatmn system with re- minedto be potentmlly problematic for small vehicles, but those
gard to the apparent meqmty the treatment of hghtwelght ~,e-
m pertaining to hghtmg,braking, and glazing v.ould easily be met
tucles wlth s~m_dar purposes but with a dlfferent number of Because of the different standards that rmght and might not be
wheels In that proposal, winch sought to revise the motorcycle met and because such standard specific exemptmns already ap-
defimlmn, NtTI"SA said "Whatever the reqmrements for hght- plied to heavy vehicles, NHTSA concluded
wmght veincles maybe m the future, there ~s no evidence at
tins time that a d~vtdmg line based on whether they have three or h thus appearsmthe public interest to considerthe needsandprob-
four wheels is rat,onaI (9) NITI’SA,,vent on to propose a mo- lemsof hghtwetght vehicles on a standard-by-standard basis as ts
presently donem the case of hea vehicles, which
D receive dlffer-
torcycle definmon that would exclude enclosed, three-wbeel ve- enhal treatmentmseveral standard~, rather than by an across the
incles (9) The proposal was subsequently deemedambiguousand board exemptmn (emphasisadded) (12)
revised several tLmes,but the tong Instory of proposals, comments,
and revisions ulttmatel2, resulted m no change to the motorcycle Thus, on May16, 1973, NHTSA removed the general exemp-
defimllon The clear meqmtym the treatment of veindes with tmn for hghtweight vehmles, but once again emphasizedthat po-
three ,rod four v, heels wasnever resolved, despite NHTSA’s orig- to
tential manufacturerscould petition for an amendment any tin-
inal concern that practical standard or could petmonfor a temporary exemptmn on
one of several potentxal bases (13) This pohcytowardb.ghtwelght
the present [MasI6 1973}defimtlonal dividing hne between vehicles remained unchallenged untd 1979, when NHTSA re-
three and four wheelswould create a majorincentive for manufac- a
cewed petltmn for the creation of a hghtv, eight vehicle categor-:
be in
turers of small~ehlcles, such as those that may developed the
futu~e for urban In
transportauon, choose three-wheeled
a designand NHTSA refused the petition m1981, stating "As a general matter,
thereb3,escapethe necess~t’,to conform mav,y safety standards
to cars of all sizes should complyw~th the same safe,y standards"
(emphaszs added)(9) (t4) NHTSA argued that the lightweight vehmle exemption was
unnecessary because it had found no evidence that the cost of
One dilemmaposed by this classtficatmn system with regard to meeting safety standards was preventing the manufactureof hght-
~s
the tll ee-v, heel EV the trade-off faced by both potential man- weight vehicles Furthermore it argued that the technology was
ufaclurers and copsumers between the cost of comphancewlth available to build "relatwely" hght passenger cars that could
safety regulations (and thus vehicle price) and consumers" own achieve a high degree of fuel economy while also complymg ’aqth
desire for con’.ement and safe, but inexpensive vehicles A small the standards Fmalty Ntt’ISA pointed out that although hght-
offers the lowest
three-’,,, heel ’. eincle that qualifies as a motorcycle weight vehicles were muse mEurope and Japan, the vehicle rmx
cost of comphance because of the relatively few standards that m those countries was d~fferent from that mthe UmtedStates and
would need to be met But the fact that these vehicles, hke mo- that the greater average vehicle v~etght mthe Umted States would
,2 RL~LAR( RL( ORD
[RAN~PORTATION If 1444
result xn a greater risk of severe injuries for occupantsof light- In the short term NEVs that arc not able to meet all of the
wmght vehicles if these vehicles were not able to meet the full FMVSSs could be allowed to operate under temporary, low-em,s-
rantge of safety standards Thus the petition was denied and pro- sion vehicle exemptmns from specific safer 3, standards The hlgh
spe(zttve manufacturers of hghtweight vehictes were encouraged is
cost of meeting the provlsmns of the FMVSSs a strong argu-
to develop designs that wouldcomplywlth the standards to ensure ment for the temporary exemptmn procedure, but the case of ob-
