World Blind Union Office 1929 Bayview Avenue Toronto, ON M4G 3E8 Telephone: 1-416-486-9698 Fax: 1-416-486-8107 E-mail: info@wbuoffice.org WBU External Position Statement Hybrid/Quiet Vehicles Approval: Date Reviewed: February, 2013 By WBU Officers Author: Mobility & Transportation Working Group, 2008-2012 Mitch Pomerantz, Chair Note: Executive Summary: The World Blind Union (WBU) is a non-governmental organization representing the interests of approximately 285 million blind and partially sighted persons world-wide. Pursuant to a resolution passed at the WBU’s 7th General Assembly in 2008, an initiative was incorporated into the WBU's 2008-'12 Workplan to task the Mobility and Transport Working Group with drafting a position statement on the issue of hybrid/silent vehicles, including strategies to inform and educate WBU members and to offer approaches for addressing this growing problem. This paper outlines WBU's position relative to the increasing prominence of such vehicles. It draws heavily from one previously prepared by the European Blind Union and we wish to acknowledge their efforts. ___________________________________________ Background Since the mid-2000's, hybrid and electric vehicles have become popular among an increasingly environmentally sophisticated population concerned about air pollution and its impact on health, rising fuel prices, and the need for new direction for a struggling automobile industry. Blind and partially sighted people around the world welcome this trend as long as the technology does not jeopardize our safe and independent mobility. Hybrid vehicles operate on a fuel-powered engine when driving above 20 MPH (32 KPH) and revert to a virtually silent electric motor when idling or traveling at slower speed. All-electric cars such as the Chevrolet Volt and the Smart Car operate silently without the usual engine noise, regardless of speed. Such vehicles pose a serious threat of injury or death to persons relying mainly on their hearing to assess whether it is safe to cross streets or in other hazardous areas (e.g. parking lots). Other pedestrians such as children, seniors, runners, cyclists, or merely inattentive walkers are also at increased risk. In their current stage of development, hybrid and electric vehicles are not fully in line with universal design principles. According to experiments conducted by researchers at the University of California Riverside, vehicles operating in electric mode can be hard to hear below 20 MPH (32 KPH). Above that speed the sound of tires and air flowing over the vehicle start to make it audible. Researchers determined that a Toyota Prius needed to be as much as 65 percent closer to test subjects than a car with a standard internal combustion engine before testers could judge its direction correctly. During the tests, the Prius was not heard until it was 10 feet (3.30 meters) from blindfolded volunteers. A recent study authorized by the United States National Highway Traffic Safety Administration in 12 states showed a 50 percent higher rate of accidents involving pedestrians for hybrids than for standard internal combustion vehicles. Progress and Current Status The WBU adopted a resolution on this subject at its 7th General Assembly in 2008. The resolution called upon "all regions where large numbers of vehicles are in use to advocate for research into technologies and standards to identify independently vehicles while 2 traversing streets or other areas where vehicles may be encountered," and "the United Nations and national governments to adopt a standard of sound adequate to alert pedestrians to the presence, speed, and direction of vehicles within the environment." Regarding the first imperative, serious research into what would constitute an appropriate warning sound commenced in 2010. Noise generators for quiet cars have been studied by Warwick University in the United Kingdom. In the U.S., General Motors has been conducting tests using sounds which closely imitate those of gasoline powered engines. Fiat, Lotus and Nissan have recognized the problem and have also been involved in various stages of research and testing. Japan has looked into developing guidelines, or even mandating minimum noise levels for such vehicles. Regarding the second imperative, the United Nations has been working to address the hazard posed by quiet vehicles to the safety of blind people and other pedestrians. The World Forum for Harmonization of Vehicle Regulations (WP.29), "Working Party on Noise" (GRB) created the Quiet Road Transport Vehicle (QRTV) working group charged with developing guidelines for designing alert sound devices. In early 2010, as the QRTV was working on developing voluntary guidelines, the National Federation of the Blind and the American Council of the Blind were able to persuade the United States Congress to adopt legislation mandating a minimum sound standard for hybrid electric and other quiet vehicles. As a result of the U.S. law, the United States and Japan proposed that the GRB develop a Global Technical Regulation, rather than voluntary guidelines. A new working group was formed in mid-2012 to draft the text of the Global Technical Regulation. Thus far, the group has met twice, in midJuly and in December 