Federal Motor Vehicle Safety Standards for Electric Vehicles

DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

49 CFR Part 571

[Docket No. 91-49; Notice 04]

RIN [2127-AF43]

Federal Motor Vehicle Safety Standards for Electric Vehicles

AGENCY: National Highway Traffic Safety Administration (NHTSA),

Department of Transportation (DOT).

ACTION: Request for Comments.

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SUMMARY: The purpose of this notice is to solicit public comments to

help NHTSA assess the need to regulate electric vehicles (EVs) with

respect to battery electrolyte spillage in a crash or rollover, and

electric shock hazard in a crash or rollover and during repair or

maintenance. Comments are requested on the potential safety hazards

associated with each, and possible regulatory solutions, for original

equipment EVs and EV conversions.

DATES: Comments must be received by November 29, 1994.

ADDRESSES: Comments on the notice should refer to the docket number and

notice number shown above, and be submitted in writing to: Docket

Section, National Highway Traffic Safety Administration, Room 5109, 400

Seventh Street, SW., Washington, DC 20590. Telephone: (202) 366-4949.

Docket hours are 9:30 a.m. to 4 p.m., Monday through Friday.

FOR FURTHER INFORMATION CONTACT:

Mr. Gary R. Woodford, NRM-01.01, Special Projects Staff, Office of

Rulemaking, National Highway Traffic Safety Administration, 400 Seventh

Street, SW., Washington, DC 20590 (202-366-4931).

SUPPLEMENTARY INFORMATION:

I. Introduction

A sizeable increase in the number of alternatively fueled motor

vehicles, including electric vehicles (EVs), in the United States is

expected. This expectation stems from initiatives by the President,

Congress, State and local governments, and private interests, since

these vehicles could help reduce air pollution and conserve petroleum

fuel.

The Clean Air Act Amendments of 1990 include provisions that

promote the use of alternative fuels in motor vehicles. Under these

Amendments, fleet vehicles sold in geographic areas with the most

serious air pollution problems will be subject to emission standards

that will require the use of clean fuels, including methanol and

ethanol, reformulated gasoline, natural gas, liquefied petroleum gas,

and electric power.

In addition, the Energy Policy Act of 1992 (EPACT) requires

Federal, State, and alternative fuel provider fleets to acquire

increasing percentages of alternatively fueled vehicles. The Department

of Energy is in the process of initiating a rulemaking, as required by

EPACT, to determine if private fleets should also be required to

purchase certain percentages of alternatively fueled vehicles as part

of their new fleet acquisitions.

Executive branch initiatives will also encourage the increased use

of alternatively fueled vehicles. Executive Order 12844, dated April

21, 1993, directs that purchases of alternatively fueled vehicles by

the Federal government by substantially increased beyond the levels

required by current law. It also established the Federal Fleet

Conversion Task Force to accelerate the commercialization and market

acceptance of alternatively fueled vehicles throughout the country.

A primary impetus for introduction of large numbers of EVs in the

U.S. market is a regulation of the California Air Resources Board.

Similar regulations are under consideration by other States. The

California regulation requires that not less than two percent of a

manufacturer's sales in the State (roughly 40,000 vehicles total) must

be zero emission vehicles (ZEVs), beginning in model year 1998. This

requirement will increase to 10 percent or roughly 200,000 vehicles

beginning in model year 2003. The definition of a ZEV is a vehicle that

emits no exhaust or evaporative emission of any kind. Currently, the EV

is the only vehicle which meets these requirements.

The National Highway Traffic Safety Administration (NHTSA) is

authorized by law (49 U.S.C. 30101-30169) to regulate the safety

performance of motor vehicles and motor vehicle equipment through the

issuance of Federal motor vehicle safety standards (FMVSSs). In

addition, NHTSA has the authority to issue guidelines for States to use

in state motor vehicle inspection programs.

Supplementing this authority in the area of alternatively fueled

vehicle safety, the Energy Policy Act of 1992 requires that NHTSA must

``within three years after enactment promulgate rules setting forth

safety standards in accordance with [the agency's statutory authority]

applicable to all conversions.'' In addition, the Clean Air Act

Amendments of 1990 include a provision that NHTSA promulgate necessary

rules regarding the safety of vehicles converted to run on clean fuels.