the safety of the vehmleusers (14) taining an exemptmn would likely depend on the type and number
This rule-making hlstor3, suggests that mthe short term ,t would of standards that the vehmle does not meet and the percmved
be &t-ficult to reinstate a general exemptionfor hghtweight ve- safety nsk of allowing the vehicles to be hcensed without con-
hicles A more feasible initial alternat,ve would be to idenufy forming to the standards In the longer term the number of ex-
those safety standards that cannot be met for a g~ven type of emptedvehmlesthat could operate in this manneris very hmlted
vehicle and to pursue exemptions or amendments for those stan- are
If NEVs to be one part of an integrated solution to the problem
dares to allow those vehicles to be licensed and operated on pubhc of improvingair quality and energy efficiency, a newvehmlecat-
roads egory must be defined along v, lth modified or newstandards that
apply to the safety concepts employed msmall vehmles
Permanent Amendment to FMVSSs
Temporary Exemption from FMVSSs
to
It is posslble that a permanent amendment one or more of the
FMVSSs could be granted for NEVson a standard-by-standard
Thedeslgn, certtficatlon, and testing of vehicle modelscan be an
basis Historically th~s has been attempted only for vehmlessuch
expensive process For example the cost m 1989 and 1990 for
as the motor-driven cycle and not for passenger vehicles The
to
Con,zeptor/EPRI test the complianceof the electric G-Van w~th
process by whmh standards are added or amendedis very tlme-
seven FMVSSs approached $I,000,000 (8) Clearly the costs
consuming,partlcularly for those standards concernedwith crash
as
comphancewith all the FMVSSs, would be reqmred for a new
protection (T Vmson, Office of Strategic Planning and Evaluauon,
vehicle design, could easily reach milhons of dollars, because the
NHTSA, unpublished mformatmn, March 15, 1993) A petltmn to
procedurewouldneed to include the cost of the test facility, mul-
alter a standard maybe discussed and revised for 2 or 3 years
to
tiple vetucles, damage test equipment, and redesigning and re-
before being accepted Becauseof a lack of precedents, it ts un-
testing of prototypes Sensitive to the needs of small companies,
clear exactly what argument would be necessary to convince
NI-FI’SA allows manufacturers of hghtwmght vehicles to seek tem-
of
NHTSA the need for a standard to be amended,but this option
poray exemptions from one or more of the FMVSSs (8) Under
is potentmlly less difficult than the creatmnof a completelynew
49 CFRPart 555, an exemptmnfrom one or more standards may
vehicle category and should be considered, particularly if only a
be ga anted for up to 2,500 vehicles per year on one of the follow-
few of the standards prove to be problematm
mg bases facthtation of the development of new low-emlssmn
Although the degree of difficulty in meeting these standards
vehlcles, substantial econotmchardship, or the existence of an
will differ by vehicle design, several standards wereIdentified by
equwalentoverall level of safety
In
NHTSA 1978 as being potentmlly problematic for electric ve-
Tl-e exemption procedure ks available to any manufacturersell-
hicles m general (15) Someother standards were not noted by
mg fewer than 10,000 umts per year and mlght prove very useful
but
NHTSA have since been ldenhfied as presenting possible dif-
to a companyinterested m marketing NEVs For a small company
ficulties for small vehicles (16) A total of 15 standards have been
with low (or no) annual sales, the exemption procedure may
identified to date, primarily mthe level 200 (crashworthmess) cat-
the only wayto put ve~cles on the market, at least in the short
egory, which suggests that attemptmg to obtain separate amend-
term In fact as of 1994 existing converters and manufacturers of
ments to each standard would be difficult and time consuming
"full-size" EVswere selling then- vehicles under one or more of
of
A careful exammahon these standards suggests that gaming
these exemptmnsThe exemption penod could be used to facth-
