Comment Log Display

Dear CARB:

Thank you for your work to bring Zero Emission Vehicles to our
state. 

We are a group of people who are eager to drive such vehicles as
well as a group of ZEV manufacturers who are able to produce and
deliver these vehicles in quantity. Our group is called the
Sustainable Transport Club and we are coordinating the Medium
Speed Electric Vehicle Working Group.

There is a way to put as many as 100,000 ZEVs on the road within
two years of having regulatory support for these Second Car
Vehicles. Two minor adjustments in the ZEV regulations would help
this to happen. These adjustments are:

1.	To change the range for a City EV from the proposed 50 to 75
miles per charge to 40 to 75 miles per charge.
2.	To Change the battery warranty requirements for this group to 3
years for the first three years of production and have it increase
to five years after that.

The hard reality is that the only ZEVs being sold are battery
electrics with limited speed and limited range.  The reality of
the current technology is that our manufacturers can produce
substantial volumes of vehicles with forty-mile range and up to 45
miles per hour speeds. That is what can be put on the market right
away and there is research to indicate that a volume market for
ZEVs can be established within these limits.

The current ten-year battery life requirement is adding
unnecessary risk to these manufacturers who are putting everything
on the line to get ZEVs on the road NOW. It also means that only
very expensive newer technology can be used for the next battery
electric ZEVS. That expense will limit the number of ZEVs on the
road.

Market research is showing that a set of Second Car Specifications
is taking shape. People are commuting an average of 30 miles per
day in LA City. The average vehicle drives 33 mile a day in the
US. Congestion is slowing traffic on both surface roads and
freeways so that the actual rate of travel is dropping
significantly. Urban areas like the Westside of LA are at the
point when a 35-mile per hour vehicle can get around town as fast
as any full speed passenger car. Those that go faster than
thirty-five wait (not so) patiently at stop lights for the 35 mph
vehicles to catch up to them.

The bottom line is that a very large number of people drive less
than 40 miles per day and get around at 35 mph or less. There are
close to a dozen manufacturers who can produce ZEVs that match
this need at very affordable prices. These ZEVs are four-wheel
cars with doors and roll cages and most of the safety features of
a passenger car. They are the next step up from a NEV and miles
away from being a golf cart. They are far safer than three wheel
cars and motor scooters. These manufacturers can produce in excess
of 100,000 vehicles a year within a year of getting regulations and
safety specifications that make sense for a 35 mph vehicle. 

That brings us to the second thing that the Air Resources board
can do to help actually get ZEVs on the road in the next two
years. That is to help get regulations passed to make this
possible including:

1.	State Regulations that call for the correct mix of safety
features for vehicles that are limited to going 35 miles per hour
on streets limited to 35 miles per hour
2.	Federal Regulations that lay out the safety requirements needed
at 35 miles per hour and that eliminate the FMVSS requirements that
are only needed for vehicles capable of going 80 miles per hour.

The 35-mile per hour speed is being used for several reasons. 

1.	Arterials in most cities support full access to the city at
that speed limit
2.	It allows these vehicles to stay with the flow of traffic
3.	Air bags deploy between 33 and 38 miles per hour in single car
accidents
4.	Air bags are the biggest safety expense in a car by several
orders of magnitude

It may be appropriate to add some speed requirement to the City EV
specification to distinguish them from the NEVs. A simple statement
that the “City EV has a top speed set by the manufacturers in
excess of 25 mph” would suffice and avoid a large discussion of
what the best speed is for such a vehicle. Manufacturers cannot
set that speed without federal regulations to support that.

The manufacturers in our group are also working to get the 35-mile
per hour regulations needed for this Second Car Option. The big
issue is to do with safety and federal safety experts will
probably resolve that concern.

The forty-mile range specification is one that is being used by GM
as the base range for battery use in the Volt. It is also the one
that is being used by most of the Plug in Hybrid engineers. This
specification is used because these companies have done their
homework and know that the Second Car specification is based in
real market demand. Adjusting this figure would put your
regulations in line with what the market actually needs.

It may not sound like there is a big difference between 40 and 50
mile range. The perspective from the battery side may help. That
is a 25 percent increase in performance and weight on a technology
that has been optimized over a hundred years. New technologies are
a quantum leap in cost with unproven records. Forty mile range is
actually a challenge for some of the manufacturers.

Consider that some large percentage of homes in California have
more than one car. One car for long trips is good to have and use
whenever someone needs to go more than 40 miles. The other cars in
the household can all be used around town at 35 miles per hour to
get things done. This includes at least one person’s commute,
getting to school and to soccer practices. Errands around town are
all done easily in such vehicles. If as many as half the households
have this situation then that means the second car option would
allow us to replace fully one quarter of the cars with ZEVs using
technology available right NOW.

Given that it will take time to get people to change their
thinking and their ways it is still very reasonable to think we
can get 100,000 vehicles in the market as Second Vehicles in short
order. This is particularly true when you consider that the energy
cost for such vehicles is around 1 1/2 cents per mile.

In case you have not had a chance to live with an EV, the
specification works because EVs are fundamentally different from
liquid fueled vehicles. A range of 200 miles plus is needed for a
liquid fuel vehicle so that people do not have to stop at gas
stations all the time. With an EV your home is your gas station
and you leave every morning with a full “tank of gas” (meaning a
full charge). IF you drive less than forty miles that day you
still have plenty of “gas” to get home.

Our people trust that you will choose to adjust your regulations
and get ZEVs on the road rather than keep the figures you have and
wait for reality to catch up to your ideas. The environment and our
energy security may not have the time to wait for a more perfect
solution.

Thank you for considering these concerns.

Sincerely Yours

Russell Sydney
Coordinator for the Medium Speed Electric Vehicle Working Group
Principle Organizer for the Sustainable Transport Club.
www.sustainableclub.org