2012. Developing a Global Technical Regulation is complex and will involve reaching international agreement on a number of issues of immediate concern to blind individuals. Key Issues While there is consensus on developing a Global Technical Regulation, specifics about what that regulation should be are undecided. Engineers are still determining what kind of alert sound would be easily recognized as a motor vehicle, what sound level will provide 3 reasonable safety, and at what speed does the sound of the tires on the pavement and wind emit enough warning that the alert sound is no longer needed (cross-over speed). The WBU must provide direction on these issues so that the Global Technical Regulation fully protects the right of blind people to travel safely and independently. Replicating the sound of a conventional internal combustion vehicle is difficult, but it is important that the alert sound be one that is intuitively recognizable as coming from a vehicle. If the sound is not identical to that of an ordinary car, it must be close enough that the pedestrian will recognize it without the need for significant training. Additionally, the Global Technical Regulation must not specify a sound level so minimal as to compromise the safety of blind and other pedestrians. In working to find a reasonable balance between a quiet sound that puts blind pedestrians in danger and a loud sound that disturbs people, safety should be the highest consideration. Regarding the cross-over speed, sound engineers have determined that vehicles emit more sound as the speed of the vehicle increases. When the naturally occurring sound made by the vehicle reaches the same level as the alert device, the alert sound is no longer needed. Determining the correct crossover speed is essential to ensuring that blind pedestrians are able to detect the presence of a quiet vehicle from a safe distance. Other questions persist, like should a minimum sound standard apply solely to hybrid electric and electric vehicles or should it also apply to quiet vehicles using internal combustion engines? Do hybrid electric and electric vehicles need to make an alert sound while temporarily stopped, and if so, should the same requirement apply to internal combustion engines using stop/start technology? If not, should vehicles come equipped with an on-off switch allowing the driver to disable the alert sound? Does the alert sound need to change in pitch as the vehicle accelerates and decelerates? The WBU must take a position on these questions so that the safety of blind pedestrians is not compromised by the Global Technical Regulation. Hybrid electric and electric vehicles are virtually silent at low speeds, and internal combustion engines are becoming increasingly quiet, potentially posing the same hazard to blind and other pedestrians as vehicles operating on electric power. Because of this, the minimum sound standard should apply to any quiet vehicle regardless of its 4 power source. Furthermore, both types of vehicles need to make an alert sound while temporarily stopped, (i.e. at a traffic light), because a stationary vehicle may begin to move at any time. If the blind person is unaware of the presence of the car, he or she may step out unexpectedly just as the driver begins to accelerate. Vehicles operating on electric power begin moving more quickly than standard vehicles, and some newer internal combustion engines with start/stop technology literally shut off the engine and are silent while stopped. It is critical for the pedestrian to be aware of the presence of a vehicle that may suddenly start moving. Although it has been argued that there is no need for the vehicle to emit an alert sound when on a highway with no pedestrian traffic or during a late drive through a quiet residential neighborhood, allowing a driver to turn the device off would compromise the safety of blind people and other pedestrians. The driver, however well intentioned, may forget to turn the device back on or may falsely believe that he or she is in a situation in which the device is not needed. The WBU objects to an on-off switch because of the potentially dangerous consequences. Finally, it is generally understood that a change in the pitch of the alerting sound should increase as the vehicle increases speed and decreases as the vehicle slows. Today's internal combustion engines naturally change in pitch in response to a change in speed. This is known as pitch shifting. Blind people rely on changes in the pitch of internal combustion engines to make judgments about when it is safe to cross a street and to monitor the vehicle's movement. Therefore, the design of an alert sound device must incorporate pitch shifting to indicate changes in the vehicle's speed. WBU Action Items The World Blind Union urges all member nations to push for a Global Technical Regulation to have a minimum sound standard that: a. Is similar in character to the sound emitted by an internal combustion engine; b. Requires sound be emitted whenever the vehicle is in operation, including when stopped; 5 c. Applies to any quiet vehicle including electric, hybrid electric and quiet internal combustion engines; and d. Prohibits the inclusion of a driver controlled on/off switch. 6