First Name | Russell |
---|---|
Last Name | Sydney |
Email Address | main@sustainableclub.org |
Affiliation | Medium Speed Electric Vehicle Group |
Subject | Getting 100,000 ZEVs on the road within three years |
Comment | 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 |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2008-03-19 10:18:35 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.