NHTSA approval for the operation of NEVs may be one of the
tate demonstrationprojects and assessments of veluele safety, po-
greatest challenges facing those whowish to introduce these ve-
for
tential markets, reqmrements newmf.rastructure, and the op-
hicles into the U S market In its I978 study NHTSA concluded
ff
eratmnal feasibthty of NqEVs the trial period indicates that
that the ClttCar, a smalI EVthat weighedless than 591 kg (1,300
NEV~ would slgmficantly and positively advance air quality, en-
lbs), would"no doubt have dxfficulty meetingexisting safety stan-
ergy, and mob~tygoals, manufacturers and regulators may wish
dards (15) Given the numberof standards with which comphance
to pursue the more challenging option of creating a newvehicle
is
of NEVs hkely to be problemaqcor that are simp?~ynot appli-
classification Such a classification v, ould removemanufacturers’
cable to the characteristics of the vehicles, potential manufacturers
uncertainty regarding design and operational characteristics, pro-
vide consumers with an appropriate standard of safety, and clarify currently have few opt)ors apply for temporary exemptmnsor
attempt to operate under loopholes in the law, such as those that
for regulators the role of such vehicles mimproving air quality
exlst for three-wheel vehicles Examplesof vehicles that use each
and advancing e~ergy pohcy
NEVs would likely qualify for the exemption as "low-emlssmn approach mclude two Damshdesigns the Kewet EI-Jet, a four-
wheel vehicle that ts operating under a temporary exemptmn, and
motol vehicles " The primary challenge m obtaining such an ex-
the City-CornCity-El, a three-wheel deslgn that ts classified as a
emption would be m convincing NHTSA that the failure of a
motorcycle
vehicte to meet one or more standards would not constitute an
unreasonable degradatmn in its safety To the extent that this
Creating a NewVehicle Category
wouldrequire detailed crash test reports demonstratingthe safety
of the vehicle the cost of thus process m~ghtbecomea hindrance A final alternative is to develop a newcategory of vehmle with
to the small manufacturers included m the regulatmn an accompanying set of fully relevant standards At the t~me of
Llprnan al
et 13
the 1978 NHTSA study the CltlCar was determined to be so d,s-
30
slmlla- from conventional vehicles that the agency considered de-
veloping rules for "a special class of vehicles with restrictions on
wmghl, operatlona[ performance, passenger capacity, and use" Top
(8) Tills option was subsequently deemed infeasible, but perhaps Speed
....~L ~T~
it wiIl be reexplored if a stzable market for small vehtcles
develops 32
i
There are two primary justifications for the creauon of a new
set
hghtweight vehicle category with an accompanying of crash- 0 ,.~w~.~ ~x)(...._j) 40{x) 5{~
worthiness standards The first of these is that safety concepts 0 kg 455 910 1365 1820 S
227
designed to minimizethe hazards of vehicle colhslons 0 e, com- Vehicle Curb Welghl
posite materials, air bags, and rigid passenger compartments) have FIGURE 1 Proposed~ehlcle class~fieatmn scheme
improvedmuchm the past 20 years, makangit potentially easter
for hghtwmght ’vehicles to provide a level of safety comparable
to tha provaded by heavaer passenger vehicles The current
m
FMVSSs some cases are highly prescrtpttve, specifying the mc propulsion (i e, NEV,MEV, and EV) and those that do not
meansby whichstandards are to be met 0 e, crush zone distance, Thas is the most basic dwlsmn needed for the purpose of applying
etc), and this approach excludes other safety concepts that may different proputsmn-relatedstandards to various vehacle types and
be mo~e appropriate for small vehicles The second just~ficatton for accommodating current and future mcentavepohcies that lower
are
for a newcategory ts that NEVs the only small vehicles that of
the price and increase the eonvemence EVsto encourage their
wall reqmre substantmlly different standards Not only will they socially desirable emissmnand energy use characteristics Other
operate m low-speed environments that will not be as hazardous for
