All May 2009 comments for CARB's PHEV09 ruling
The following is a compilation of the public comments made to CARB in advance of its May 2009 ruling on proposed legislation to regulate conversions of vehicles to PHEVs (also referred to as "phev09"). For background, see Spotlight on Conversions: 70 MPH Prius and Hummer PHEVs; Gas Guzzlers; CA Air Board Regulations.
Comment 134 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: JamesLast Name: Rieley
Email Address: jbrieley@rieley.com
Affiliation:
Subject: Plug-In Hybrid Vehicles
Comment:
I hope that the Board does not take this opportunity for the larger community and over-regulate it by following the model that has been used for traditional internal combustion vehicle standards. Hybrid electric vehicles can help the state to solve several of the complex and inter-related challenges that it faces...Let's try to ensure that the Board does all that it can to ensure that we, the auto purchasing and driving public, have an opportunity to use hybrid electric vehicles to help the state solve those challenges.
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-12 19:41:34
Comment 135 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: DavidLast Name: Hill
Email Address: david.hill@inergyautomotive.com
Affiliation: Automotive Fuel Systems
Subject: Contradiction in Terms
Comment:
Section II 1.12.6 and 5.4 seem to contradict each other. One requires a maximum state of charge prior to the 2/3 day diurnal while the second clause requires a minimum state of charge so that the vehicle can maximize its amount of purge. Can someone explain this contradiction?
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-20 16:02:48
Comment 136 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: DanielLast Name: Sherwood
Email Address: daniel@3prongpower.com
Affiliation: 3Prong Power Inc.
Subject: 3Prong Power Inc. Comments on Plug-In Hybrid Test Proceedres
Comment:
Dear California Air Resources Board,
I would like to respectfully submit the following comments on
behalf of our startup company, 3Prong Power, our employees, our
customers and the customers we plan to serve in the years ahead.
Our company enables owners of the popular Toyota Prius hybrid to
reduce their air and climate impact and increase their fuel economy
through the installation of an after-market plug-in electric
upgrade.
We appreciate the thoughtfulness that CARB has put into drafting
the proposed regulations and test procedures to address the newly
available class of off board charging hybrid vehicles. We know
your agency is aware of the enormous potential for this emerging
class of vehicle, commonly known as Plug-In Hybrid Electric
Vehicles (PHEVs), to improve California's air quality and to
address global warming.
Since the last time these regulations were considered at a CARB
board meeting in January, we have met on several occasions with
CARB staff to discuss our concerns. We appreciate the CARB staff's
willingness to meet with us and their movement toward a tiered
structure for compliance with these proposed regulations.
At 3Prong Power we believe that PHEV conversions are a crucial
first step in catalyzing a "virtuous cycle" or positive feedback
loop in the marketplace, one that steadily raises electric
driving's share of the transportation market, in foreseeable steps.
The virtuous cycle we envision looks something like this:
* We start by converting existing vehicles to PHEV;
* These PHEV conversions lead to more recharging
infrastructure;
* More infrastructure and market development lead to even more
demand for plug-in vehicles;
* The plug-in vehicle market grows to the point where large
businesses and automotive OEM's jump in;
* This leads to high volumes, lower costs and improved
performance, encouraging more electric driving;
* Growing demand spurs installation of second generation
charging technology such as fast charging, battery swap, and
vehicle-to-grid technology.
Ultimately, as batteries and infrastructure improve, it becomes
possible to dispense with the gas engine entirely and transition to
all electric transportation. That end result represents a dramatic
paradigm shift.
Along the way, PHEV conversions help to:
* Clean the air;
* Slow global warming;
* Break our addiction to oil;
* Foster innovation;
* Create good, green jobs here in California.
Because it offers all these valuable benefits along the way to
ultimately transformative change, our PHEV conversion technology
merits a lighter regulatory touch than alternative technologies
whose end results are merely incremental reductions in carbon and
other criteria pollutants, technologies such as agricultural
biofuels or "alternative" fossil fuels.
In fact, though, regulation of PHEV conversions should go further,
and create incentives that grow this segment of the transportation
market, rather than chill it or even stop it altogether.
In this spirit, we welcome the conceptual shift proposed by the
CARB staff toward a tiered approach to certification in our
industry. A tiered approach should allow small, innovative
California businesses to operate, grow, and gain important market
and technological feedback at a low and manageable cost of
compliance, while ramping at a reasonable rate toward full
compliance with necessary regulations at an appropriate stage.
An appropriately tiered ramp-up in regulatory requirements is
crucial to the survival of these companies, which are presently
very young and highly vulnerable to significant cost burdens.
Costs such as those imposed by the laboratory testing requirements
in Tier 2 would cripple us, and other California PHEV conversion
companies, if imposed too early.
Unfortunately, we feel that these concerns are not reflected in
the CARB staff's current proposal.
We respectfully request the following modifications to the
proposed regulations:
1. Tier 1 Ceiling. First and most imporant, we urge CARB to
raise the Tier 1 ceiling to 100 vehicles (up from 10 as currently
proposed).
Setting the first tier ceiling at only 10 vehicles, while placing
the most expensive part of compliance in the second tier, defeats
the intended purpose of the tiered approach. All the businesses in
California currently offering PHEV conversions have already
exceeded the proposed 10 vehicle first tier limit.The one notable
exception to this pattern is an out-of-state company which has been
able to pay for laboratory testing with financial resources
unavailable to the California companies Setting the first tier
ceiling so low would be highly disruptive to the nascent California
PHEV industry.
Instead, the number of vehicles sold under Tier I should be
sufficient to allow room for product refinement, feedback from
consumers, business development, and revenue generation, before
companies like ours face the most expensive area of compliance:
laboratory testing. If we assume $200,000 as a reasonable estimate
of the cost of testing, spreading this cost over just 10 vehicles
effectively adds $20,000 to the cost of each one. It's easy to see
that this figure is prohibitive from the consumer's perspective --
roughly equaling the base cost of a new Prius, and more than
tripling the cost of conversion alone.
We suggest that a Tier 1 ceiling of 100 vehicles is more
appropriate. A Tier 1 ceiling of 100 will vehicles allow PHEV
businesses still in their infancy to continue operating in the
first Tier, while integrating customer feedback, refining their
products, developing their businesses, and generating revenue.
Spreading the testing cost over 100 sales effectively adds just
$2,000 to the cost of each vehicle, which is manageable.
2. Evaporative Emissions. We request that the test procedure be
modified so that only a charge sustaining drive cycle is required
before evaporative emissions testing.
The current test procedure calls for a short drive cycle in charge
depletion mode before testing for successful canister purge.
Depending on the PHEV architecture, it may be possible to complete
this short drive cycle using only the electric motor. Using solely
the gasoline engine will result in no purging of the canister and
cause the vehicle to fail the test procedure.
We believe this is flawed reasoning for two reasons. Firstly,
real world experience has shown that most of our customers have
longer drive cycles than required by the test procedure, so that
the engine does, in fact, run in charge sustaining mode most days.
This enables a proper purge of the canister. Secondly, those
customers that are able to keep their driving to a minimum and
maintain the vehicle in charge depletion mode, will quickly realize
that their needs can be as easily met by an EV as a PHEV and
therefore will likely become early adopters of that technology.
Even if that transition does not materialize, this situation is not
worse than the situation where someone decides to ride their
bicycle or take public transportation most days and leave their car
at home.
Requiring a PHEV to operate only in charge depletion mode before
testing for canister purge is analogous to requiring standard
hybrids to be parked while the driver rides a bicycle around before
testing for canister purge. Both situations, commuting by bicycle
and driving a PHEV in electric mode only, will increase evaporative
emissions, however we believe that both situations deserve to be
encouraged not prohibited due to technicalities of a test
procedure. Therefore we request that the test procedure be modified
so only a charge sustaining drive cycle is required before testing
for evaporative emissions.
3. Warrany Issues. The warranty requirement should explicitly
exclude a performance warranty on the battery.
