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

[Elio Amazed]

Again, Morgan applied for an exemption based on a hoped-for inconsequential noncompliance determination...
It it also included vehicles already registered in the US. They even appealed it after they were denied the first time...
And were again denied. They have not, to the present date, received approval on their application for exemption
Neither have they received approval on any "inconsequential noncompliance determination".

They were basically told that they were still in violation on those vehicles already registered.
And that they would have to "recall", and make modifications to, any and all such vehicles...
Who's owner would so choose to have their vehicle brought into compliance.

I read all of this two weeks ago.

I have also communicated with another three-wheeled manufacturer on this subject.

If you still believe otherwise, please provide a link to the specific language that verifies your claim.

Thanks

 

[Stephen Workman]

Although several of us former Elio fans have moved our support (and our $) over to Electra Meccanica for the SOLO Alpha Series vehicle, it doesn't mean that we (I don't feel I'm speaking for only myself here) don't still wish fervently to share the roadways with our Elio-driving brothers & sisters. I want a new vehicle in 2017 - I have more faith in Electra Meccanica to make that happen sooner than Elio. Plus, I just like PEVs more than ICE - for a three mile round trip daily commute. I'm certain as the wait grows longer, more of my Elio enthusiast friends will join us over at the soloowners.net forum. If nothing else come over and get some info and ask questions...what else have you got to lose with with all the time from now until 4th quarter 2017?

 

[Elio Amazed]

Not a generic exemption. Morgan had a inconsequential noncompliance determination. Very often a petitioner will reference an earlier IN determination in their petition. Morgan referenced a GM petition and determination tho it was not completely on point. It was about daylight running light systems on their cars that were in technical noncompliance. After reading in the Federal Register the many petitions and determinations I came to conclude this is a nonissue for EM even tho they may not have actually have petitioned at this point.

Took me a while Mike, but here it is...

Morgan 3 Wheeler Limited, Denial of Petition for Decision of Inconsequential Noncompliance
From the Federal Register Dated 04/12/16...

https://www.federalregister.gov/doc...for-decision-of-inconsequential-noncompliance

 

[Rob Croson]

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.

 

[Rickb]

No need to promote or encourage a Federal Autocycle classification. Perhaps a headlight addendum for trikes to the existing MC Classification would be a simple less governmental restrictive solution. Corbin's Sparrow passed the final DOT vehicle compliance back in 1999. The Solo designers added a center headlight to it's hood, perhaps EM should simply add lights and/or reflectors to the Elio fenders if visibility is an issue. If a vehicle has an enclosed cabin people will refer to it as a car. My 2 cents.

 

[Rob Croson]

No need to promote or encourage a Federal Autocycle classification. Perhaps a headlight addendum for trikes to the existing MC Classification would be a simple less governmental restrictive solution.

Perhaps. IANAL, so I can't say for sure. I do think that this is something that could really benefit from some work.

Corbin's Sparrow passed the final DOT vehicle compliance back in 1999.

I cringe whenever I see a picture of that thing. No way that thing could ever see widespread adoption in the US.

The Solo designers added a center headlight to it's hood, perhaps EM should simply add lights and/or reflectors to the Elio fenders if visibility is an issue.

Yes, Solo did essentially the same thing Morgan proposed. A center-mounted headlight, and converting the others to separately switched "auxiliary" lights. That center-mounted light would screw up the Elio's critical aerodynamics. A single headlight in the middle looks ... cheap. The way Solo did it with the dual lights looks much better. Maybe you could do something "high tech" like a wide LED light bar that could be shorter, and more aerodynamic, and give a cool high-tech look like you see on a lot of the higher priced vehicles now.

I would be surprised, and more than a little disappointed, to find that EM had not already considered the headlight issue. They are, after all, suppose dot be the experts at this. Having something like this slip by them would be surprising.

 

[airforceguy6]

Perhaps. IANAL, so I can't say for sure. I do think that this is something that could really benefit from some work.


I cringe whenever I see a picture of that thing. No way that thing could ever see widespread adoption in the US.


Yes, Solo did essentially the same thing Morgan proposed. A center-mounted headlight, and converting the others to separately switched "auxiliary" lights. That center-mounted light would screw up the Elio's critical aerodynamics. A single headlight in the middle looks ... cheap. The way Solo did it with the dual lights looks much better. Maybe you could do something "high tech" like a wide LED light bar that could be shorter, and more aerodynamic, and give a cool high-tech look like you see on a lot of the higher priced vehicles now.

I would be surprised, and more than a little disappointed, to find that EM had not already considered the headlight issue. They are, after all, suppose dot be the experts at this. Having something like this slip by them would be surprising.

I honestly hate what Solo did with the add-on headlight. It looks cheap, just like those aftermarket "hood scoops" people put on their cars which do nothing. I do think that Elio needs to address this issue asap, as it has the possibility of causing design or legal issues down the road. If they are not able to amend the current law, and they are required to modify the Elio's design, I hope they go the route of Polaris did with the Slingshot.

The center mounted headlights ensured compliance with the laws, and it actually looks good and a part of the original design of the three wheeler. Solo just slapped a pair of lights on the hood, which look like an after thought and can affect the aerodynamics.

I would like Elio to keep its current design, but perhaps add the center headlights near the top of the front bumper, or integrate it into the very end of the hood to match the current lights. (would also love marker lights on the wheels too)

 

[slinches]

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

 

[MagicDragon]

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

Maybe Elio will take a hint from the 1948 Tucker. Their center headlight turned with the front wheel steering

 

[Elio Amazed]

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

The requirement is no more than 200mm (approximately 8") apart.

I would like Elio to keep its current design, but perhaps add the center headlights near the top of the front bumper, or integrate it into the very end of the hood to match the current lights. (would also love marker lights on the wheels too)

As long as the lights are also between the required minimum and maximum distances from the ground. That's another part of the requirements.

Minimum = 22 inches. Maximum = 54 inches.

It may very well be that Elio Motors has already reached an "unofficial" agreement with the authorities. Another three-wheeled vehicle manufacturer already got a pass on these requirements without (to my knowledge) even applying for either an exemption or a determination. But we may not have a straight answer to that either way until the first Elios are sold, registered and on the roads.

And possibly not even then.

And what's with people just naturally assuming that the entire market shares their taste in looks?