refinements can be addedto this basic framework full sine and
as those of freeway-capable vehacles but their safety can be en- small hybrid vehicles and for other alternate-fuel vehacles Third,
hanced through speclahzed traffic control measuresand infrastruc- thas classlficatmn scheme dastmgmshes between MEVs,which
ture aeslgn concepts These measures can be employedto restrict will likely be freeway capable and should meet the intent of the
of
the corammghng NEVs with heavaer, faster vehmles whennec- FMVSSs new
(although possibly employmg safety concepts), and
essary (see paper by Stem et al, th~s Record) In a larger sense the slower and generally smaller NEVs,which are not freeway
safety must be considered m context In the case of NEVsthe capable and thus have clearly distmct reqmrements for safety
contexl is slow-moving traffic, a restricted operating environment, standards
and tailored traffic controls Thus a new ctass~ficatlon scheme would provide a simple
The development of a newvehicle category will reqmre that frameworkthat could be used for the dual purposes of developing
consensus be reached amongmanufacturers and regulators as to mcentavepolicies for the use of clean, efficient vehmlesand of
the description of thls newclass of vehicle This may be some- developingsafety standards that address the specafic needs of dif-
what difficult, but m the long term it seems unavoidable given ferent vehicle types and sizes It Is important to note that the
that the characteristics of NEVs essentially preclude them from majority of the standards wall be met without dtfficulty by small
(at
compbmg a reasonable cost) with all of the safety standards vehicles, but mthe long term standards that are based on vehicle
currently imposedon passenger vehicles The following newdef- speed and size will need to be modtfied, pamcularly for NEVs,
are
mmons suggested as a starting point for discussmn for these vehicles to be brought to market a~ a reasonable cost
Mmtvehtcle (MV)a motor vehicle having three or more wheels
m contact wlth the ground, a fully enclosed passenger compart-
ment, ~ vehlcle curb weight of less than 910 kg (2,000 ibs), and INCONSISTENT REGULATIONS AND
a top operating speed of over 65 km~r (40 mph) and that ZEV MANDATE
designed and used for the transportatton of people
a
Mzm-electrtc vehtcle (MEV) mmivehlcIethat is powered The primary motivation for manufacturers to introduce EYs m
electrical energy Cahfomaa ~s the ZEVmandate promulgated by CARB Sectaon m
Netghborhoodelectric vehicle (NEV)a motor vehicle having 1960 1 of Tttle 13 of the CahformaCodeof Regulations But the
three o more wheels mcontact wath the ground, a fully enclosed ~s
apphcabthty of that mandate to NEVs unclear because of the
passenger compartment, a vehicle curb weight of less than 910 inconsistent and vague vehmle defimttons m regulahons and
kg (2,000 lbs), and a top operating speed of 65 kroJhr (40 mph) codes The ZEV mandate apphes only to passenger cars and hght-
or less and that ~s poweredby electncaI energy duty trucks Although the definition of a "passenger car" used
is
by CARB "any motor vehmle designed primarily for transpor-
Thls scheme can be represented as shown m F~gure 1 tation of persons and having a destgn capacity of 12 persons or
This classtficatmn ~ystem as useful because at accomphshes less," at this hme some vehicles, pamcularly NEVs with three
three maportanttasks First, it makesthe baste distmchonbetween wheels that would be cerhfied as ZEVs (for purposes of tax cred-
small vehicles, with a vehicle curb weaghtof under 910 kg (2,000 ats and other mcenhves)would not be awarded ZEV credits (Cal-
lbs), and larger vehmlesThts dlstmctmnis necessary because the fforma Code of Regulatmn%Title 13, Sechon 1900) Manufac~
has
current set of FMVSSs been destgned for full-size vehteles, turers of fourowheel NEVs apparently would recetve ZEV credits,
and all small vehacles, regardless of thetr propulsion system, may has
but CARB yet to makean official determination on the mclu-
benefit from standards specifically destgned for them Second, a m