NHTSA wishes to assure the safe introduction of EVs and other

alternatively fueled vehicles to the market without impeding technology

development.

II. Background

On December 27, 1991, the agency published in the Federal Register

an advance notice of proposed rulemaking (ANPRM) on EV safety (56 FR

67038). The purpose of the notice was to help NHTSA determine what

existing FMVSSs may need modification to better accommodate the unique

technology of EVs, and what new safety standards may need to be written

to assure their safe introduction. The ANPRM requested comments on a

broad range of potential EV safety issues including battery electrolyte

spillage and electric shock hazard, and elicited widespread public

interest. A total of 46 comments were received.

After reviewing all of the comments and information received in

response to the ANPRM, NHTSA concluded in a November 18, 1992 notice

(57 FR 54354) that it was premature to initiate rulemaking for new EV

safety standards at that time. In the areas of battery electrolyte

spillage and electric shock hazard in a crash, the agency concluded

that further research was needed.

In 1993 NHTSA conducted research and testing on two converted EVs.

The vehicles were tested relative to several FMVSSs, including a crash

test in accordance with FMVSS No. 208, Occupant Crash Protection. The

two vehicles were equipped with lead-acid batteries located in the

front and rear (engine and luggage compartments). One vehicle was

equipped with twelve 12-volt batteries (five in the front and seven in

the rear). The second vehicle was equipped with ten 12-volt batteries

(four in the front and six in the rear). The tests involved frontal

crashes into a fixed barrier at 48 kilometers per hour (kph). In both

crashes the front batteries sustained significant damage, spilling

large quantities of electrolyte. On one vehicle 10.4 liters of

electrolyte spilled from the front batteries as a result of the crash.

On the other vehicle 17.7 liters of electrolyte spilled from the front

batteries. In addition, several electrical arcs were observed under the

hood of one vehicle during the crash.

Based on the results of this research and the increasing interest

in using EVs to meet clean air requirements, the agency has decided to

reexamine through this notice the safety issues involving EV battery

electrolyte spillage and electric shock hazard. NHTSA notes that the

Society of Automotive Engineers (SAE) through its various committees is

also exploring possible voluntary industry standards and guidelines in

these two areas. The agency wishes to identify the magnitude of the

potential safety hazards involved, as well as possible solutions for

both original equipment EVs and EV conversions.

With respect to conversions, NHTSA's statutory authority

distinguishes between two populations of vehicle conversions. The

distinction is based on whether the vehicle is converted before or

after the first sale to the ultimate consumer.

When a vehicle is converted to an alternative fuel before the first

sale to the ultimate consumer, the converter is in the same position as

an original vehicle manufacturer. The converter must certify that the

vehicle still complies with all applicable FMVSSs, including any fuel

system integrity standards applicable to the alternative fuel. For

example, if a converter before the first sale converted a gasoline

powered vehicle to an EV, and if NHTSA has promulgated an electrolyte

spillage standard applicable to that model year EV, the converter would

need to certify that, among other requirements, the vehicle complied

with the electrolyte spillage requirements. In the case of a

noncompliance, the manufacturer or converter must recall and remedy the

noncompliant vehicles by repair or replacement; in addition, NHTSA has

the authority to impose a civil penalty of $1000 per violation up to a

maximum of $800,000.

By contrast, if a vehicle is converted after the first sale to a

consumer, different requirements apply. 49 U.S.C. 30122(b) provides

that:

A manufacturer, distributor, dealer, or motor vehicle repair

business may not knowingly make inoperative any part of a device or

element of design installed on or in a motor vehicle * * * in

compliance with an applicable Federal motor vehicle safety standard.

This includes a vehicle's fuel system. (The prohibition only

applies to a converter which is functioning as a ``manufacturer,

distributor, dealer, or motor vehicle repair business,'' not to an

individual or to a commercial entity which converts a vehicle for its

own purposes.) This provision differs from requirements before first

sale in that the converter does not ``certify'' compliance with the

standard, but instead must not ``knowingly make inoperative.''