The staff recommendations continue to focus on the length of the
warranty, and seek to hold PHEV supplemental batteries up to the
high standard set by the HEV industry. We do not disagree with the
warranty length as recommended. However, we believe that what
exactly is covered by the warranty should be more clearly spelled
out. Specifically, for current HEVs, the hybrid battery warranty
does not warranty against degradation of the battery capacity over
time. It warranties that the vehicle will run and that it will
meet emission requirements. We believe that the supplemental
battery should be held to that standard, i.e. to warranty that
emissions will not be impacted and that the vehicle will continue
to run. Performance degradation of the battery over time should
not be interpreted as a reason to replace the entire battery under
warranty. The exact nature of the warranty requirements are not
explicit in the staff proposal. We request that an explicit
exclusion of performance warranty on the battery be included.
Thank you for the opportunity to provide this input on how to
create a set of regulations for PHEVs and ZEVs that will best
provide Californians with increasingly clean alternatives for
personal transportation.
We hope very much that you will choose to adopting the changes
requested here. We believe these are the best ways CARB can
support the California consumers who want to drive Plug-In Hybrids,
the young California companies that provide the technology, our
employees, and clean air and a healthy climate for everyone. With
your help, we'll do all we can to advance California's transition
to electric driving as smoothly and quickly as possible.
Respectfully submitted,
Daniel Sherwood
President, 3Prong Power
Daniel@3prongpower.comAttachment:
Original File Name:
Date and Time Comment Was Submitted: 2009-05-21 10:36:26
Comment 137 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: KietLast Name: Chau
Email Address: kchau@vivid-hosting.net
Affiliation:
Subject: Plug-in hybrid regulations
Comment:
Dear California Air Resources Board, please support the California Plug In Hybrid conversion industry by raising the Tier 1 ceiling to 100 vehicles up from the currently proposed 10.
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-21 14:34:33
Comment 138 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: MichaelLast Name: Bender
Email Address: membender@hotmail.com
Affiliation:
Subject: Tier 1 caps for small PHEV Conversion companies
Comment:
Dear CARB, I work in the PHEV-advocacy "business," and know that your proposed cap of a mere TEN vehicles for Tier 1 in your latest proposal is too low for nascent conversion companies and will put most if not all out of business. And during these economic times, especially here in California, these small and innovative companies are exactly the WRONG kind that we want to see disappear. Some could be the Hewlett-Packards of the future (especially since most of them got started, appropriately, in GARAGES), but *not if they are put out of business before they can gain a foothold*. So please, raise the cap on Tier 1 to 100 or 200, so that these companies can afford to stay in business and grow to become well-established, job-producing and GREEN companies. Thank you.
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Date and Time Comment Was Submitted: 2009-05-21 15:13:12
Comment 139 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: GerryLast Name: Gaydos
Email Address: gerry.gaydos@hotmail.com
Affiliation: EAA member
Subject: testing requirements for PHEV conversions
Comment:
Please consider raising the number of PHEV conversions that would trigger the requirement for emissions testing, from 10 vehicles to 100 units. Start-up PHEV ventures will be unduly burdened with the cost of these tests at the proposed limit of 10 conversions, to such an extent that it would become impractical (unprofitable) to lunch a business to perform Plug-In conversions. At 100 vehicles, the burden of testing costs on each car could be at least manageable, ($2000) even if not ideal, allowing us to collectively proceed with the important work of improving the fuel economy of tens of thousands of existing hybrid vehicles on the roads in North America. A business that fails due to excessive external costs, can't help the cause. Thank you for your continued efforts on behalf of all who care about the air. regards, Gerry Gaydos founder, CEO FunkymotoªElectric Vehicles Inc.
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Date and Time Comment Was Submitted: 2009-05-21 16:15:15
Comment 140 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: Wesley WLast Name: Schilling
Email Address: flwrman@sbcglobal.net
Affiliation:
Subject: Save Plug-In Hybrid EV's
Comment:
Please do not limit or do away with the Plug-In Hybrids in CA. I believe this is a retro fit that is a great alternative for those of us that do most of our driving in town and not on the highway. Thank you for listening to me. Wesley W Schilling Fremont, CA 94536
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-21 16:18:03
Comment 141 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: barryLast Name: nicholls
Email Address: bnhappy5@aol.com
Affiliation:
Subject: phev's
Comment:
I WANT THIS FLEDGLING INDUSTRY TO BE A SUCCESS AND HELP IN THE
FIGHT AGAINST GLOBAL WARNING. GIVING THESE COMPANYS THE 100 CAR
LIMIT HELPS THEM GET ESTABLISHED AND REFINE THEIR FINAL TECHNIC
BEFORE THEY FACE A LARGE HURDLE OF TESTING AND CERTIFICATION. I
HOPE TO OWN A PHEV AND WOULD LIKE AND DESERVE THE WIDEST POSSIBLE
RANGE OF VEHICALS TO CHOOSE FROM.
THANK YOU BARRYAttachment:
Original File Name:
Date and Time Comment Was Submitted: 2009-05-21 17:24:30
Comment 142 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: ZakiyaLast Name: Harris
Email Address: zakiya9@gmail.com
Affiliation:
Subject: Plug In Hybrids
Comment:
Save the hybrids, reduce our dependency on foreign oil and help reduce our carbon footprint!
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-21 22:00:34
Comment 143 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: JamieLast Name: Knapp
Email Address: jamie@jknappcommunications.com
Affiliation:
Subject: Environmental NGO Comments on PHEV Conversion Proposal
Comment:
Comments of Union of Concerned Scientists, American Lung Association in California, Coalition for Clean Air, and Center for Energy Efficiency and Renewable Technologies.
Attachment: www.arb.ca.gov/lists/phev09/218-09-05-4-phev-env-comments.pdf
Original File Name: 09-05-4-PHEV-env-comments.pdf
Date and Time Comment Was Submitted: 2009-05-21 22:02:48
Comment 144 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: WilliamLast Name: Henry
Email Address: bhenry@nvidia.com
Affiliation:
Subject: Raise conversion limit from 10 to 1000
Comment:
Companies that convert hybrids to plug-in hybrids are indeed focused on doing the right thing for the planet and our economy. TO make a dent in the electric vehicle market we need many more start-ups to convert vehicles. People recently displaced from the auto industry can get into the car conversion game to rapidly expand the expertise and production base of plug-in hybrids. The current 10 unit limit will stop every entreprenuer in his tracks since you cant build a business with only 10 individual customers. Let these businesses support many customers before imposing such an onerous burden The limit is quite ridiculous in the first place. Plug in hybrids will use less fossil fuels. In my case, driving my electric car is totally carbon neutral since I have solar panels to fuel the car. We need more affordable electric vehicles on the road. Converting a Prius to plug in covered my daily commute.
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Date and Time Comment Was Submitted: 2009-05-21 22:43:56
Comment 145 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: lisaLast Name: nordman
Email Address: lisanordman@telus.net
Affiliation:
Subject: battery power for the future
Comment:
This is a positive and critical step towards the green future of our planet. Whether we are stewards, grandparents or parents by what initiatives do we want our legacies to remember us? Let us make all viable greenways available to as many as we can today.
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-21 23:13:27
Comment 146 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: JamesLast Name: Rieley
Email Address: jbrieley@rieley.com
Affiliation:
Subject: Plug-In Hybrid Vehicles
Comment:
Dear Air Resources Board... As someone who first owned an electric car in the 1970's (one that wasn't all that practical), I have been watching with keen interest all the work done by 3-Prong to offer a sound, rational alternative to our current automotive options. In a time in which we are being hammered with economic problems, clear environmental challenges, and the need to find more sustainable choices; the hybrid options that 3-Prong offers are welcomed...and I trust that you will do whatever possible to give them and the other hybrid suppliers the opportunity for consumers to make better transportation choices.
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-22 00:45:49
Comment 147 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: SteveLast Name: Woodruff
Email Address: steve@autobeyours.com
Affiliation: AutoBeYours.com
Subject: my personal message about plug in hybrids
Comment:
Please make it easier for smaller companies to make and sell plug in hybrid conversions.