ston of various types of NEVs the credit scheme The fate of
useful chstmctmnis madebetween the vehicles that employelec- NEVs wtth regard to this critical mandateis therefore unclear
14 RLSLAR( RI ( ORD
II¢.ANSPORFATION H 1444
In addition to the uncertamtms surrotmdmg the CARBZEV muchless than gasohnc-powercdvehicles (and full-sized EVs),
regulations, NEVs face the problem of a lack of consistency fractional ZEVcredits could bc awarded
among the vehicle defimtmnsused by various reguiattons and ve-
hicle codes The EPAClean .,Mr Act Amendments (CAAA),the
Corporate Average Fuel Economy (CAFE)standards, the federal CONCLUSIONS
UmformVehmle Code (UVC), and the Cahforma Vehicle Code
(CVC)all use different motor vehmle definmons, adding greatly The lntroductlon of small, hm~tcd-performanceNEVs consum- to
to the confusion surrounding policy and regulator,y issues related ers and cities confronts a rule-makingsystem tied to ftlll-sxzc,
To
to NEVs choose a particularly bewddermg example, a three- gasohne-poweredcars Standards and rules need to be made more
wheel EVcapable of 50-mphtravel (an early prototype madeby flexible to accommodate differences A first step ~s to dcfine ap-
the Horlacher company would meet these criteria) would be con- propriate classifications, defimtmns,and standards for NEVs and
sldered a "passenger vehicle" by CVC,a "motorcycle" by UVC, other small vehicles Specifically the development of NHTSA
a "passenger car" by CARB,a "hght-duty vehicle" under safety regulations that are appropriate for small vehicles operating
and
CAAA, possibly a "passenger automobile" and possibly not in restricted environments and the inclusion of all NEV designs
(deper drag on a determinationby the Secretary of "I ransportatlon) mthe credit schemeof the ZEV mandate are critically ~mportant
for purposes of inclusion under the CAFE standards for the success of the NEV concept The second issue, qualifica-
The definitions used in promulgating the CAFE standards and tion for ZEV credits, is of especially great ~mportance because it
the resulations of CAAA confusing in that the terms passenger
are creates a potential market for NEVs
car, passenger automobile, and hght-duty vehicle are all used to A research agenda designed to address the issues raised mthis
meanessentially the samething, but subtle d~fferences do exist paper must include safety, emissions, and vehicle use studms De-
A passenger automobde is defined, for the purposes of CAFE velopmentand testing of newsafety concepts, newmaterials, and
standards, as a vehicle designed to carry "no more than 10 rod> the mteractmn between vehmtes m low-speed operating environ-
v~dual,,," and a hght-duty vehicle is defined, for the purposes of ments will clarify howsafety standards can be modified to allow
CAAA, being "capable of seating 12 passengers or less "’ Thus
as The
for the safe operation of NEVs potentml for these vehicles
a vehl(le seating 11 passengers is a "hght-duty vehmle"but not to substitute for short, low-speed, urban trips suggests that thmr
a "pa,.,senger automobile" (40 CFR§600 002-85 and 40 CFR emissions reductions may be far greater than indicated by the
§86 082-2) Of greater relevance to the NEV the language of
is numberof trips or numberof miles they travel Thus the ability
the C.&FEregulation defining an automobile as a "four-wheel of NEVsto complement, rather than replace, gasohne-powered
vehicle " The exclusion of vehmles with fewer than four wheels vehicles within a household stock of vehicles must be assessed
would hold barnng a determmatmn the Secretar 3, of Transpor-
by With the cooperation of vehicle manufacturers and federal and
tation that such vehicles would be "substantially used for the state agencies, procedures and pohmesthat wllI allow NEVs to
same purposes" (40 CFR§600 002-85) meet the requirements of ZEV regulations in California and other
A first and obvious recommendatmn would be to combine the states and to provide safe transportation can be implem~.ntedIf
terms ~assengercar, passenger automobile, and passenger vehicle this is done the viability of the ZEV mandatewill be strengthened