Using the above example of conversion from gasoline to EV, if a

converter after first sale to the consumer converted a gasoline-powered

vehicle to an EV, and if NHTSA regulated electrolyte spillage for that

model year vehicle, the converter need not certify compliance to the

electrolyte spillage standard. However, the converter could not

knowingly perform the conversion in such a way that the vehicle would

fail to meet the requirements of the electrolyte spillage standard. If

this standard was tested for compliance by means of crash tests, this

might be impractical for converters. Therefore, for aftermarket

conversions, NHTSA is exploring the promulgation of regulations which

would define ``make inoperative'' in terms of design requirements as a

surrogate for the FMVSS requirements. The penalty for noncompliance

with Section 30122(b)'s make inoperative provision is $1000 per

violation, up to a maximum of $800,000.

In addition to Federal motor vehicle safety standards, NHTSA has

the statutory authority to issue vehicle safety inspection standards

which can serve as guidelines for those States which conduct safety

inspection programs. The agency could issue such inspection standards

for EVs, which a State could voluntarily use if it opts to conduct

vehicle inspections for converted EVs.

Thus, in this notice NHTSA seeks comments on a variety of possible

approaches to address the potential safety hazards of EV battery

electrolyte spillage and electric shock hazard. Among the possible

options are:

(1) Federal safety regulation for EVs and EVs converted before the

first sale to a consumer. These would most likely be primarily

performance oriented requirements, such as in FMVSS No. 301, Fuel

System Integrity, which limits the amount of allowable fuel leakage for

liquid fuels after a barrier crash and rollover test. Although the

agency's goal in establishing safety standards is to have performance

oriented requirements, the agency does have some latitude to establish

design oriented requirements when necessary or more appropriate.

(2) Regulations to define the term ``make inoperative'' in Section

30122(b) as it applies to EVs converted after the first sale to a

consumer. These regulations would most likely be design oriented, since

it may not be practical for a converter to crash test, and thereby

destroy, the converted vehicle. Such regulations would help vehicle

converters understand what constitutes ``make inoperative'' in

converting a vehicle to electric power. An example of such regulations

could be where to locate or how to protect the EV batteries so as to

minimize battery damage and therefore minimize electrolyte spillage in

a crash.

(3) Vehicle safety inspection standards to serve as guidelines for

those States which conduct motor vehicle safety inspection programs.

The agency could issue such inspection standards for EVs, which a State

could voluntarily use if it chooses to conduct vehicle inspections of

EVs, both original equipment and conversions.

III. Potential Problem Areas and Possible Solutions

In this section of the notice NHTSA requests comments on the

potential safety hazards due to EV battery electrolyte spillage in a

crash or rollover, and due to electric shock in a crash or rollover and

during repair and maintenance. Information is also sought on possible

means to address such hazards through performance and design

requirements for original equipment EVs and EV conversions. Information

is requested separately for (1) EVs with a GVWR of 4536 kg or less and

all school buses, which is the population of vehicles NHTSA

traditionally has regulated for fuel system integrity, and for (2) EVs

with a GVWR greater than 4536 kg, excluding EV school buses, since

there may be potential safety hazards and possible approaches which are

unique to vehicles of this size and type. Finally, other information on

EVs is requested, including current and projected EV populations and

production, industry and State or local guidelines on EV safety, hybrid

EVs, charging, batteries, and starter interlock performance.

This section of the notice is organized as follows:

A. Battery Electrolyte Spillage

--Potential Safety Problem

--Possible FMVSS Performance Requirements

--Possible Requirements for Conversions After First Sale to

Consumers

--EVs With GVWR Greater Than 4536 Kilograms

B. Electric Shock Hazard

--Potential Safety Problem

--Possible FMVSS Performance Requirements

--Possible Requirements for Conversions After First Sale to

Consumers

--EVs With GVWR Greater Than 4536 Kilograms

C. Other

A. Battery Electrolyte Spillage

Potential Safety Problem

Currently-produced EVs carry onboard the vehicle a relatively large

number of batteries, and therefore a substantial amount of electrolyte

solution. Because of the hazards of electrolyte, there is the potential

in a crash or rollover for injury to vehicle occupants, bystanders, and

emergency rescue and clean-up personnel. The agency requests comments

on the potential safety hazards for EVs with a GVWR of 4536 kg or less,

and all EV school buses regardless of weight.

