Specifically calling out EVs and hybrids is backwards-thinking. If this is about a required minimum sound level, then encode in the FMVSS under what conditions a road-legal vehicle must generate what sound characteristics and be done with it. I wouldn't be surprised if a number of combustion engine cars would also fail those conditions; my mother's old Camry was virtually silent at idle except for accessory belt noise.
Otherwise this smells like a knee-jerk reaction, and maybe a money grab.
NoiseOff provides a
good overview of the NFB's history of noise regulation lobbying. They also point to a 2008 NHTSA study titled "
Incidence of Pedestrian and Bicyclist Crashes by Hybrid Electric Passenger Vehicles (PDF)". It's a pretty decent study, if limited by sample size, and points to a need for quiet vehicles to emit some type of audible alert when performing certain maneuvers. One major flaw pointed out below.
This study found that pedestrian and bicyclist crashes involving both HEVs and ICE vehicles commonly occurred on roadways, in zones with low speed limits, during daytime and in clear weather, with higher incidence rates for HEVs when compared to ICE vehicles. A variety of crash factors were examined to determine the relative incidence rates of HEVs versus ICE vehicles in a range of crash scenarios. For one group of scenarios, those in which a vehicle is slowing or stopping, backing up, or entering or leaving a parking space, a statistically significant effect was found due to engine type. The HEV was two times more likely to be involved in a pedestrian crash in these situations than was an ICE vehicle. Vehicle maneuvers such as slowing or stopping, backing up, or entering or leaving a parking space, were grouped in one category based on that these maneuvers are potentially have occurred at very low speeds where the difference between the sound levels produced by the hybrid versus ICE vehicle is the greatest. In future analysis with a larger sample size, it would be ideal to investigate each of these maneuvers individually. Incidence rate of pedestrian crashes in scenarios when vehicles make a turn was significantly higher for HEVs when compared to ICE vehicles. There was no statistically significant difference in incidence rate of pedestrian crashes involving HEVs when compared to ICE vehicles when both type of vehicles were going straight.
The small sample size greatly restricted the usefulness of the survey and undermines their conclusions above. For example, there was 1 recorded incident of an HEV/pedestrian crash when entering/leaving a parking space, 3 when starting in traffic, and 7 when braking.
One big issue with the study is that the data does not support the conclusion that HEVs crash with pedestrians/bicycles more frequently than ICE. Instead, they're saying that of the recorded crashes, pedestrians/bicyclists are over-represented in HEV crashes vs ICE crashes. In other words, when HEV DO crash, they are more likely to do so with pedestrians/bicyclists than the equivalent occurence for ICE. If HEV crashed with other cars more frequently but the pedestrian crash rate was unchanged, then the NHTSA report would view this as a "better" scenario.