We require noisy EVs for safety, but let’s stop the real killers: SUVs & gas

Much has been made of the supposed danger to pedestrians from quiet electric cars, to the point where the government now requires noisemakers on each EV model. But if we really want to save pedestrians, and everyone else, we need to target the actual culprits: big, pedestrian-killing SUVs and trucks, and the associated pollution they create.

The noisemaker rule has finally gone into effect, after being tweaked and pushed back over the course of several years. This has resulted in noisier EVs, each with its own noise (some worse than others), in the name of pedestrian safety.

NHTSA’s rule was based on a DOT analysis that showed hybrid vehicles to be 17% more likely to be involved in a pedestrian crash, when accounting for situational factors and vehicle age, though this analysis only included hybrid vehicles up through the 2011 model year. The law mandating the DOT to study and propose a rule for this dates back to 2010, when only a handful of electric cars were on the road in the US.

When implementing the noisemaker rule, NHTSA estimated these noisemakers will save 32 lives over the lifecycle of a single model year’s fleet. The rule requires noisemakers for EVs and hybrids when operating under 19 mph, the safest speeds for pedestrians. It does not require noisemakers or minimum decibel levels for gas-powered vehicles, even if those vehicles are equipped with engine stop/start or other technologies which make the engine quieter or silent in certain situations – for example, when slowing down and approaching an intersection, a place pedestrians are likely to be.

And as of February of this year, NHTSA has even opened an investigation into whether every electric vehicle since 1997 should be retrofitted, at some cost and difficulty, in order to comply retroactively with the noisemaker rule, in a way that virtually no other vehicle regulation has ever been implemented. The petition itself acknowledges there is no data yet showing relative danger from EVs that are not equipped with noisemakers.

What’s really deadly to pedestrians? SUVs

But there’s another common vehicle type that is 45% more likely to kill pedestrians: “light trucks,” a classification that includes SUVs and pickup trucks. Though “light” might be an odd word to apply, given that today’s SUVs are as large as literal tanks.

Light trucks are more deadly to pedestrians because they are larger and have higher hoods, resulting in decreased pedestrian visibility for drivers (with pedestrians obscured behind hoods, or behind other vehicles that are taller than the pedestrians or cyclists on the other side of them) and more deadly pedestrian impacts.

Cars are required to have bumpers designed for pedestrian safety, but light trucks have a different set of requirements. This leads to light trucks impacting pedestrians higher on the body, which causes more injury to the torso and head than the legs, resulting in deadlier collisions when a light truck is involved.

So not only are they more likely to hit pedestrians, but more deadly when they do.

And in fact, pedestrian death rates have skyrocketed in the US recently, up around 50% in the last decade, reaching the highest point in 40 years. Not coincidentally, SUV sales rates have increased in the same time frame. More deadly vehicles on the road have resulted in more pedestrian death, with the growth in SUVs responsible for killing at least a thousand pedestrians as of 2019 – which is a lot more than 32. Pedestrian deaths continued to rise sharply after 2019, so that number is surely significantly higher now.

The rise of SUVs is not solely a matter of consumer preference. Automakers use light truck exemptions to get out of emissions and safety rules and make more money, and actively push consumers toward these vehicles (even though barely anyone uses them for their intended purpose). How can Americans buy wagons, or city cars, or hatchbacks, when everything on the dealer lot is an SUV?

But running over people isn’t the only way that SUVs are dangerous; the pollution they make is orders of magnitude worse.

Noise itself is deadly

The DOT’s analysis of EV pedestrian safety explicitly did not consider environmental noise as a confounding factor to its research.

In a world choked with noise pollution from combustion engine vehicles, it stands to reason that quieter vehicles would be harder to hear. But if the world were not choked with noise pollution, those quieter vehicles would no longer be too quiet, they would be the norm. In a quieter world, EVs aren’t “harder to hear” once the sounds they make are no longer masked by the pathetic belching of combustion engines. Lower noise levels are a benefit of EVs, not a downside.