1. Describe the different types of propulsion batteries which are

expected to be used in EVs over the next five and ten years, including

the form (liquid or gel), chemical properties, and temperatures of the

various electrolyte solutions. Which of the electrolyte solutions are

acidic, basic, or water reactive, and to what extent? How many

batteries and what quantity of electrolyte are expected to be onboard

EVs over the next five and ten years? Where will the batteries be

located on EVs?

2. Is there a potential safety problem with electrolyte contacting

occupants, bystanders, rescue teams, or clean-up personnel as a result

of an EV crash or rollover? If so, what are the potential safety

consequences? Can chemical or thermal burns result? Is there the

potential for toxic or asphyxiant vapors? If so, from which

electrolytes and due to what quantities of spillage?

3. What is the potential fire hazard of spilled or sprayed

electrolyte in a crash or rollover? Could battery electrolyte ignite in

the same way as a fuel? If so, which electrolytes and in what

quantities, concentrations, or mixtures, and at what temperatures? What

is the likelihood that leaking electrolyte at a crash scene could serve

as an electrical conductor or short circuit, thereby creating a fire

hazard?

4. The agency understands that sodium-sulphur batteries operate

with liquid coolant at approximately 316 degrees C., which circulates

around the batteries and through a heat exchanger onboard the EV. The

temperature of liquid coolants for internal combustion engines on

conventional vehicles is much lower, approximately 91 degrees C.

Further, sodium-sulphur batteries require an extremely strong vacuum

insulated container to retain the heat and prevent spillage in an

accident. Sodium can explode if it comes into contact with water. Is

there a potential safety problem with high temperature battery coolants

contacting occupants, bystanders, rescue teams, or clean-up personnel

as a result of an EV crash or rollover? If so, what are the safety

concerns? Can burn injuries result? What types of coolants are used

with EV batteries, and what are their corresponding temperature ranges

during driving and charging operations?

5. Describe the likelihood and potential safety consequences of

having spilled electrolyte from an EV crash mix with a different

electrolyte or with other vehicle fluids, such as gasoline, diesel

fuel, engine coolant, or oil. Could a chemical fire or explosion occur,

and if so, with which electrolytes and fluids? Is there the potential

for toxic or asphyxiant vapors? Please discuss.

6. Describe all EV crashes or rollovers or noncrash events

involving spilled electrolyte, including the sequence of events, a

description of the EV, and the type of electrolyte which spilled. Were

there injuries or fatalities as a result of the spilled electrolyte? If

so, please describe.

7. Discuss the need for federal regulation to address the potential

safety hazards of battery electrolyte spillage in a crash or rollover,

or noncrash event.

Possible FMVSS Performance Requirements

One approach which the agency could use to address electrolyte

spillage in a crash or rollover is to limit the amount of allowable

spillage through a performance test. This could be similar to the

requirements in FMVSS No. 301, Fuel System Integrity, which limits the

amount of allowable liquid fuel spillage after barrier crash and static

rollover tests. FMVSS No. 303, Fuel System Integrity of Compressed

Natural Gas Vehicles, contains similar crash test limitation

requirements. FMVSS No. 301, for example, after barrier crash tests

requires that there be no more than (1) One ounce (28 grams) by weight

of liquid fuel loss from the time of barrier impact until vehicle

motion has ceased, (2) five ounces (142 grams) during the next five

minutes, and (3) one ounce (28 grams) per minute during the next 25

minutes. These requirements apply to vehicles of 10,000 pounds (4536

kg) GVWR or less when subjected to a 30 mph (48 kph) frontal fixed

barrier crash test, or 20 mph (32 kph) lateral or 30 mph (48 kph) rear

moving barrier crash test. For school buses with a GVWR greater than

10,000 pounds (4536 kg), FMVSS No. 301 requires a 30 mph (48 kph)

moving barrier impact at any point from any angle on the bus with the

same allowable fuel loss. FMVSS No. 301 has similar fuel spillage

limitations during a static rollover test, following a crash test, for

vehicles of 10,000 pounds (4536 kg) GVWR or less.