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Date and Time Comment Was Submitted: 2009-05-22 04:41:11
Comment 148 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: IngramLast Name: Schwahn
Email Address: ips330@att.net
Affiliation:
Subject: Pros and Cons of plug-in Hybrids
Comment:
Do Plug-in Hybrids cost less than self-charging Hybrids ? The advantage of self-charging Hybids is obvious: no wasted time to plug in to electrical outlets after finding out where they are if needed on a trip. Thanks for doing this research. Ingram Schwahn
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Date and Time Comment Was Submitted: 2009-05-22 08:11:12
Comment 149 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: novellaLast Name: carpenter
Email Address: novellacarpenter@yahoo.com
Affiliation: biofuel oasis
Subject: Plug in hybrids
Comment:
Hello CARB: Please, let's make the right choice and allow the production of plug-in hybrids. This kind of innovation will only lead to better electric cars and thus will decrease the amount of CO2 in the air. Sincerely, Novella Carpenter
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-22 13:39:54
Comment 150 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: EdwardLast Name: Rollins
Email Address: edwardrollins@hotmail.com
Affiliation: small business owner
Subject: 3 Prong Power
Comment:
Hi,I am writing to encourage the California EPA's Air Resources Board to do everything they can toencourage the use of battery powered vehicles in the state of California. The rest of the country has come to depend on the state of California to lead the way for the rest of the country when it comes to clean emissions and environmental action! Thank you, Edward L. Rollins
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-22 15:52:49
Comment 151 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: melanieLast Name: barna
Email Address: melbarna@comcast.net
Affiliation:
Subject: support 3 prong power
Comment:
To Whom It May Concern, Please support clean car energy research. Please support the efforts of 3 Prong Power, allowing them to continue their work in creating a more carbon emission free system with plug in hybrid vehicles.
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-22 16:08:42
Comment 152 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: JeanLast Name: Woo
Email Address: jean.woo@gmail.com
Affiliation:
Subject: Plug-In Hybrids
Comment:
1442A Walnut St #368 Berkeley, CA 94709 5-22-09 Dear folks at CARB: I have followed your work for many years, and am overall very proud of the work that you are doing. I have a 2004 Prius with over 100,000 miles on it, and last year put a solar array on my house specifically because I plan to convert my Prius to a plug-in car and run it primarily on solar power. I use very little electric power personally, and oversized the array just for this purpose. I believe that we (the general public) and the owners of cars taht can be run on electric power via a plug-in device are much better served by increasing the Tier One limit from 10 to 100, even 1000. The ability to run our economy, even if only a small percentage of the transportation sector, using solar panels and clean non-polluting non-CO2 producing energy, will be a necessary and critical part of our new low carbon economy. As the viability of plug-in hybrids increases in the market, and in particular vis-a-vis the traditional American SUV, truck and auto, we the people of the world will all benefit. We in the US need this time and opportunity to create a manufacturing/retrofit industry and pathway, open to a large cross-section of society. Please raise the cap for the Tier One segment to at least 100, and better, 1000. We have precious little time to get off of oil and fossil fuels, and into the new low-carbon economy. As potential consumer interested in converting my Prius, I would like to add--do not burden us with additional costs for this testing. Please please use some of the stimulus funding for the state to support the testing effort and promote the plug-in hybrid --the sooner that the issues are resolved, the faster state and local governments can purchase low-carbon plug-in fleets, and replace older dirty cars and trucks, and the sooner that shops that are engaged in retrofits will be able to standardize their processes and bring down costs. Better than just covering the cost of the testing, include incentives to cover the cost of retrofitting an existing hybrid to a plug-in car. Additional funds released for (1) solar parking lots equipped with fast-charging stations (2) Battery swap-out systems in places that they will be convenient and cost-effective for customers and (3) a "smart card" system similar to the zip car or other "credit-type" cards in which the power used from the plug-ins to support the grid can be saved onto a card, from which one can draw to either decrease the homeowner's electricity bill, or to purchase and support organic and green services and products (paints, energy audits, solar systems, small wind and hydro systems, microfinance systems, groceries, clothing, toys and so forth, even makeup (!)) and to support non-profits doing good in other parts of the world, will make owning and charging a plug-in car bring value to the most sectors of the economy in the most seamless way. In this way, the plug-in electric car can be part of a system to create jobs and kick-start our economy - all without using or importing oil and gas, or using food crops to create transportation fuel. Thank you for your time and attention to this matter, Jean Woo MD MPH
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Date and Time Comment Was Submitted: 2009-05-22 17:04:17
Comment 153 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: PatrickLast Name: Rentsch
Email Address: patrick@coastside.com
Affiliation:
Subject: PlugIn Hybrid conversions
Comment:
To the California Air Resources Board, The entire world recognizes the need for all electric and plug-hybrid vehicles. Yes, we also need to ensure that these vehicles do not have adverse impacts. The proposed limit of Tier 1 conversions of 10 cars is way too low. This will place a huge burden on early adopters, and be overly restrictive on a developing technology. We need options, we need to fine-tune the possibilities. It is unrealistic to think this can be achieved with just 10 units. Make it 1,000, or at least 100. Even one "legacy" (i.e., more than 30 years old) automobile will pollute more than all of the proposed plug-hybrids. In fact, the plug-hybrids will pollute less than even some of the cleanest cars (e.g., the Prius). Please, help this country lead again. Thank you, Patrick Rentsch 650.738.0876
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-22 17:08:52
Comment 154 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: TimLast Name: Rentsch
Email Address: txr@alumni.caltech.edu
Affiliation:
Subject: Proposed Rulemaking for Plug-In Hybrid Electric Vehicle etc
Comment:
The proposed numbers for each tier all seem marked too low. The tier 1 number should be more like 100; the tier 2 number should be more like 500; the total number should be more like 25,000 or maybe 50,000. These are necessary for economic health of small companies and also to prevent domination by a few large concerns. Diversity is what will make the effort succeed. The proposed rule making should be revised with these concerns, including the economic viability of small companies kept in mind. thank you, Tim Rentsch
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-22 17:22:54
Comment 155 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: nicholasLast Name: cederlind
Email Address: nickelonious_c@yahoo.com
Affiliation:
Subject: Hybrids are the way to go!
Comment:
Hi,
Plug-in Hybrids are ALL my friends talk about - 3 already
have them and 3 more are getting them. Even regular hybrid owners
are saying to me they feel left behind! I'm getting one next year
and I feel we need to support this new wave of the future!
- Nick CederlindAttachment:
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Date and Time Comment Was Submitted: 2009-05-23 13:15:55
Comment 156 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: DavidLast Name: Lincer
Email Address: dalincer@comcast.net
Affiliation:
Subject: Size of a Company
Comment:
As I understand the proposed rule, the CARB intends to require a $200,000 test once a company has modified 10 vehicles. The costs of such testing spread over 10 vehicles make a "small" company not viable. At $20,000 / car for #1-#10 your rule will prevent the innovation that a small company can bring. Large companies that intend and have the resources to build thousands of vehicles can amortize the cost of such testing over the design cycle and initial manufacturing. I request consideration that 100 vehicles possibly emitting more air pollution while definitively reducing their gasoline usage is worth our efforts to support. Note that POSSIBLY emitting more air pollution, not guaranteed to do so. I agree that the testing needs to be done once the design of the modifications has stabilized. I support the requirement for testing at 100 vehicles, not the ten that the proposed rule would require. David Lincer
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Date and Time Comment Was Submitted: 2009-05-23 18:32:25
Comment 157 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: RoseLast Name: Vasquez
Email Address: novaacademy@hotmail.com
Affiliation:
Subject: Electric Cars
Comment:
If America is to live up to the great potential our founding fathers fought for, it is time for a new revolution. Electric cars by any and all means possible! We, the people, will no longer sit idling by in our combustion engine vehicles waiting for government and/or corporations to take the lead. So lead, follow or get out of the way. The wheels of the future are already in motion.
