Comment Log Display

We believe that it is important that the ZEV regulations should be
more specific in definition of "CITY" ZEV as to its capabilities
and equipment.

NEV (LSV) is well defined by FMVSS#500 as well as by California
Vehicle Code.

CITY ZEV could be both important and cost-effective solution to
California effort to both reduces "pollutant" emissions as well as
reduction of CO2 emissions by increased use of PURE ELECTRIC
VEHICLES in local city traffic.

Current Lead-Acid Sealed Battery technology can provide 20 to 40
mile range per charge and recharge times of under 4 hours using
standard 15A 120V AC household source.

NEV (LSV) due to their Federally mandated maximum speed of 25 MPH
on level surface over one mile distance are perceived by majority
of public as "too slow" to be safe in typical traffic patterns in
California cities where most major streets have speed limits of 35
MPH or more.

Several states (Oregon, Montana, Washington) have already adopted
MSV (Medium Speed Vehicle) regulations permitting PURE ELECTRIC
VEHICLES to attain maximum speed of 35 MPH and otherwise confirm
to FMVSS #500 (LSV).

We are asking that MSV "definition" is included in the proposed
ZEV regulations, so that further steps to include it in California
Vehicle Code and also get new class (MSV) established on a Federal
level by NHTSA can be undertaken.

CITY MSV capable of 35-MPH top speed in typical traffic would be
far more attractive to California consumers as second and/or third
in family vehicles.

Since MOST pollutants are emitted during COLD START and RE-START
of conventional vehicles, the emission reduction contribution of
MSV would be substantial.

Also the economic facts can not be ignored, if MSV is
substantially less expensive (under $10,000) than a small economy
car (now in $12,000 to $16,000 range) then far more consumers will
seriously consider its purchase especially with addition of any
grants and or tax credits.

Full function electric vehicles in costs ranging from $30,000 to
$100,000 are just small niche vehicles which will never achieve
any great market volume to make any measurable impact on the
California environment.

However low cost MSV could gain substantial popularity and reduce
the real annual gasoline vehicle miles driven by average
California family by from 3,000 to up to 7,000 miles annually.

This is significantly more annual miles than is logged by current
owners of NEV's in California.