Comments are requested on possible approaches for addressing the

safety hazards of electrolyte spillage in a crash or rollover for EVs

with a GVWR of 4536 kg or less, and for all EV school buses regardless

of weight.

8. Discuss the appropriateness of using an approach similar to that

of FMVSS No. 301 to regulate the safe performance of EV electrolyte

spillage in a crash or rollover.

9. What would be an appropriate amount of electrolyte spillage to

allow after a crash or rollover test? Please discuss. Should it be

based on the number or type of batteries onboard the EV, or whether

spillage occurs inside or outside the passenger compartment or cargo

areas? If so, how much should be allowed? For example, should a ``level

of hazard'' be defined by battery type, which would allow spillage of

larger quantities of less harmful electrolytes and smaller quantities

of the more harmful electrolytes? Would it be appropriate to require no

spillage? Is there an amount that would approximate the no-spillage

condition?

10. Would it be appropriate to set similar requirements for the

spillage of high temperature liquid coolants from EV batteries? If so,

what should be the allowable amounts of spillage? What should be the

threshold temperature above which spillage requirements are needed?

11. Are there other performance requirements that should be

considered in addressing the safety hazards of EV battery electrolyte

spillage in a crash or rollover? If so, please describe them.

Possible Requirements for Conversions After First Sale to Consumers

In the case of EVs converted after first sale to a consumer, where

the ``make inoperative'' requirements apply, it may not be practical to

test for the safe performance of electrolyte spillage through a crash

test since this would destroy the converted vehicle. Design oriented

requirements may be more appropriate, such as defining where to locate

or how to protect the EV batteries in a crash or rollover. Comments are

requested on possible approaches for EVs with a GVWR of 4536 kg or

less, and all EV school buses regardless of weight.

12. For EVs converted after first sale to a consumer, would it be

appropriate to define the term ``make inoperative'' as being not able

to comply with the performance requirements of a crash standard? For

example, would it be appropriate to require such EV conversions to be

tested in accordance with any crash test requirements the agency may

establish relative to battery electrolyte spillage? please discuss.

13. Alternatively, would it be appropriate to establish separate

design requirements as a surrogate for performance requirements, to

address electrolyte spillage in a crash or rollover for EV after-first-

sale conversions? Please discuss. Would such requirements provide a

level of performance comparable to that of a vehicle crash test? If so,

please describe them.

14. Discuss the appropriateness of requiring that batteries be

placed onboard the EV at locations which minimize their damage in a

crash or rollover, or in a protective box. What locations would

minimize battery damage? What requirements should be placed on battery

box design, construction, or testing? Should the boxes be constructed

with dual walls to allow some crush of the outer wall in a crash or

rollover?

15. Would it be appropriate to require that all batteries be

equipped with threaded vent/filler caps, rather than friction-fit caps,

to minimize electrolyte spillage? Alternatively, should only sealed

batteries be used--those without vent/filler caps?

16. Discuss the need for EV labeling with respect to electrolyte

spillage. Should EVs be labeled with the type of battery electrolyte

onboard the vehicle to assist emergency rescue teams at a crash scene?

17. Would such design requirements be appropriate for States to use

as guidelines in conducting motor vehicle safety inspection programs:

If not, what requirements would be more appropriate? Please describe

them.

EVs With GVWR Greater Than 4536 Kilograms

In this section of the notice NHTSA requests comments in response

to items 1 through 17 above, as they apply to original equipment EVs

and EV conversions with GVWR greater than 4536 kilograms, excluding

school buses. These include transit buses, intercity buses, trucks, and

other heavy vehicles. NHTSA requests information on this group of

vehicles separately, since there may be potential electrolyte spillage

problems, and possible solutions, which are unique to such heavy

vehicles.

18. Please provide the information requested in Questions 1-17

above, as it applies to EVs with a GVWR greater than 4536 kg, excluding

school buses. Should these types of EVs be regulated for electrolyte

spillage in a crash or rollover? Are there unique safety hazards among

EVs of this size and type?

19. Should heavy EVs, other than school buses, be crash tested for

electrolyte spillage in the same way as heavy school buses in FMVSS No.

