A Petition for Rulemaking filed by Battalion Fire Chief Steven LaPenta of the Newark Department of Public Safety, Fire Division, was formally received by the U.S. Department of Transportation (DOT) and the National Highway Traffic Safety Administration (NHTSA) Office of Chief Counsel in Washington, D.C. on July 1. The petition calls for a standardized system requiring all new motor vehicles to communicate their propulsion type — internal combustion engine (ICE), hybrid/plug-in hybrid (HEV/PHEV), or battery electric (BEV) — through externally visible identification.
Chief LaPenta, who has spent more than three decades in fire service, filed the petition in his individual capacity. In it, he argues that existing manufacturer badging and trim-level markings are inconsistent across brands, often too small or subtle, and effectively unreadable in crash, fire, nighttime, or adverse-weather conditions. "Responders have to make life-or-death decisions within the first few seconds of approaching a vehicle," he states, "but in many cases they can't even tell whether that vehicle is electric."
The petition emphasizes that battery electric vehicles carry hazard profiles distinct from conventional vehicles — including stranded high-voltage energy, thermal runaway, delayed reignition, and toxic or flammable off-gassing. Without early recognition of propulsion type, it argues, every subsequent tactical decision — approach, extrication, suppression, isolation — can be delayed or misjudged, putting both responders and occupants at risk.
To support the petition, LaPenta cites NTSB findings that high-voltage batteries reignited a total of 15 times across three electric-vehicle crashes it investigated, along with a Washington State study on EV fires that found 62 percent of surveyed towing companies had no system for identifying whether a vehicle involved in an accident was electric. The petition also notes U.S. Department of Energy data showing more than 5.8 million electric vehicles now on U.S. roads and more than 1.4 million new EV sales in 2023 alone — evidence, it argues, that vehicle identification systems have not kept pace with the speed of electrification.
The petition is careful not to mandate any specific technology or design. It sets out performance-based criteria only — that identification be visible to the naked eye from outside the vehicle, recognizable in both daylight and darkness, placed in standardized locations, and durable enough to survive the early stages of a crash or fire. The final design, it states, should be determined through the formal rulemaking process. The requested scope is limited to newly manufactured vehicles, beginning with ICE, hybrid/PHEV, and BEV categories, with hydrogen fuel-cell vehicles (FCEV) and other technologies to be considered for inclusion at a later stage.
"Propulsion type is no longer just product information," the petition states. "It is safety information that directly affects emergency response and rescue operations" — underscoring the need for a nationally unified exterior identification standard.
The filing is notable as a case in which a serving fire-service commander has formally asked the U.S. federal rulemaking process to treat propulsion type itself as a new category of safety information, at a moment when EV fire and battery safety have become a global concern.
The petition is a public document filed with NHTSA and is available for anyone to review. Chief LaPenta has also agreed to the release of the full text and a link to the original document.


 

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