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-24 08:55:08
Comment 158 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: RussellLast Name: Brown
Email Address: rbrown@adobe.com
Affiliation: Human
Subject: Plug in hybrids
Comment:
California Environmental Protection Agency, Just as your name implies, we all need to protect the environment in which we live. Making it more difficult for consumers to help you with this cause is not logical. Your current plans for adjusting the regulations for hybrid conversions is not going to help the situation, but instead make things more difficult. Please, Please, Please, support the California Plug In Hybrid conversion industry by raising the Tier 1 ceiling to 100 vehicles up from the currently proposed 10. You can save the planet or kill it. You decide. Sincerely, Russell Brown
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Date and Time Comment Was Submitted: 2009-05-25 10:44:50
Comment 159 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: MarvinLast Name: Schafer
Email Address: Schaferdds@yahoo.com
Affiliation:
Subject: California citizens require your vote this week
Comment:
To the members of the California Air Resources Board: In years past the Board has helped to make California a leader in the world, and at other times it has buckled under the pressure and legal threats of the automotive industry. The industry opposed seat belts, air bags, and increased fuel economy standards. Their interests are at odds with the needs of the citizens of California. I urge each of you to vote to allow free enterprise to flourish in California by allowing entrepreneurs to build at least 100 Plug-In hybrid cars before being subject to the Tier 2 testing requirements. Adding batteries to capture the momentum in a car so less of the kinetic energy is wasted in heating the brakes can only reduce emissions. Please vote for small business and raise the Tier 1 ceiling to 100 vehicles up from the currently proposed 10 cars. Make a vote for Californians, the environment, and small businesses, and not for the auto industry. M P Schafer Former Development Engineer Hewlett-Packard Company
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-25 23:49:40
Comment 160 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: MarstonLast Name: Schultz
Email Address: mschultz@cleanpower.coop
Affiliation: Clean Power Cooperative of Nevada County
Subject: Rules for Plug-in hybrid electric vehicles
Comment:
I bought a Toyota Prius with the intention to conver it to a plug-in. Now I see the plug-in conversion market is about to take off but is threatened with excessive restrictions before the industry can even get off the ground. Why do you require a 10 year warranty on plug-in. Are catlytic converters on non hybrids warrantied for ten years? I understand that you are concerned about the catalytic converter will not stay warm and will release more undesirable emissions. The whole purpose of a hybrid is to be able to drive in electric mode locally and to return home withiut ever using the internal combustion engine, hence no use of the caolytic converter unless going on long trips. Please let the Plug-in conversion industry move ahead without excessive regulatuion. Raise the Tier 1 ceiling to at least 100 vehicles
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-25 23:59:08
Comment 161 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: GaryLast Name: Gerber
Email Address: gary@sunlightandpower.com
Affiliation: President, Sun Light & Power
Subject: Zero Emission Vehicles
Comment:
As an electic car driver for the past eight years, I know from a customer's point of view what a struggle it can be to adopt and use EV's. There is virtually no support structure for EV's, and most of the progress that has been made in this technology seems to have come from small, independent, dedicated but undercapitalized start-ups, supported by a small, independent and dedicated group of EV owners. I understand that CARB rules are being considered which may force some of the pioneers of plug-in hybrid technology out of the market and consequently out of business. PLEASE consider raising the Tier 1 ceiling for emission testing to at least 100 vehicles, to make it possible for small businesses to continue the work that they started years ago. Not only is this a good policy decision, but is the moral and ethical thing to do. Many of these good people have put their life savings on the line to promote a public good, and have done so without any government support. Now that the government is getting involved, it would be a sad day if one of the first things CARB does is to take actions which put these people out of business and hand over the reins of Plug In Hybrid technology exclusively to big businesses. Pioneers and leaders deserve to be supported and rewarded, not destroyed. We have already seen what happened to the EV mandate nearly a decade ago. Lack of support for small businesses will ultimately erode the innovative spirit that feeds innovation. Thank you.
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-26 09:30:43
Comment 162 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: GonzoLast Name: Rock
Email Address: grocks@gmail.com
Affiliation:
Subject: DO NOT LOCK OUT THE INNOVATORS!
Comment:
Creating Tiers, and then capping Tier 1 at 10 vehicles, though seemingly an improvement, is not any better than the first proposal. You must allow for small firms to get a footing before saddling them with expensive emission testing. To do otherwise creates an unfair advantage and eliminates the innovation that only comes from small firms scrapping to provide a solution to our planets problems. DO NOT LOCK OUT THE INNOVATORS!
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Date and Time Comment Was Submitted: 2009-05-26 10:49:47
Comment 163 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: FredLast Name: Neff
Email Address: OrdDepot@hotmail.com
Affiliation: Cal-Cars
Subject: Please don't over regulate the PHEV pioneers
Comment:
Without them we wouldn't even be having these public discussions, and there wouldn't be any hybrids let alone the plug in type. It is just silly to let the special interest, big auto makers influence you into regulating the small shops out of existence. There is just no way these small upstarts could be a threat to California's air quality, and in fact would be quite the opposite! Please don't be a chump for big oil and the big three auto industries, they aren't big enough to retrofit all the vehicles that are already on the road. If we are to get a handle on this global warming threat, we need the small shops to take up the challenge to modify vehicles already on the road to accellerate the changes our country need to the fleet of personally owned vehicles. I may not be from California, but all of us in the states are looking for your leadership in this area; as everyone knows that where California goes, so does the nation! Sincerely, Fred Neff
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-26 10:53:41
Comment 164 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: PeterLast Name: Peteet
Email Address: petes_garage@earthlink.net
Affiliation:
Subject: Plug in testing
Comment:
Please do not require extensive emission testing of plug-ins at the level of only 10 units;100 units is a more reasonable and realistic level.Thanks-Peter
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-26 13:21:27
Comment 165 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: MichaelLast Name: Chiacos
Email Address: mchiacos@cecmail.org
Affiliation: Community Environmental Council
Subject: Please raise the Tier 1 ceiling for small PHEV conversion companies
Comment:
Dear CARB Directors, The Community Environmental Council (CEC) is a 39 year old organization based in Santa Barbara, CA. We work exclusively on sustainable transportation, energy efficiency, and renewable energy issues. My organization is working on a pilot grant to test products that convert existing gasoline or diesel vehicles to PHEVs. Numerous companies have established proof of concept for this technology, but no fleet testing has been done yet. While we propose to test the technology on a small number of vehicles, the testing and waiver requirements are large. The current requirements impose significant financial hardships that will stifle innovation among small companies. Please consider raising the Tier 1 ceiling to 100-1000 vehicles. This will enable smaller companies to test their products at a reasonable scale and establish an income stream before investing in expensive emission testing. Raising the Tier 1 cap from 10 vehicles will not harm air quality as the current Tier 1 regulations require a company to show detailed engineering analysis that its modifications will only reduce air pollution. Burdensome regulations have caused many innovative companies to not be able to bring their technology to the market. Please help the nascent PHEV retrofit community survive and thrive. Sincerely, Michael Chiacos Transportation Specialist Community Environmental Council
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-26 14:39:17
Comment 166 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: StevenLast Name: Douglas
Email Address: sdouglas@autoalliance.org
Affiliation:
Subject: Alliance of Automobile Manufacturers Comments on PHEV09
Comment:
Attached is the Alliance of Automobile Manufacturers comments on the PHEV test procedure.
Attachment: www.arb.ca.gov/lists/phev09/294-alliance_comments_on_phev_hearing_5-26-2009.doc
Original File Name: Alliance Comments on PHEV Hearing 5-26-2009.doc
Date and Time Comment Was Submitted: 2009-05-26 14:59:18
Comment 167 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: JeanLast Name: Woo
Email Address: jean.woo@gmail.com
Affiliation: Presidio School of Management
Subject: Plug in Conversion for Prius
Comment:
I have been following this thread for a while. I think that if the engineering fix is to have the engine start at the beginning and heat up the catalytic converter, then run the car in EV mode--this can be done without requiring several cars to undergo extensive testing --just mandate it for the conversions and the plug-ins will be less polluting but still viable. Adding a huge price-tag seems like over-kill. CARB can sub-contract with one provider, test the ----- out of the car in ev and other modes, and come up with an engineering fix that should satisfy both the need to reduce overall emissions, and the need to not spend an extraordinary amount of money to do it. Certainly some of the Stimulus money must be oriented to the transportation sector--this would be a small issue for that large pot of money. But a big win for the environment if we can run our electric cars (largely) without the fossil fuel that we are running them on now. As I said before, I put a solar array on my roof just so I could run my car on sun power. I think everyone (and every corporation that can get a parking lot involved with on-site solar and chargers) should do the same. We can definitely dial down our GHG's this way. Thanks for listening. Jean
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-26 16:03:01
Comment 168 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: ElmerLast Name: Baum
Email Address: bshelter6@msn.com
Affiliation:
Subject: PluginsRaise the limit
Comment:
Raise the the limit to 100.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2009-05-26 20:08:17
Comment 169 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: FrankLast Name: Kuchinski
Email Address: fkuchinski@poulsenhybrid.com
Affiliation: Poulsen Hybrid, LLC
Subject: Comments from Poulsen Hybrid, LLC
Comment:
Attached are comments from Poulsen Hybrid, LLC on the proposed PHEV test procedures.