301, Fuel System Integrity, where a contoured barrier traveling at 48

kph strikes the vehicle at any point and angle? Please discuss. Are

there other approaches which would be more appropriate for addressing

electrolyte spillage in heavy EVs? For example, what type of design

standard or alternative approach would be necessary to provide a level

of safety equivalent to that of FMVSS No. 301, and how would this be

evaluated?

B. Electric Shock Hazard

Potential Safety Problem

The electric propulsion systems for current technology EVs operate

at a relatively high level of electric power. In the case of the two EV

conversions which the agency crash tested in 1993, the nominal voltage

levels for the electric propulsion systems were 120 and 144 volts with

a maximum battery system current limit (controlled by fuse) of 400 and

350 amps for the Sebring and Solectria vehicles, respectively. Current

technology EVs have battery voltage levels up to 400 volts or more, and

maximum current ratings up to 400 amps. Because of these high levels of

electric power, there is the potential for electric shock to occupants

and rescue teams as a result of an EV crash or rollover. There is also

the potential for electric shock to persons performing EV repair and

maintenance.

The agency requests information on the potential safety hazards of

electric shock for EVs with a GVWR of 4536 kg or less, and all EV

school buses regardless of weight.

20. What levels of voltage (volts) and current (amps) are expected

to be used in EV propulsion systems over the next five and ten years?

Do these levels depend on vehicle size or the type of electric drive

system onboard the EV (AC or DC)? Please describe.

21. Describe the potential for electric shock to vehicle occupants

and rescue teams as a result of an EV crash or rollover. How could

electric shock be incurred by each? What technologies and designs are

being incorporated by EV manufacturers to minimize or eliminate such

hazard?

22. Describe the potential for electric shock to trained service

personnel and ``do-it-yourself'' persons while performing EV repair and

maintenance. How could electric shock be incurred by each? What

technologies, designs, instructions or labeling are being incorporated

by EV manufacturers and converters to minimize or eliminate such

hazard?

23. Provide the minimum levels of electric shock to the human body

in terms of current, time, and voltage (up to 600 volts), which can

produce injuries and fatalities. Describe the types of injuries that

can be incurred, along with the corresponding levels of current, time,

and voltage. Can such injuries be related to the Abbreviated Injury

Scale (AIS) for automotive medicine? What levels and time periods can

cause fatal injury? Do these vary based on whether the current is AC or

DC, or on the age, weight, and general health of the person? Please

discuss.

24. Describe the potential for an electrical fire as a result of an

EV crash or rollover. How could an electrical fire occur? Is it

possible for a high power electrical connector or conductor onboard the

EV to become short circuited to another object, become overheated, and

thereby cause a fire? What is the likelihood of this?

25. Describe all incidents of electric shock to occupants or rescue

teams as a result of an EV crash or rollover or noncrash event, or to

persons performing EV repair or maintenance. Include a description of

the circumstances, the vehicles and persons involved, and what type and

severity of injury or fatality that occurred due to electric shock.

26. Discuss the need for federal vehicle regulation to address

electric shock hazard as a result of an EV crash or rollover, noncrash

event, or during EV repair or maintenance.

Possible FMVSS Performance Requirements

NHTSA requests comments on possible approaches for addressing the

safety hazards of electric shock in a crash or rollover, and during

repair and maintenance, for EVs with a GVWR of 4536 kg or less, and all

EV school buses regardless of weight.

27. Would it be appropriate to require EV circuit interrupter

performance in a crash or rollover, which would automatically

disconnect the propulsion batteries from all other electrical circuits

and thereby prevent high voltage and current flow to other parts of the

vehicle? Such response would be similar in timing and deceleration

level to that of an occupant protection airbag in a crash. Does the

technology exist to require such performance of a circuit interrupter

for EV propulsion batteries in a crash or rollover? Please discuss.

28. What time period, deceleration level, and vehicle attitude

should be required for circuit interrupter performance of EV propulsion

batteries in a crash or rollover? Should these be related to the

minimum injury levels for electric shock discussed earlier, or whether

the EV drive system is AC or DC? What types of circuit interrupter

device should be required? Please discuss.

