Changes so BugE can be registered in New York

In my phone conversations with my NY-DMV caseworker, the main problem with my vehicle appears to be the lighting and controls. So, I used an image editor to investigate how some different lighting layouts might work. The FMVSS guide I'm using is HERE . First, about the lighting. Because this vehicle is classified as a motorcycle, it needs to have DOT/SAE motorcycle lights with motorcycle markings in the housing. Finding aftermarket lights has been surprisingly hard since the market is flooded with cheap replacement lighting.

Anyway, my first thought on revised headlight placement was to have a single light shine out through the windshield so the light would not affect the aerodynamics. However, using a spotlight, I found that others would only see a glowing blob coming down the road. Since I didn't want to cut into the bubble to mount a light, I eliminated this option.

The second option I considered was to take the existing navigator headlights off, then put DOT blinkers in the holes and mount a couple of sealed-beam DOT legal motorcycle headlights on the fenders. Reading the regulations, I found that primary motorcycle lights cannot be more than 8" apart. At first, I was convinced there was some regulation that would exempt a tadpole trike since it would show other drivers that a very wide thing was coming towards them rather than a very skinny thing! However, I found no such exemption. I have since observed that some motor trike vehicles such as the Xebra that clearly would benefit from a wider lighting layout still retain a headlight in the center. Another three wheeled vehicle, the Aptera, does only have two lights on the side more than 8" apart. However, that vehicle is only available in California. So I suspect a special exception was made at the state level rather than the national level.

Another configuration I considered was to have the motorcycle light shine out the front door. The headlight, mounted through the removable door panel, would be at the lowest height permitted. One cost of this option is that I would lose use of the front cargo door.
The final configuration is to simply place a single sealed-beam DOT approved motorcycle light in the front. I would also like to keep the dual navigator lights on the side since they look nice but they don't need to be DOT grade since the state would consider these ornamental rather than functional.

So, I submitted in writing the 2nd and 3rd proposed lighting configurations to my caseworker that shows some proposed configurations and measurements (eg headlight would be so many inches from the ground) and also states electric interlock requirements (eg. motor can't be on without the headlight). Hopefully, my DMV caseworker can point out additional obvious problems. At minimum, I know I need to redo the whole 12V wiring harness for a center light but that was something I was going to do anyway.

For now, it's back to the garage for the BugE. As soon as I get my survey back, the work can start on changing out the lighting.

In a supreme bit of irony, I learned that Auburn High School completed a roadway legal BugE. Unfortunately, these roadway legal experts were in Auburn Alabama not Auburn NY!

Studying for the New York State DMV inspection...

New York State goes by the Title49 guidelines by the NHTSA. The good thing is that it's a federal standard. So, if I move to another state, I'll be OK. There is quite a bit to the code so I have delayed my inspection request until I can make sure the BugE complies with the code. I guess everyone needs a hobby. This for the moment is mine.

So far, the problems that may be an issue are:
-Still don't know for sure if NY will have a problem with the frame, body and wheels. I suspect they will find the BugE acceptable, but I don't know for sure. The case I'll be making is that 23 other states approved vehicles based on kit parts and so far, there have been no accidents due to structural failure. If NY rejects the vehicle on the basis of this, one has to ask, how many successful vehicles would it take? If I were rejected on this basis, I think I have a strong basis to appeal the decision although I have no idea how I would do so.

As for the NEV limitation, New York doesn't restrict electric trikes to 25MPH. Instead, it insists all motorcycles (electric or not) must be able to EXCEED 40MPH! Yay! got that one!

As for the other areas I CAN address according to Code49...

• The kit provided tires I have are acceptable provided I can demonstrate that the weight does not exceed the capacity of the tires.
  
• thumb throttle is fine. (twist grip throttle shipped with newer BugE kit works too)
• "self canceling turn signal" mechanism providing 4-way flasher capability is nice, but not required.
  
• Blue Sky kit turn lamps need to be replaced with slightly larger DOT legal versions
• Blue Sky kit tail lamp needs to be replaced with DOT/SAE legal version (I'm using one from a salvaged bike I bought on Ebay)
  
• Replacing side headlights is tricky with two headlights, one for high beam, one for low beam. In NY the headlights can't be more than 8" across or there needs to be a center light. The center lamp should have DOT/SAE markings and also say "motorcycle" on them with hi/lo in the same body.
  
• Mirrors - the Eurosport mirrors look good but they were mounted a little too low. I'll be replacing them with Izuzu truck mirrors which will give a larger mirror area.
  
• Glad I wired in the turn signal indicator lights to the speedometer! At the time, I thought this would just be a nice, but not necessary feature for me. Turns out having turn signal pilot lights and an illuminated speedometer are both needed!
• right-left brake layout is acceptable as is and is also safer than stopping using rear wheel. If rear wheel locks, the vehicle could go into a spin!

That's it for now.

Oh, and there is also a quiz. Which lamps are DOT approved? Yes, in both cases, bigger is better. However, it's not the size that makes the grade. What really makes the lights legal is the DOT / SAE code on the lens of each lamp. FINDING authentic DOT/SAE stamped parts at any price is a challenge. In my case, I gave up searching for a new tail light and just went with a 2nd hand part. This approach works, but the tail light I settled on is nearly 20 years old!

Trial of the BugE by NY DMV

So, I make a big sigh and embark on the obstacle filled path of the home built vehicle maker rather than the easier path available to those vehicle owners that have vehicles that already have a VIN. So, I write my letter to the DMV stating that I've built a vehicle based on the BugE kit and would like an information packet to start the process of getting a "home built" vehicle approved on New York State roadways.

I'm expecting a long wait for the packet, long wait for an inspection date and a laundry list of wants when it comes to blessing the BugE for New York roadways. I'm sure people at the DMV do not like approving home built vehicles. There are probably lots of engineering questions since this catch-all category includes everything from motorized furniture to parade floats. So, I'm expecting a form with all sorts of hurdles and mods I will need to make to claim the BugE is safe. Of course, in my favor, the BugE is considered a motorcycle in trike configuration so the national requirements should not be so strict as for a car but I have no idea what kooky New York State laws may lurk about. Perhaps it will need strobe lights or need to be painted florescent orange or carry several fire extinguishers. It may get plates, but then get lumped into the category of regular NEVs which are governed to not exceed 25MPH! Not that it's that big of a deal. The surrounding roadways are 35mph so even with a NEV restriction, the BugE should still be a useful vehicle for me.

However, instead of getting a thick compliance packet with a mile-long check list, I get a phone call from a representative stating that he doesn't think the BugE is fit for roadway use, ironically BECAUSE it's a kit! The reasoning probably is, if the kit maker didn't issue a VIN, it must have been denied by NHTSA or DOT at some point so it's crap. Denied unseen - even without an inspection!

But that is only the first skirmish in what looks to be a long war. Not to be a person who accepts a denial of a BugE even without some sort of inspection or at least a set of hurdles to overcome, I respond in writing and point out that the BugE has been accepted in 4 different states & I give references (since then, I have learned that BugE vehicles are being driven legally in 23 states so his case for a blanket denial of the BugE design is totally without merit) and of course I offer to make mods on whatever may be lacking for compliance with New York State laws.

So, I've enlisted the help of the kit designer Mark Murphy. I see by email correspondence that Mark and my caseworker have had a back and fourth Q&A. Things are looking good. Looks like the main problem technical services has is with the lighting, specifically with the headlight location and making sure all lighting meets DOT/SAE standards.

Meanwhile, I've accepted that I'll be carting the BugE around to several locations so I've installed a trailer hitch on my regular car so carting the BugE around can be done inexpensively.