Attachment: www.arb.ca.gov/lists/phev09/299-poulsen_hybrid_comments_052709.pdf
Original File Name: Poulsen Hybrid Comments_052709.pdf
Date and Time Comment Was Submitted: 2009-05-27 06:27:48
Comment 170 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: PeterLast Name: Sinz
Email Address: pwsinz@onelinkpr.net
Affiliation:
Subject: Aftermarket Plug In Hybrid Conversions
Comment:
It is unbelievable to se bickering on allowing 10, 100 or even 10,000 conversions being questioned. If I have the money and interest to increase my vehicle(s) mileage and use less fuel to get around, that's my business and freedom to do. Who am I hurting by doing this ? The Arabs/Venezuelans ? too bad. We are actively converting in Puerto Rico, with cheering enthusiasm by the public and auto owners. Think of what a (only) 40 mile range recharge can do for the citizens of the small islands (Lesser Antilles, Bermuda, etc)who cannot drive too far because the small size of the island who could recharge their batteries with photovoltaic or wind. ZERO pollution, ZERO gas. Incindentally, the gas used in these islands has to be imported as a finished prouduct at $3.00 to $4.00 MORE than stateside cost. $7.00 a gallon is not unheard of. Do you know jow many units will have to be converted to make a dent in the millions of autos sold YEARLY in the US. Let the grassroots builders do their thing. You never know whar really great discoveries can be made, but only if you are active in the field. Shame on you for trying to "regulate" new field. Peter W. Sinz San Juan Puerto Rico
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-27 09:31:21
Comment 171 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: BenLast Name: Jones
Email Address: ben@pluginsupply.com
Affiliation: Plug-In Supply, Inc.
Subject: Comments from Plug-In Supply Inc on Proposed PHEV09 Regulations
Comment:
Attached are comments from Plug-In Supply, Inc. on the proposed PHEV09 regulations.
Attachment: www.arb.ca.gov/lists/phev09/302-carbphev-comments-pluginsupply.pdf
Original File Name: carbphev-comments-pluginsupply.pdf
Date and Time Comment Was Submitted: 2009-05-27 09:39:35
Comment 172 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: RobbLast Name: Protheroe
Email Address: robb@pluginsupply.com
Affiliation:
Subject: PHEV09
Comment:
Submission to CARB on proposed PHEV test regulations Madame Chairman, Board of Directors and Staff. My name is Robb Protheroe and I am the President of Plug-In Supply. We manufacture PHEV conversions in California. I support PHEV conversions and ask that these unnecessary regulations be delayed for several years. There are many reasons to justify a delay but simply put, these regulations are based on testing first generation PHEV conversions that use Toyota EV mode and produce more pollution. Our next generation conversions produces less pollution than the unmodified car and do not use Toyota EV mode. There are no provisions in these procedures to test advanced PHEV conversions. We asked Staff for a simple test to prove we reduce emissions. Instead we got expensive, make-work, phone book thick test procedures. At the last meeting I heard the Board tell Staff to work with the PHEV conversion industry. I attended the meetings with Staff. We made reasonable suggestions to promote our industry and help clean the air. Every answer from Staff was the same: no, no and no. I also want to comment on the evaporative canister venting issue. This is a red herring. This 40-year-old design is an antiquated and primitive device found on every car. Much better designs exist. Instead of making the car companies modernize this device Staff has pushed it onto PHEV converters. Their twisted logic goes like this. If a hybrid is modified into a plug-in, the car could drive around for days, doing short trips, without using the gas engine. After 3 days of no gas engine operation the evap canister will vent releasing a few grams of benzene. The PHEV conversion caused this and that is an emissions increase compared to an unmodified hybrid and not allowed. If millions of hybrids are converted to PHEVs we will have a major problem. To solve this imagined problem they want us to start the gas engine every time the car is used to prevent evap canister venting. We must release a few pounds of CO2 every time the car is used to prevent releasing a few grams of benzene every 3 days. Every gas car that sits for 3 days vents. Following Staff logic all cars should be started every 3 days to prevent evap canister venting. Car salesmen should start every car on their lots every 3 days. If I ride my bike to work the canister vents. If I ride the bus the canister vents. If I walk to work the canister vents. All this is encouraged but if a PHEV causes venting by keeping a gas engine off, it’s a crime. I hope you see the lunacy in this. My final comment is on the cost of testing PHEV conversions. Staff released a document: APPENDIX K TECHNICAL SUPPORT DOCUMENT FOR ECONOMIC IMPACTS RELATED TO THE PROPOSED EXHAUST AND EVAPORATIVE TEST PROCEDURE AMENDMENTS. This document clearly state that these regulations will increase the cost of testing a PHEV modified car by 50%. And to add insult to injure, the more pure electric range the PHEV car has the more it will cost to test. I am not making this up. I ask the Board to tell Staff that all vehicle electrification products including PHEVs should be tested and approved for free and the cost of gas vehicle testing increased by 50%. Thank you for listening to my comments today. Robb Protheroe
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-27 10:55:19
Comment 173 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: TaylorLast Name: Davis
Email Address: taylorsdavis@gmail.com
Affiliation: SunPower Corp.
Subject: I Support Plug-In Hybrid Conversions
Comment:
If I had a nickel for everyone I've explained hybrids, plug-in hybrids and biofuels to over the last six years I'd be a rich man. I am very interested in the widespread adoption of these technologies and I drive a biodiesel truck and a hybrid car. In the aftermath of the fall of automakers that were considered "too big to fail" the new CARB restrictions on independent plug-in hybrid conversion companies threaten to make them "too small to succeed". Please support a worthwhile industry by raising the Tier 1 ceiling to AT LEAST 100 vehicles up from the currently proposed 10. I am astonished that it is perfectly legal to add superchargers to V8 gas guzzlers, but the plug-in hybrid conversion industry is stymied by the thought that their kits MIGHT in some POSSIBLE circumstance increase emissions. Now is the time to give these small businesses the help they need and deserve. Thank you, Taylor Davis
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-27 10:59:15
Comment 174 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: EdLast Name: Kulik
Email Address: ekulik@ford.com
Affiliation:
Subject: Ford Comments
Comment:
Thank you for the opportunity to provide public comment. Please find attached Ford's letter of support and input for consideration regarding the PHEV aftermarket conversion requirements. Ed Kulik
Attachment: www.arb.ca.gov/lists/phev09/305-ford_comments_phev_aftermarket_conversion_requirements_may_27_2009.doc
Original File Name: Ford comments_PHEV Aftermarket Conversion Requirements_May 27 2009.doc
Date and Time Comment Was Submitted: 2009-05-27 11:23:58
Comment 175 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: MichaelLast Name: Lord
Email Address: michael.lord@tema.toyota.com
Affiliation: Toyota Motor Eng & Manufacturing NA
Subject: Toyota Comments on PHEV Test Procedure Revisions for OEM and Aftermarket Conversions
Comment:
Please see attached.
Attachment: www.arb.ca.gov/lists/phev09/306-09063.pdf
Original File Name: 09063.pdf
Date and Time Comment Was Submitted: 2009-05-27 11:25:14
Comment 176 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: ChuckLast Name: Protheroe
Email Address: chuck@pluginsupply.com
Affiliation: PHEVIA
Subject: Comments from the Plug-In Hybrid Industry Association
Comment:
PHEVIA's Comments to the California ARB
Dear Board members and Staff,
The Plug-In Hybrid Industry Association would like to submit for
your consideration the following comments on the proposed
regulations for aftermarket conversions of plug-in hybrid electric
vehicles, PHEVs (OVCC HEVs).