Noise itself is incredibly deadly to pedestrians – or rather, to everyone. Noise, mostly from cars but also from other combustion engines (airplanes, small off-road engines, etc.), greatly increases the rate of heart attacks in noisy areas, negatively affects the health of hundreds of millions of Americans, and is responsible for 12,000 premature deaths per year across Europe. Some research shows noise pollution to be just about as deadly as vehicle crashes overall.

The government even knows this to be the case, and has for some time, as it established the Office of Noise Abatement and Control through Congressional acts in the 1970s. This office was intended to study and regulate environmental noise in the US, but was – in a phrase that should be common to people who study social ills – defunded by Reagan in the ’80s.

So since noise is deadly, and since noise itself contributes to the problem the NHTSA wants to solve (by making it harder to hear quieter cars), then why don’t we work on making less noise instead of more?

And then, there’s air pollution

And finally, air pollution is deadlier than all of the above. And air pollution overwhelmingly comes from combustion engines.

Outdoor air pollution kills over 4 million people globally per year (including 100-200K in the US) and shortens global lifespans by two years. The health and environmental costs of fossil fuels add up to $5.3 trillion globally per year.

Much of this pollution and fossil fuel use comes from gasoline-powered vehicles, with larger vehicles like SUVs consuming more fuel and emitting more pollution than smaller vehicles (and tremendously more than zero-emission EVs). Vehicle pollution results in 4 million new cases of childhood asthma per year, sentencing these children to a lifetime of health issues.

Which brings up the point that this pollution is often not killing the people who emit it. Not only are children harmed for a lifetime by this despite not having contributed to this pollution, but environmental damage is disproportionately felt by the poor and is disproportionately emitted by the affluent.

This disparity was recently pointed out by the LA Times, in an article which Tesla CEO Elon Musk criticized despite his company being one of the solutions to this problem (perhaps someone could remind him that he’s still CEO of Tesla?). We already have studies showing that more EVs means cleaner air (with each EV bringing ~$10K in societal health benefits), and we know that more gas cars means dirtier air – and more deaths.

So if you want to reduce deaths, I’ve got a proposal

We know that:

• Big cars kill more pedestrians by running them over.
• Noisy cars kill more people by increasing stress, and also cover up the noises made by cars that operate at a more appropriate volume.
• Big, noisy combustion engines kill a whole lot of people by choking them to death with pollution.

Which means these noisemakers aren’t the most effective solution to the problem they are meant to solve. More effective solutions involve doing something about noise, and about air pollution, and about big pedestrian-murdering vehicles.

This also means that EVs aren’t the only answer. While a Hummer EV (the least-efficient EV) uses about as much energy as a Toyota Prius (one of the most-efficient gas-powered vehicles), the Hummer EV also takes up more space and causes more pedestrian danger. The trend toward SUVs threatens to eliminate emissions reductions from electrification, and while electric SUVs are still vastly more efficient than any gas car, they are less efficient than smaller electric cars.

If we truly want to make the world safer for pedestrians, there are a lot of things that we can do outside of noisemakers. A discordant symphony of clown-car sound effects at every intersection isn’t going to be the big change that makes the world more walkable or cyclable.

To do that, we should put cars (or transit) on the road that don’t hog as much space, that don’t obscure pedestrians and cyclists from the view of other drivers, that don’t make the world too loud to think straight, that don’t choke everyone with stinky exhaust. These steps will give people more confidence to use their legs to make use of these more efficient, healthier, cheaper transportation methods – once these myriad benefits are no longer overshadowed by the problem of huge land yachts increasingly trying to murder them.

So here’s a modest proposal for society: If every EV needs a noisemaker for the safety gains mentioned above, then we should also take every “light truck” off the road for even more safety. If we’re thinking about making the EV rule retroactive to 1997, then we can make the much more effective SUV rule retroactive to 1997 as well. Do the latter, and you can have the former.

And if you won’t, then it’s not really about safety, is it?

Featured photo by Charles Edward Miller