29. What is an appropriate method of compliance testing circuit

interrupter performance of EV propulsion batteries in a crash or

rollover? Would an EV crash test (front, side, or rear) and static

rollover test, as in FMVSS No. 301, be appropriate, where performance

of the circuit interrupter could be measured over time at a certain

deceleration or vehicle attitude? Alternatively, could a component test

of the circuit interrupter be conducted, which would eliminate the need

for a vehicle crash test? Please discuss.

30. Would it be appropriate to require that EV batteries,

connectors, cables, and wiring be located, routed, and insulated so as

to minimize or eliminate electric shock hazard due to a crash or

rollover, or during repair and maintenance? Similarly, should there be

a requirement for minimum wire size in EV circuits? For example, what

should be the minimum wire sizes for AC and DC propulsion drive

circuits ranging from 120 to 600 volts? Should there be a requirement

that EV propulsion circuits not be grounded to the vehicle chassis

(electrically isolated)? What standards and guidelines are being used

by current EV manufacturers and converters? Please discuss.

31. Would it be appropriate to require EVs to have a means of

manually disconnecting the propulsion batteries from other EV circuits

for safety during repair or maintenance? Additionally, should circuit

interruption performance be required of EV circuits through means such

as fuses, circuit breakers, or ground fault interrupters? What types

should be required? Are EV controllers typically equipped with

capacitors which can remain energized even after the main power circuit

has been disconnected? What technologies are available? Please discuss.

32. Would it be appropriate to require EV labeling and written

instructions to minimize electric shock hazard as a result of a crash

or rollover, or during repair or maintenance? Should an EV be labeled

as ``Electric Vehicle,'' along with labels or instructions on the

location and method of manually disconnecting the propulsion batteries?

Please discuss.

33. Should there be requirements for battery container dielectric

strength? If so, what levels should be established and how should this

be tested? What standards currently exist? Please discuss.

34. Are there other performance requirements that should be

considered in addressing the safety hazards of electric shock in EVs as

a result of a crash or rollover, or during repair or maintenance? If

so, please describe them.

Possible Requirements for Conversions After First Sale to Consumers

In the case of EVs converted after first sale to a consumer, where

the ``make inoperative'' requirements apply, it may not be practical to

test for electric shock safety through a crash test since this would

destroy the converted vehicle. Design oriented requirements may be more

appropriate. Comments are requested on possible approaches for EVs with

a GVWR of 4536 kg or less, and all EV school buses regardless of

weight.

35. Please provide the information requested in Questions 27-34

above, as it applies to EVs converted after the first sale to a

consumer.

36. Are there other design requirements that should be considered

in addressing the safety hazards of electric shock in EV conversions as

a result of a crash or rollover, or during repair or maintenance? If

so, please describe them.

EVs With GVWR Greater Than 4536 Kilograms

In this section comments are requested in response to items 20

through 36 above, as they apply to original equipment EVs and EV

conversions with GVWR greater than 4536 kilograms, excluding EV school

buses. These include transit buses, intercity buses, trucks, and other

heavy vehicles. NHTSA requests information on this group of vehicles

separately, since there may be potential electric shock hazards, and

possible solutions, which are unique to such heavy vehicles.

37. Please provide the information requested in Questions 20-36

above, as it applies to EVs with a GVWR greater than 4536 kg, excluding

EV school buses.

38. Are there unique safety hazards among EVs of this size and

type? Should these types of EVs be regulated for electric shock hazard

in a crash or rollover, or during repair and maintenance? If so, how?

C. Other

Other information on EVs is requested for both original equipment

EVs and EV conversions of all sizes, addressing hybrid electric

vehicles, standards and guidelines, EV populations, charging,

batteries, and starter interlock performance, as follows:

Hybrid Electric Vehicles

39. Are there unique safety problems presented by hybrid electric

vehicles (HEV) relative to electrolyte spillage or electric shock? An

HEV is one which can operate on electric power, another fuel such as

gasoline, or both. Are there any unique safety problems which could

occur when both fuel sources are being utilized? Are there other

potential safety problems which should be considered relative to HEVs,

or EVs equipped with range extenders? Please discuss.

