Comment Log Display

The Executive Summary for this proposed amendments to PHEV testing
includes the following:  “The most recent changes to the ZEV
regulation, considered in March 2008 included provisions that
strongly encourage commercialization of plug-in HEVs (PHEV) or off
vehicle charge capable (OVCC) HEVs.”

However, parts of the proposed changes will have the opposite
effect, to discourage commercialization of PHEVs.  In Section 4.5
Aftermarket Parts Program, the requirement for mandatory warranty
periods as listed in Table 4-1 sets unrealistically high
requirements that will destroy the newly developing plug-in hybrid
conversion industry.  Current battery technology cannot last for 10
years or 150,000 miles, so requiring the conversion companies to
offer such long warranties will require them to charge for triple
conversions, essentially putting them out of business.  

There is much research going on to improve battery technology, so
this is an area where we should encourage innovation and let the
market sort out the viable technologies.  This means encouraging
small businesses to do these conversions and see what works and
what people are willing to pay for.  Don’t inhibit this innovation
by setting unrealistic regulations.  You should drop the warranty
requirements entirely from the regulations of conversion systems.

I also urge you to work with the small conversion businesses (such
as 3Prong Power in Berkeley, Luscious Garage in San Francisco, and
Pat’s Garage in San Francisco) to ensure that the emissions testing
requirements for conversion systems are affordable for small
businesses.  These businesses don’t have the resources of the major
car companies, that can afford to do extensive testing.  However,
these small companies do have the ability to be much more
innovative, much more quickly, which has the promise of advancing
our ZEV technology faster than the major car companies can.  Please
don’t over regulate this emerging industry and retard its
development.

Sincerely,
Shelby Solomon