Report: Electric Vehicles Proven to be Safer Alternative to Horse Carriages
A safety report from Harley Holt & Associates concludes that:
- the horse carriages lack basic safety features
- occupants of horse carriages would be placed in an increased risk of injury and death in the event of an accident
- the NYCLASS "Horseless eCarriage" is a significantly safer alternative to horse carriages.
"Because horse drawn carriages do not meet basic motor vehicle safety standards, any crash involving a horse drawn carriage and a motor vehicle would result in the occupants of the horse carriage being placed at considerably greater risk for injury and death,” according to the report.
A complete copy of the safety report is included below.
Harley Holt & Associates
1704 Random Stone Court
Reston, VA 20190-3251
(703) 709-9798 FAX: (703) 709-9768 Email: [email protected]
June 6, 2014
SAFETY OF HORSELESS eCARRIAGE VEHICLES COMPARED TO HORSE-DRAWN CARRIAGES IN NYC
Open horse drawn carriages are operated in New York City as tourist conveyances for sightseeing on the roadways in the area around Central Park and Times Square. Additionally, the horse carriages must maneuver through midtown traffic on their way to and from the horse stables every day. The horse drawn carriages operate on these public roadways and congested streets with virtually none of the safety and environmental safeguards required on the vehicles surrounding them and thus present distinct risks of safety hazards to the carriage occupants, drivers, and horses.
An improved method of providing a safer and environmentally cleaner vehicle for transporting sightseers has been commissioned by New Yorkers for Clean, Livable and Safe Streets (NYCLASS). NYCLASS is a non-profit animal rights advocacy group that seeks to ban horse-drawn carriages from New York City streets and parks. The vehicle proposed for replacement of horse drawn carriages has been under development by Creative Coachworks, Inc. for several years. It is an all-electric powered vehicle that is styled after and reminiscent of an early 1900s automobile.
This report provides a comparison of the overall safety and safety features of the vehicle created by Creative Coachworks, Inc. in Dania Beach, Florida. The Horseless eCarriage, as it is being called, is being proposed as a replacement for the horse drawn carriages for use as tour vehicles in and around NYC Central Park as well as other areas in the US that are looking for a viable, nostalgic replacement for horse drawn carriages or for any fitting locale where this type of tourist vehicle would be appropriate.
The safety regulations in place for horse-drawn carriages in New York City are minimal at best. There are no requirements for seat belts or other passenger safety items that would protect occupants in the event of a crash. The opposite is true for Horseless eCarriages which would provide a significantly safer alternative.
Regulations Applicable to Horse Drawn Carriages
A review of the federal regulations applicable to manufacturers of horse drawn carriages reveals there are none. What regulations that do exist in NYC for horse drawn carriages are promulgated and enforced by NYC and other local or state regulators in the states and municipalities where they operate. Horse drawn carriages are not considered to be motor vehicles by statutory federal definition and so there are no federal regulations that apply to their manufacture or sale.
In NYC, the only horse drawn carriage regulations are those that apply to the driver/operators of the carriages. A review of the Training Manual for Horse Drawn Carriage Operator’s Course published by the NYC Department of Mental Health and Hygiene describes in brief terms the requirements and use of brakes for relieving the load on the horses during downhill operation and for parking. There is also a section stating that “Sufficient lighting and reflective materials shall be provided on all horse drawn cabs, including sufficient lighting on the rear axle of all cabs at the location where licenses are affixed.” There is no description of the terms, “significant lighting and reflective materials” offered.
The chassis and body structures of horse drawn carriages provide none of the basic crashworthiness features required for driver and occupant protection in all other passenger carrying vehicles.
There are no further statements or requirements for any safety items relating to occupant safety or protection from death or injury on the roadways. However, a speed of not greater than 5 mph is required inside Central Park.
Safety Features of the Horseless eCarriage
The Horseless eCarriage meets all existing US DOT requirements mandated by the National Highway Traffic Safety Administration (NHTSA), including seat belts, brake systems and other crash protections. These include the Federal Motor Vehicle Safety Standards (FMVSSs) applicable to the manufacture and sale of multipurpose passenger vehicles (MPVs) of greater than 10,000 lbs GVWR. The applicable FMVSSs include the following from Title 49 Part 571:
§571.101 Standard No. 101; Controls and displays.
§571.102 Standard No. 102; Transmission shift position sequence, starter interlock, and transmission braking effect.
§571.103 Standard No. 103; Windshield defrosting and defogging systems.
§571.104 Standard No. 104; Windshield wiping and washing systems.
§571.105 Standard No. 105; Hydraulic and electric brake systems.
§571.106 Standard No. 106; Brake hoses.
§571.108 Standard No. 108; Lamps, reflective devices, and associated equipment.
§571.111 Standard No. 111; Rearview mirrors.
§571.113 Standard No. 113; Hood latch system.
§571.116 Standard No. 116; Motor vehicle brake fluids.
§571.119 Standard No. 119; New pneumatic tires for motor vehicles with a GVWR of more than 4,536 kilograms (10,000 pounds) and motorcycles.
§571.120 Tire selection and rims and motor home/recreation vehicle trailer load carrying capacity information for motor vehicles with a GVWR of more than 4,536 kilograms (10,000 pounds).
§571.124 Standard No. 124; Accelerator control systems.
§571.205 Standard No. 205, Glazing materials.
§571.205(a) Glazing equipment manufactured before September 1, 2006 and glazing materials used in vehicles manufactured before November 1, 2006.
§571.207 Standard No. 207; Seating systems.
§571.208 Standard No. 208; Occupant crash protection.
§571.209 Standard No. 209; Seat belt assemblies
§571.210 Standard No. 210; Seat belt assembly anchorages.
§571.302 Standard No. 302; Flammability of interior materials.
Each Horseless eCarriage has a federally required certification label affixed showing a unique vehicle identification number (VIN) and specifying that the vehicle meets all of the applicable Safety Standards in effect at the time of manufacture. Creative Coachworks, the official manufacturer of the vehicle, is fully registered as such with the US DOT. In the event of a recall for a safety defect or noncompliance Creative Coachworks will repair or replace all defective parts. The company also provides a Manufacturer’s Certificate of Origin with each new vehicle to allow registration by the state motor vehicle divisions.
Additionally, although it is not required, The Horseless eCarriage meets nearly all of the requirements in NY State regulations for buses. The Horseless eCarriage is not classified as a bus because it is designed and intended to carry less than 10 passengers.
Due to a lack of safety regulations on horse-drawn carriages in New York City, the Horseless eCarriage – equipped with critical safety features – provides a safer alternative to the horse-drawn carriages that cause a traffic and safety hazard on New York City streets.
Because horse drawn carriages do not meet basic motor vehicle safety standards, any crash involving a horse drawn carriage and a motor vehicle would result in the occupants of the horse carriage being placed at considerably greater risk for injury and death.
In the absence of any comprehensive safety regulations applicable to horse drawn carriages there are very few features, if any, that compare with the safety features which are part of every Horseless eCarriage. The major safety features of all motor vehicles i.e. braking systems, lighting, occupant protection systems, vehicle controls and displays, and more on each Horseless eCarriage vehicle, are non existent on horse drawn carriages.
Harley E. Holt, President
Harley Holt & Associates, Inc.