Standards and Guidelines

40. Describe industry, State, or local standards or guidelines that

could be used to address the safety hazards of EV battery electrolyte

spillage or electric shock. Are there standards or guidelines for

industrial or recreational vehicles, such as forklifts or golf carts,

which could be applied to EVs? Please describe.

41. Which States require motor vehicle safety inspection of EVs,

and what are the requirements? Please describe.

EV Populations

42. Provide estimates of the number of EVs in operation within the

United States today, and the number expected within the next five and

ten years. Please categorize by vehicle type. For vehicles with GVWR

less than or equal to 4536 kg, categorize by passenger car, pickup

truck, van, and other. For vehicles with GVWR greater than 4536 kg,

categorize by school bus, transit bus, intercity bus, heavy truck, and

other. What portions of these represent original equipment EVs, EV

conversions before the first sale to a consumer, and EV conversions

after first sale? Which types of EV propulsion batteries are expected

to be used? Please describe.

43. What is the likelihood that there will be an EV conversion

industry for used vehicles, i.e., those converted after first sale to a

consumer? Please discuss.

Charging

44. Describe the technology and potential safety problems

associated with EV recharging. Should there be federal safety

requirements? Should these include requirements for battery box venting

or flame arrestor performance, to protect against emissions of

explosive battery gases during recharging and other times of vehicle

operation? What standards, guidelines, or design practices are being

followed by manufacturers and converters to assure EV safety in this

area? Please discuss.

Batteries

45. Is there a potential safety hazard with EV batteries becoming

projectiles in a crash or rollover? Should there be federal

requirements for battery restraints? What standards, guidelines, design

practices, or other requirements are currently being followed by

manufacturers and converters? Please discuss.

46. What Federal, State, and local requirements currently exist for

the disposal, recycling, and transport of EV batteries? Do the

requirements distinguish between batteries which are damaged and leak,

and those which do not leak? Please discuss.

Transmission Starter Interlock

47. The agency understands that some EVs have a forward, neutral,

and reverse switch, while others have no neutral position or other

means such as a clutch for disconnecting the drive train from the

propulsion motor. Is there a potential safety problem with inadvertent

starting and unwanted vehicle motion among those EVs which have no

means of disconnecting the drive train? Please discuss.

48. What types of EV drive train designs are expected over the next

five and ten years? Is there a need for requiring EV starter interlock

performance, similar to that required on automatic transmissions in

FMVSS No. 102, Transmission Shift Level Sequence, Starter Interlock,

and Transmission Braking Effect? FMVSS No. 102 requires that the engine

starter be inoperative when the transmission shift level is in a

forward or reverse drive position. Please discuss.

Submission of Comments

The agency invites written comments from all interested parties. It

is requested that 10 copies of each written comment be submitted.

No comment may exceed 15 pages in length. (49 CFR 553.21).

Necessary attachments may be appended to a comment without regard to

the 15-page limit. This limitation is intended to encourage commenters

to detail their primary arguments in a concise fashion.

If a commenter wishes to submit specified information under a claim

of confidentiality, three copies of the complete submission, including

purportedly confidential business information, should be submitted to

the Chief Counsel, NHTSA, at the street address given above and seven

copies from which the purportedly confidential information has been

deleted should be submitted to the Docket Section. A request for

confidentiality should be accompanied by a cover letter setting forth

the information specified in the agency's confidential business

information regulation, 49 CFR part 512.

All comments received before the close of business on the comment

closing date indicated above for the proposal will be considered, and

will be available for examination in the docket at the above address

both before and after the closing date.

To the extent possible, comments filed after the closing date will

also be considered. NHTSA will continue to file relevant information as

it becomes available in the docket after the closing date, and it is

recommended that interested persons continue to examine the docket for

new material.

Those persons desiring to be notified upon receipt of their

comments in the rules docket should enclose a self-addressed, stamped

postcard in the envelope with their comments. Upon receiving the

comments, the docket supervisor will return the postcard by mail.

(49 U.S.C. 322, 30111, 30115, 30117, and 30166; delegations of

authority at 49 CFR 1.50)

Issued on: September 26, 1994.

Stanley R. Scheiner,

Acting Associate Administrator for Rulemaking.

[FR Doc. 94-24165 Filed 9-29-94; 8:45 am]

BILLING CODE 4910-59-M