and give the resulting term a clear and consistent definmon and a new modeof safe, effiment and env~ronmentall), bemgn
throughout the vinous codes and regulations The authors suggest transportation will become available
using t~ae term passenger car, as used m UVC, because it ~s the
most w~dely used and thus the easiest to standardize and also
becaus~ it has a simple defmmon that clearl3, excludes motorcy- ACKNOWLEDGMENTS
cles and could easily be modified to exclude other vehicle cate-
gories Another recommendatmnwould be to define the terms The authors gratefully acknowledgethe information and insights
hght-&tty vehicle, med, um-du~, vehzcle, and heavy-duty vehwle offered by William L Garrison, Cece Martin, and AaamStein
primarily mterms of the weight of the vehicle and to restrict the a
This work was conducted for CALSTART, pubhc-prwate con-
usage of these terms to situations m whichthe weight of the ve- sortium for advanced transportation technology, with funding
hmle is important In cases m whichweight ~s not an ~ssue, more from the FTAand the Cahforma Energy Commission
general terrmnology should be used (1 e, passenger car, neLgh-
borhood electric vehicle, etc )
In summary simplifying and reconcdmgthe terms used to de- REFERENCES
fine vehicles would remove a considerable amount of confusmn
that cmrently exists A consistent and precise defimtmnscheme of
1 Beggs, S D, and N S Cardell Chome Smallest Car by Mult~-
and for
Vehicle Households the Demand ElecmcVehmles Transpor-
would allow manufacturers to knowwith certainty howvarious A,
tation Research Vot t4A, 1980
vehicle designs would be affected by laws and regulations and 2 Bunch, D S, MBradley, T F Golob, R Ka,’amura, and G P Oc-
would aid them m then" strategic planning m bringing their ve- for ,n A
chtuzzoDemand Clean Fueled Vehmles Cahforma D,screle-
hmles to market and m meeting the ZEVmandate Given the Chmce Stated Preference Pdot ProJect TransportattonResearchA,
Vol 27A, No 3, 1993
potentmi importance of the mandate m Cahforma and elsewhere for
3 Calfee, J E Estimatingthe Demand Electric Aatomobdes Using
in promoting the sale of EVs, the success of the NEV concept Fully DtsaggregatedProbabthst~cChome Analysis 7ransportatton
mayde3end on it being included mthe provisions of the rule ResearchB, Vol lqB 1985
Such mclusmn would likely have to be supported by analyses of 4 Sperhng,D Future Drive Electric Vehicles and Sustainable Trans-
D
portation Island Press, Washington, C, forthcoming
howmuch pollutmnanc~gasoline vehicle t, se is reducedas a result for
5 Turrentme, T, K S Kuram,and D Sperl,ng Demand Electrm
of each NE\, purchase If analysis shows that NFVsare used Yetucles Exploringthe HybridHousehold Conceptwith Present and
et
Ltpman al 15
Po enttal Electrtc Veh~c|eOwners [nstttute of Transportation Studtes, 11 Federal Regcster 35, 3297
Umverslty of Cahforma, Davis [’ransportatton Pohcy, forthcoming 12 Federal Regtster 37, 16553
6 M~shaw, J L, and D L Harfst The Struggle for Auto Safety Har,,ard 13 Sparrow, I- T, and R K Wh~tford The ComingMini/Micro Car Cry-
Unwerslty Press, Cambridge, Mass, 1990 sis Do WeNeed a NewDefinitmon’~ Center for Public PolEcy and
7 Cr,mdall, R W, H K Gruedspecht, T E Keeler, and L B L~ve Public Admm~stratlon, Purdue Umvet’slty, West Lafayette Ind 1983
Regulattng the Automobtle The BrookmgsInstltullon, Washington, 14 Federal Register 46, 12182
D C, 1986 15 Apphcabthty of Federal MotorVehtcle Standards to L’lectrtc and Hy-
8 EV,kA Membershtp Update Apphcabthty of the Federal Motor Ve- brid Vehicles NIVI,’SA,U 5; Departmentof Transporlat~on, 1978
hicle Safety Standards to Electric Vehicles Electrtc Vehtcle Assocta- 16 Sobey, A J Draft Plan for the Assessment of Regulatory Require-
ttor of the Americas, Cupertino, Cahf, Oct 15, 1992 ment for the Half Wlclth Vehicles Oct 2, 1989
9 Federal Register 38, 12818
10 Neighborhood Electric Vehicle Concept Feaszbll~ty Study Barry, Pubhcatton of thts paper sponsored by Commttteeon Alternattve Trans-
Theodore & Assoclates, March 1992 portatton Fuels
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