The Plug-In Hybrid Industry Association (PHEVIA) is an association
of aftermarket PHEV conversion manufacturers and non-profit
advocacy groups. It was formed at the beginning of the year to give
voice to the many small but innovative manufacturers who have
pushed the PHEV conversion industry into existence.
We appreciate the Board's January decision to have these
regulations revisited and we also appreciate Staff's attempt to
provide a more financially viable path to compliance. However, the
currently proposed regulations will financially bar the majority of
conversion manufacturers from selling in California for the same
reasons as the original regulations. Therefore, we are offering
the following alternatives to make certification financially
possible for conversion manufacturers:
-Keep regulations as is, but have them not come into effect for a
period of 2 years or industry-wide sales of 14,000 units (5% of
HEVs currently on the road)
This will give successful manufacturers the time needed to
raise funds to pay for certification while keeping the number of
conversions to a non-significant level for California's air
quality.
We realize there are concerns with this approach, for setting
precedent in aftermarket regulations, and for having sub-par PHEV
conversions taint the public's perception of PHEVs. We therefore
offer this second alternative:
Keep regulations very similar to those proposed, and provide
incentive for PHEV conversions by funding all successful emissions
testing.
This will allow successful manufacturers to demonstrate the
quality and cleanliness of their products while enforcing strict
regulations on all conversions. It will also put California on
track for the AB32 requirements of 15% greenhouse gas emission
reductions by 2020 and put California at the forefront of President
Obama's goal of having 1 million PHEVs on the road by 2015.
For this approach the durability to vehicle's useful life, and
battery durability test requirements, would have to be delayed from
100 units to 500 units or 3 years as this data would take at least
this long to accumulate. Additionally testing access and
certification processing would have to be expedited, or an
in-process exemption would have to be granted, as current
certification times of 6 months to 1 year per tier would be too
long for smaller manufacturers to not be doing business.
Please consider the following environmental and economical effects
of passing the proposed regulations unmodified:
-Most conversion manufacturers would not be able to sell their
products in California, giving many a high-chance of going out of
business entirely. Includes but is not limited to, 7 PHEVIA member
manufacturers
-California dealers and installers of these manufacturers would go
out of business. Includes but not limited to 12 current member
businesses and hundreds of potential businesses.
-California distributors and contractors would loose a significant
amount of business immediately and loose the potential for an
enormous amount of business with future increased demand for
conversions. Includes but not limited to roughly 50 businesses per
member manufacturer.
-Loss of environmental benefits (emissions reductions,
electrification infrastructure improvements, etc.) from conversion
systems that would have been done in California. Includes but not
limited to projected average 300 units per member manufacturer per
year.
-Less pressure on vehicle manufacturers to produce PHEVs
themselves leading to slower mass-production.
While PHEVIA believes that the above-mentioned alternatives are
the most important changes the Board can make, and would give
conversion manufacturers access to certification, we would also
like you to consider the following issues we see with the currently
proposed regulations.
Warranty: conversion systems failing, or conversion systems
battery degrading results in stock vehicle operation and therefore
stock vehicle emissions. While a 5-10+ year warranty on conversion
systems is something to strive for, and in the future may be
appropriate to mandate, it is not currently necessary and would
result in higher-cost conversion systems and less innovative
designs. Both leading to less PHEVs on the road and the negative
effects of this. We instead suggest the ARB mandate a warranty
that the conversion system will not adversely affect vehicle
emissions. Let performance and consumer protection warranties be
dictated by the private sector.
Evaporative emissions: the problem of evaporative canister purging
is one found unaddressed in all vehicles, be they conventional gas
vehicles, HEVs, or PHEVs. While a PHEV may operate its gas engine
less, burning less fossil fuels and producing less exhaust
emissions, this does not make it responsible for the sub-ideal
design found in the stock vehicle. The PHEV is not any more
polluting then the car left in the garage on bike-to-work-week.
Emissions testing procedures: current emissions testing procedures
are outdated, based on driving patterns observed in the 70's before
HEVs and PHEVs existed. These procedures no longer accurately
reflect PHEV owners' driving which leads to PHEVs and HEVs that
have been optimized for passing tests instead of performing
efficiently and cleanly.
Thank you for your consideration.
Sincerely,
Chuck Protheroe
Representative
Plug-In Hybrid Industry Association
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Original File Name:
Date and Time Comment Was Submitted: 2009-05-27 11:48:56
Comment 177 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: RonaldLast Name: Gremban, CalCars
Email Address: rgremban@calcars.org
Affiliation: CalCars
Subject: Comments to PHEV09
Comment:
Comments to the California Air Resources Board by Ronald Gremban, CalCars Technology Lead, 5/27/2009 The attached file is a formatted version of these comments. 1. These are comments to the “Supplemental Staff Report for the Proposed Rulemaking for Plug-In Hybrid Electric Vehicle Test Procedure Amendments and Aftermarket Parts Certification Requirements” 2. Why are PHEV conversions important to California? 2.1. Automotive emissions vs. AB32 2.1.1. Automotive emissions make up around 40% of California’s GHG emissions 2.1.2. If automotive emissions decrease by only a small amount by 2020 (see below), all other segments will need to decrease by over 45% by then to make up for the shortfall toward the required overall 30% reduction from business-as-usual 2.2. Plug-in hybrids (PHEVs) are the only low carbon automotive option available in the short term, requiring no huge new infrastructure, and capable of renewable energy as the eventual energy source 2.2.1. PHEVs 2.2.1.1. The electric grid has excess nighttime capacity 2.2.1.2. Increasing renewable portfolio standards are already in progress 2.2.1.3. PHEV energy storage can eventually help even out renewable energy supply intermittency to enable higher proportions or renewables 2.2.1.4. Only ordinary outlets (120VAC, 15A) are required for overnight charging 2.2.1.5. Homes with garages usually already have outlets, and 2.2.1.6. Ordinary outlets can be added to apartment complex garages and carports by ordinary electricians and with minor if any local grid upgrades 2.2.2. Biofuels 2.2.2.1. Huge cellulosic or algae refineries, not yet proven at commercial scale, and transport infrastructure for feedstocks and resulting fuels, are needed to make enough biofuels to make a difference 2.2.2.2. As with PHEVs, most new vehicles will need to be forced to be capable of using the fuel(s) much sooner than anticipated, and existing vehicles will need to be converted en masse 2.2.3. Hydrogen: all infrastructures must be built from scratch 2.2.4. CNG 2.2.4.1. As with PHEVs and biofuels, vehicles will need to be converted en masse 2.2.4.2. Vehicle range is decreased 2.2.4.3. Although natural gas is nearly as ubiquitous as electricity, fueling stations with high pressure pumps and storage will need to be built 2.2.4.4. The 30% improvement in GHG is a dead end, as unlike electricity, it cannot eventually come from renewable sources as easily and efficiently as electricity 2.3. Best-case and likely worst-case new PHEV production 2.3.1. If 100k PHEVs are built in 2011 and production increases by 50% each year, 21% of new vehicles, and 3% of the nationwide fleet, will be PHEVs by 2020, reducing overall CO2 emissions by about 1% 2.3.1.1. If ¼ of these are in California, PHEVs might command 84% of the new car market by 2020 and 12% of the fleet, still reducing CO2 emissions by less than 4%. 2.3.2. If PHEV new-car penetration occurs at the same rate as for hybrids, only 2.2% of new vehicles, and 0.3% of the nationwide fleet, will be PHEVs by 2020, reducing CO2 by only 0.1%! 2.3.2.1. If ¼ of these are in California, PHEVs might command 8.8% of the new car market by 2020 and 1.2% of the fleet, still reducing CO2 emissions by less than 0.4%. 2.4. The importance of HEV-to-PHEV conversions, despite few hybrids 2.4.1. There are only XXX hybrids in California after a decade of sales. At this rate, there will be YYY by 2020. Converting these will reduce overall fleet GHG emissions by only ???