Electra Meccanica (three Wheel Electric) Email-11/2/15

[airforceguy6]

How far apart are the inside edges of the existing Elio lights? Maybe they already technically conform to the standard.

I emailed Elio Motors to see if we can get a response from the company, and whether or not they are addressing the situation (either redesign or legislative change or exemption). Per the Federal Register report, the National Highway Traffic Safety Administration (NHTSA) and Department of Transportation (DOT) were the agencies responding to the Morgan headlight issue. In particular, the "headlight spacing" issue is this:

"The noncompliance involves the spacing between the headlights. Paragraph S10.17.1.2.2 of FMVSS No. 108 specifies that if motorcycle headlamps are horizontally disposed about the vertical centerline, the distance between the closest edges of their effective projected luminous lens areas must not be greater than 200 mm."

Since the headlights on the Elio are much greater than 200mm (almost 8 inches) I would like to know how Elio Motors is addressing this problem.

The full report again:
https://www.federalregister.gov/doc...for-decision-of-inconsequential-noncompliance

 

[Elio Amazed]

IMO, overall vehicle width may have something to do with which three-wheelers have to do a cyclops.

Overall width...

650 V-star Custom = 34.6"
Tango = 39"
Solo = 47.6"
Arcimoto SRK = 61.5"
Elio = 66.8"
3-wheeled ICE Morgan = 67"
Tanom Invader = 83.75"

https://www.law.cornell.edu/cfr/text/49/571.108

 

[Rob Croson]

I emailed Elio Motors to see if we can get a response from the company, and whether or not they are addressing the situation (either redesign or legislative change or exemption).

Great idea.

effective projected luminous lens areas

This phrase is key. It's not that the edges of the lenses have to be 200mm, it's the area through which the light shines. You can't make one giant lens that goes across the whole front of the vehicle and say you only have one light. You have to measure across the area actually used by the beam.

 

[slinches]

Answered my own question.

Looking at a front end photo of the P5 and using the track width as a measure, the spacing looks to be at least 17 inches apart. So it seems not to meet the letter of those requirements as stated above.

 

[DeltaMike]

That ruling is a very interesting read. It points out some of the very real legislative problems of three-wheelers. It greatly underscores the need for an autocycle law.

There were actually two requested inconsequential noncompliances in that petition. The first being the headlight spacing, and the second being that the headlight lenses don't have a DOT stamp indicating compliance with DOT regulations. The DOT stamp doesn't really concern us. It's a silly thing that Morgan just dropped the ball on, then tried to weasel their way out of. The headlight spacing issue does apply to Elio's case, though.

Morgan argues that the wide spacing of the headlights is actually safer, because it more clearly delineates the wider dimensions of the vehicle, which would be masked by the narrower spacing required by the regulations. DOT fires back that:
1) The narrower spacing required by regulations is intended to inform other drivers that the vehicle they are seeing is actually a motorcycle
2) The wider spaced headlights are still not as wide as the vehicle, so do not fulfill the purpose Morgan claims of showing others how wide the vehicle is
3) If Morgan is worried that other drivers won't be able to accurately gauge the full width of the vehicle, then they should use auxiliary lighting (e.g., parking lamps)
4) Motorcycle laws allow the use of headlight modulation, and if Morgan were to use modulation in combination with wide-spaced headlights then they may be mistaken for an emergency vehicle
5) Morgan's proposed single, center-mount headlight means that their wider-spaced lights are now considered auxiliary lights, and may now interfere with the regulation regarding auxiliary lights and the impairment of other lights such as turn signals


Issues 1 and 2 are directly relevant to the Elio, and 3 is something that several people here have been concerned about. The Elio is as wide as a standard four-wheel car, but has narrower spaced headlights. Having non-illuminated parts hanging out substantially farther than the vehicles lights is unusual, and will not be anticipated by other drivers. Cars just don't have that, and quite a few people here have already mentioned that they are worried about people not realizing how far out the wheels extend. If Elio offered an option of having marker lights on the wheel pods, I'd probably get it. It is something that I would consider as after-market equipment, depending on cost.

Elio's headlights don't meet the requirements of motorcycle headlights with regard to spacing. Do they have an inconsequential noncompliance ruling already? If not, are they going to get one? If they choose to go Solo's route and add a center headlight, then do their wider spaced "auxiliary lights" cause compliance problems with regard to turn signals, as NHTSA implied with regard to the Morgan's lights?

The Elio crosses the line between four-wheeled cars and motorcycles. It needs to be thought of by the public as a car so it can gain the high-volume sales it needs to succeed. In order to do that it needs to look as much like a car as possible. A single, center mount headlight doesn't do that. Having to meet regulations that prevent its acceptance as a car, and in the process may actually make things less safe, is really what the autocycle regulations are intended to address.

Some good work, guys. I've been consumed by family health crises in the midst of this conversation...and couldn't follow up w more research. Seems like that was done. I am tilting in favor of a Federal autocycle designation not only for this but for CAFE as well. I don't recall if the FMVSS specifies headlight but EM might put the headlights in the grille and designate the present ones as auxiliary. Honestly it's clear the standard was intended for narrow, two-wheelers rather than wide three wheelers. That's the flaw w specification-based rules rather than performance-based rules. Sigh. Again, good work on your follow-up and my bad for lack of same.
[edit] I see 22-54 inches above ground is required. Is that still within the grill dimension by an estimate, anyone?

 

[Elio Amazed]

Great idea.


This phrase is key. It's not that the edges of the lenses have to be 200mm, it's the area through which the light shines. You can't make one giant lens that goes across the whole front of the vehicle and say you only have one light. You have to measure across the area actually used by the beam.

Not much of a difference there in most lights if any. Research the terminology and the science.

 

[airforceguy6]

Hey all, received a reply from EM today:

 

[Stephen Workman]

From the Electra Meccanica Facebook Page dated November 10th, 2016...

"Electra Meccanica Vehicles will honor your deposit of up to $1,000 made on any car so you can drive SOLO instead.
Send your receipts to: info@electrameccanica.com"

 

[Coss]

From the Electra Meccanica Facebook Page dated November 10th, 2016...

"Electra Meccanica Vehicles will honor your deposit of up to $1,000 made on any car so you can drive SOLO instead.
Send your receipts to: info@electrameccanica.com"

That's old news; Rickb told us about it months ago.

And you thought it would be enough to rattle someone? Weak, really weak.

 

[Rickb]

The Solo is starting to look very affordable at $15,000 US - the $1000 vehicle deposit credit - the $2500 Electric Motorcycle Tax Credit = $11,500.