Comment Log Display

25 September 2013
Mr. Craig Duehring
California Air Resources Board
1001 I Street
Sacramento, CA 95814
RE: Comments to the Amendments to the Alternative Fuel Vehicle
Conversion Certification Procedures for On-Road Motor Vehicles and
Engines. 
Mr. Duehring,
Transfer Flow Incorporated appreciates that the California Air
Resources Board has listened to the suggestions from industry and
is willing to work with industry to increase the availability of
Alternative Fuel Vehicles in California.  Transfer Flow Inc. has
and will continue to work with CARB to ensure that regulatory
actions keep pace with technology while maintaining feasibility for
businesses.  
Transfer Flow Inc. supports CARB’s efforts to streamline the
certification process for AFV’s in California however Transfer Flow
Inc. disagrees with some of CARB staffs assertions.  To continue to
require durability testing on vehicles and components that are past
their useful life is an overreach regulatory action.  If a vehicle
is past its expected useful life and is able to pass the State
approved testing at a Bureau of Automotive Repair licensed state
inspection facility then such a vehicle should be able to be
converted without any further regulatory intervention.  Similarly,
the requirement that any credit generating converted vehicle must
be inspected by a BAR Referee prior to releasing the vehicle to the
consumer is not feasible.  
While Transfer Flow Inc. agrees that technologies are continuously
advancing, the justification for the use of a sunset provision to
eliminate many of the proposed streamlining measures due to lower
emissions standards taking effect in the 2018 Model Year is not
true streamlining.  Since lower emissions standards will be the new
requirement in 2018, AFV’s will continue to have to meet the new
lower standards for newer model year vehicles. Requiring more
stringent certification measures in 2018 for AFV’s will not change
the emissions standards that the converted vehicles have to meet,
but rather will cause the same situation we currently find
ourselves in where conversion manufacturers are unable to meet
certification requirements in a timely cost effective manner.
Transfer Flow proposes the elimination of the sunset provision as a
“safety net to contain potential emissions impacts”.  Any such
emissions impacts would be discovered by the safety net already in
place through emissions inspection and testing at the biannual
vehicle testing at BAR licensed state emissions testing
facilities.
Furthermore Transfer Flow Inc. proposes the ability to use
aggregate durability testing for certification.  Data from multiple
converted vehicles that have like systems installed with similar
initial miles prior to conversion with different driving use, and
therefore different accumulated mileage after conversion, would
adequately prove the required durability testing. 

Transfer Flow Inc. looks forward to the outcome of CARB’s
consideration of the amendments to the certification requirement
for AFV’s in California and appreciates the opportunity to comment
on the proposed changes.

Sincerely,

Todd LaPant P.E.
Director of Engineering  
Transfer Flow Incorporated
1444 Fortress St.
Chico CA 95973