%. However, HEV-to-PHEV conversions have (and can continue to): 2.4.1.1. Brought public attention to PHEVs 2.4.1.2. Provided the first actual experience of PHEVs operating in customers’ hands: customers’ responses, actual drive patterns, and how the vehicles perform 2.4.2. Handling the PHEV battery reliability and endurance ‘chicken and egg problem’ 2.4.2.1. Battery reliability and endurance testing takes years for each specific design 2.4.2.1.1. Accelerated bench testing is expensive, time consuming, and is too limited to be certain to apply to actual vehicle use 2.4.2.1.2. On-road experience requires many vehicles on roads for many years 2.4.2.2. No manufactured PHEVs and only a few conversions have been in consumer hands so far 2.4.2.3. Conversions (both from HEVs and ICEs) are an exceptionally good platform for gaining in-field battery experience, as 2.4.2.3.1. Many can be put in the field far faster than via new PHEVs 2.4.2.3.2. Each vehicle can be returned to OEM non-PHEV status if the battery fails, minimizing the impact. This can even be arranged to happen automatically. 2.4.2.3.3. Small conversion manufacturers can try a far wider variety of battery chemistries, manufacturers, and products than could possibly be brought into automotive production 2.4.2.3.3.1. Some will fail, but in doing so will leave knowledge in their wake 2.4.2.3.3.2. Others will succeed that otherwise might never have had the financial backing to make it to market via the auto manufacturers 2.4.3. Getting a significant number of designs on the road in the next few years, so that 2.4.3.1. The automotive and conversion industries discover what works in real customer hands, and use that knowledge to ramp up ASAP to millions of new PHEVs and ICE conversions soon enough to significantly impact 2020 GHG emissions. 2.4.3.1.1. GM was inspired to design the Volt via both PHEV conversions and Tesla Motors, then to commit to building it only after huge public response – enabled by the media response to conversions – to the Volt prototype 2.4.3.1.2. GM has solicited information from drivers of conversions to help tune the Volt’s design. 2.4.3.2. Conversion customers and the people they talk to will help pressure the auto manufacturers to begin building, then quickly build more and more PHEVs of all shapes and kinds 2.5. ICE conversions are needed to meet AB32’s 2020 goals 2.5.1. ICE conversions can target the least fuel-efficient vehicles 2.5.1.1. They are most cost-effective as well as most effective for larger, less fuel-efficient vehicles: SUVs, pickup trucks, and vans on up through many heavy-duty trucks and buses 2.5.2. ICE conversions can be rapidly scaled up 2.5.2.1. Though starting more modestly, a ramp-up rate much faster than that of new PHEV manufacture is possible, as 2.5.2.1.1. Other than the battery, only a few components need to be fabricated 2.5.2.1.2. The relatively time-consuming installation process can be farmed out to service shops throughout the state (and nation) 2.5.2.2. Battery availability is the limiting factor, but, unlike auto manufacturing, which depends on high volume designs, multi-year design and pre-production processes, and heavily capitalized suppliers, ICE conversions can 2.5.2.2.1. Use batteries of multiple chemistries and from smaller manufacturers 2.5.2.2.2. Be a venue for companies with innovative batteries to get field experience despite being too small or new to be an automotive OEM supplier 2.5.2.2.3. Cause the battery industry to scale up faster and sooner 2.6. Though these rules are for HEV-to-PHEV conversions, we are concerned about the implications for the ICE-to-PHEV rules that will also be needed 2.6.1. Poulsen Hybrid, LLC, has already been attempting to get their ICE-to-PHEV conversion certified, so far without success 3. What is the nature of the industry and its innovation? 3.1. The first are – and must be – small, experimental, and self-funded 3.1.1. Venture capital is not yet available 3.1.1.1. The market is as yet unproven 3.1.1.2. There is little experience of battery longevity in the field until many PHEVs have been driven for many years 3.1.1.2.1. This is a chicken vs. egg problem that a small-scale, innovative conversion industry can help break through by getting many possi 3.1.2. Start-up funds from home refinancing or small business loans – both especially difficult now 3.1.2.1. Total funds excluding receipts from early sales are typically within a factor of 2 or 3 of $100k 3.1.2.2. As well as supporting development and testing, these funds must also support the founders until sales can do so 3.1.2.3. Therefore, compliance costs must be funded as a percentage of sales receipts up to when the compliance is required 3.1.2.3.1. Figures higher than 25% of pre-compliance sales receipts will drive many entrepreneurial converters out of business 3.1.3. Speed 3.1.3.1. Most pre-sale engineering must be on paper, then one prototype 3.1.3.1.1. Cannot afford even to buy vehicles beyond those used for the founders’ own transportation 3.1.3.1.2. Neither time nor money for extensive, instrumented experiments 3.1.3.1.2.1. To verify field usage except in customer vehicles 3.1.3.1.2.2. To check operation in temperature and other extremes 3.1.3.1.3. Further engineering must be done by tracking and acting on feedback from the field 3.1.3.1.3.1. Customer feedback 3.1.3.1.3.2. Data from instrumented vehicles in customer hands (more below) 3.1.3.1.4. Much development is by field-inspired improvements, often inspiring retrofits to the rest of the converted fleet 3.2. As the industry matures, funding will become available and competitively necessary 3.2.1. For production engineering, bulk supply purchases, production processes, dealer/installer network development, marketing, etc. 3.2.2. A123’s purchase of Hymotion, started on a shoestring, illustrates one developing avenue 3.2.3. Once a market and industry are established, venture capital will also be possible 4. Possibly-unacknowledged existing SULEV/PZEV high-emissions scenarios 4.1. Engine start-up under load due to untested but possibly common driving regime 4.1.1. Unconverted: Warm-up under load occurs if accelerating (e.g. uphill) immediately after vehicle activation (start-up) 4.1.2. Conversions 4.1.2.1. This is the only known non-evaporative mechanism of emissions increase in conversions. 4.1.2.2. There are various well-known ways of controlling this at least as well as in the unconverted vehicles. 4.2. Evaporative emissions due to lack of use 4.2.1. Due to airport parking, mass transit or bicycle use, carpooling, etc, beyond 3 days 4.2.2. Why count pure EV trips in conversions differently? 4.2.2.1. If pure EV trips are counted as “vehicle unused” occasions, then conversions need only make sure to purge the OEM canister during non-EV trips 4.2.2.2. Otherwise, in order to purge the OEM canister, the engine must be used for long enough on every trip, thereby always causing gasoline use and emissions. 5. Tier quantities 5.1. The proposed quantities are a problem for early, necessarily self-funded conversion companies, as design and testing must be largely funded through sales 5.1.1. Compliance engineering and testing costs should be measured as a percentage of pre-requirement sales income 5.2. Our major new proposal will show how higher numbers will not risk higher emissions 5.3. However, we propose a new requirement for instrumentation of some converted vehicles and public release of anonymzed collected data 5.3.1. A major value of accommodating conversions is that of learning about driver behavior, battery requirements, and component reliability under real road conditions 5.3.2. Systems to collect, record, and transmit CAN bus information to a central server are commercially available at reasonable prices for use on a representative sample of vehicles 5.3.2.1. This data can be invaluable to 5.3.2.1.1. CARB 5.3.2.1.2. Both auto and conversion manufacturers, and 5.3.2.1.3. All researchers working to project the value of transportation electrification toward petroleum displacement and GHG emissions reductions 5.3.2.1.3.1. Projections can be refined with real data where only unvalidated assumptions have been available up to now 5.3.3. We propose that one Tier 1 vehicle, 5% of all Tier 2 vehicles, and 1% of Tier 3 vehicles be required to be so outfitted, with anonymzed data made available monthly or quarterly to CARB, which will immediately publish it its website 5.4. Please verify CARB staff’s indication that the 5000 vehicle total limit is for Tier 1 and 2 only 5.4.1. On page 5 it says, "After 5,000 vehicles are converted industry-wide, Tier 1 and Tier 2 options are no longer available. This limits and controls the overall potential emissions and economic impacts for the tiers as will be discussed in the next section." 5.4.2. At the recent session with CARB staff, we were led to believe that this 5000 is a limit of all vehicles in tiers 1 and 2 -- which would allow for up to 50 manufacturers -- not a total of all conversions. Since Tier 3 conversions will have been tested as per the previous non-tiered proposal, they do not have the perceived (see our new proposal, below) potential of impacting emissions that Tier 1 and 2 vehicles might have. On the other hand, if Tier 3 conversions are counted, one or two manufacturers could easily install more than 5000 (mostly Tier 3) conversions before other potential manufacturers get the chance to take advantage of the Tiered system at all. Therefore, we request that the 5000 limit be clarified in the rules to apply only to Tier 1 and Tier 2 conversions. 6. Warranty issues 6.1. Does the proposed conversion warranty extend OEM vehicle warranty in some cases? 6.1.1. Though recent revisions have reduced the cases where this may occur, the conversion warranty is required to extend beyond the OEM warranty on the vehicle when a conversion is applied on a vehicle with a shorter remaining or run-out OEM warranty. Though this may be clarified elsewhere, it is not clear from the conversion standards documents whether in this case the conversion warranty applies just to the conversion and any OEM parts that it may harm, or if it applies to the whole powertrain as necessary to keep it in compliance with emission requirements. 6.1.1.1. We see the former as an appropriate requirement and no problem. 6.1.1.2. However, if, as part of the required conversion warranty, the conversion manufacturer must also warranty the OEM powertrain beyond its OEM warranty, this could pose a serious hardships, as the converter would thereby become responsible for possibly expensive and near-worn-out OEM parts (such as engine, transmission, and catalytic converter components) beyond their design life. If this is indeed required, it would be economically unfeasible for conversion manufacturers to allow the conversion of vehicles without sufficient remaining OEM warranty to match the required conversion warranty. 6.2. PHEV battery warranty 6.2.1. As of yet, PHEV battery longevity in actual vehicles is somewhat of an unknown, as few if any such vehicles have been operating for even 3 years or 50,000 miles. Additionally, some inexpensive batteries have expected lifetimes nowhere near the 5 year / 75,000 mile requirement, let alone the possible 10 year / 150,000 miles required of a brand new PZEV vehicle conversion. For example, lead-acid batteries, with an expected lifetime of 2-3 years but a low enough cost to allow for multiple replacements during the vehicle's lifetime, are often employed because of low up-front costs, an initial savings that would be removed by having to prepay for the expected replacements via an extended performance (as opposed to emissions-only) conversion warranty requirement. 6.2.2. We suggest that the required conversion warranty cover only whatever battery capacity or capability is required, given the conversion’s electronics, to maintain required emissions levels (some conversions may be able to accomplish this with a completely dead conversion battery), not what may be necessary for any particular level of plug-in performance. 6.2.3. For consumer protection, require only that the vehicle work as well as before conversion during the warranty period, and that the conversion manufacturer state its additional battery warranty. Competition will no doubt independently lead conversion manufactures to offer additional battery performance warranties consistent with the capabilities, costs, and developing track records of the batteries used in their conversions. 7. Durability testing 7.1. Though other components may be hard to ‘prove’, the batteries are the main issue 7.2. It is completely unfeasible for small conversion manufacturers to life-test the batteries that go into its conversions, as batteries are especially difficult to test for durability. 7.2.1. Battery manufacturers' test data is seldom directly applicable to PHEVs, is usually on a cell (vs. pack) basis, and is often unavailable to small conversion manufacturers anyway. 7.2.2. Accelerated cycle testing of packs requires large and expensive automated test equipment, is difficult to match to expected road use and conditions, the timeline can often be accelerated by a factor of only 4 or 5, and the effects are nonlinear and cannot necessarily be extrapolated from early results. 7.2.2.1. The Electric Power Research Institute (EPRI) has had a major accelerated PHEV-cycle battery testing project going on for years that has so far managed to test only one NiMH and one now-obsolete Li-ion pack to around 3/4 of its lifetime. 7.2.3. Vehicle lifetime testing therefore takes years per possible battery pack, each of which is obsolete by the end of the test and may or may not end up acceptable anyway. 7.3. It is totally unfeasible for largely-sales-financed small conversion manufacturer to be able to show vehicle-life durability beyond a few thousand miles prior to selling 100 conversions and requiring Tier 3 certification to continue, as -- unless a special deal can be reached with a taxi company -- to do so would require both paying drivers to put miles on a converted vehicle nearly 24-7 and prematurely wearing out the multi-thousand-dollar vehicle itself. 8. CalCars’ major new proposal to minimize testing costs to validate low conversion emissions 8.1. There are only two known sources of added emissions in HEV-to-PHEV conversions 8.2. There are simple solutions to each of these problems that have already been demonstrated to work (though at the cost of less gasoline displacement), and innovative new solutions can be validated as necessary 8.2.1. Engine warm-up under load 8.2.1.1. Do not disable engine start-up and warm-up upon initial vehicle activation. Then, force periodic restart of the engine to ensure maintenance of the catalytic converter’s (CAT’s) temperature. 8.2.1.1.1. Periodic restarts can be timed for pauses no longer than the maximum encountered in unconverted vehicles, or 8.2.1.1.2. The CAT temperature can be measured, and a restart initiated before its temperature falls below a specified ignition temperature 8.2.1.2. To run the vehicle as a pure electric, with no engine start, engine start must be inhibited until a no-load warm-up period is ensured, or until the vehicle is deactivated and reactivated in a mode where the engine is immediately started and warmed-up. 8.2.2. Reduced purging of evaporative canister 8.2.2.1. Do not disable engine start-up and warm-up upon initial vehicle activation 8.2.2.2. Once every day (or every X days, as decided by CARB), force engine operation for long enough to purge the canister 8.3. The validation that a conversion reliably uses a known-to-work solution for each of the two areas of concern is much easier and just as effective as full emissions testing 8.4. Once ICE-to-PHEV conversions are shown to have a similar small set of areas of concern, they, too, should be subject to similar abbreviated certification requirements 8.5. Our proposal 8.5.1. To be certified Tier 1, a conversion must be shown on paper to reliably incorporate a known solution to each of the two areas of concern, or to incorporate another method that is logically proven to CARB staff to also solve the problem. 8.5.2. As above, we propose a new requirement for instrumentation of some converted vehicles and public release of anonymzed collected data 8.5.2.1. A major value of accommodating conversions is that of learning about driver behavior, battery requirements, and component reliability under real road conditions 8.5.2.2. Systems to collect, record, and transmit CAN bus information to a central server are commercially available at reasonable prices for use on a representative sample of vehicles 8.5.2.2.1. This data can be invaluable to 8.5.2.2.1.1. CARB 8.5.2.2.1.2. Both auto and conversion manufacturers, and 8.5.2.2.1.3. All researchers working to project the value of transportation electrification toward petroleum displacement and GHG emissions reductions 8.5.2.2.1.3.1. Projections can be refined with real data where only unvalidated assumptions have been available up to now 8.5.2.3. We propose that one Tier 1 vehicle, 5% of all Tier 2 vehicles, and 1% of Tier 3 vehicles be required to be so outfitted, with anonymzed data made available monthly or quarterly to CARB, which will immediately publish it its website 8.5.3. To be certified Tier 2, the operation of these solutions must be demonstrated to CARB staff, either by direct demonstration or by results from an instrumented Tier 1 conversion 8.5.4. Tier 3 certification will require ongoing verification of the solutions on instrumented Tier 2 and Tier 3 vehicles 8.5.5. We believe this proposed alternative to CARB staff proposals greatly reduces the potential for emissions from conversions while simultaneously greatly reducing the costs to conversion manufacturers. An additional advantage is the availability of valuable operational data for use by many parties. Thank you.
Attachment: www.arb.ca.gov/lists/phev09/309-ronscalcarscomments_090527.doc
Original File Name: RonsCalCarsComments_090527.doc
Date and Time Comment Was Submitted: 2009-05-27 11:55:56
Comment 178 for Plug-In Electric Hybrid Vehicles (phev09) - 45 Day.
First Name: AlanLast Name: Weverstad
Email Address: Non-web submitted comment
Affiliation:
Subject: General Motors
Comment:
please see attached
Attachment: www.arb.ca.gov/lists/phev09/314-alan_weverstad.pdf
Original File Name: Alan Weverstad.pdf
Date and Time Comment Was Submitted: 2009-05-29 09:47:09
