Comment Log Display

Howard Letovsky 707-481-5252
CARB Proposed PHEV Regulation Comments:

I am of the opinion that CARB and all developers of systems
intended to improve gas mileage and reduce emissions and dependence
on foreign oil are working toward the same goal. Therefore I
suggest the following:

1.	A developer should be able to acquire a “Certificate to Perform
R&D” from CARB immediately on request for on any technology with
the stated purpose of reducing the use of fossil fuels and reducing
emissions.
2.	This “Certificate to Perform R&D” should include the name,
address, and phone number of the technologist, a short description
of the intended technology, and the VIN number of the intended test
vehicle if one exists. An addendum to the “Certificate to Perform
R&D” should be gotten if a test vehicle is chosen at a later date.
3.	When the test vehicle that uses the above stated technology is
registered for road use, or within 6 months of the receipt of the
“Certificate to Perform R&D”, it must get a smog test.
4.	If the test vehicle passes the smog test, it is allowed to be
used on the road for a year – at which point a second smog test
must be successfully passed or the vehicle modifications must be
removed. If the second smog test is successful the modifications
can stay.
5.	CARB should provide free emissions and compliance testing for
all holders of said “Certificate to Perform R&D”.
6.	All technologies covered under the “Certificate to Perform R&D”
should not be subject to any harsher or different regulations than
any other replacement part that does not affect a smog test.
7.	In the specific case of PHEV modification units, CAB should
provide convenient testing services for all developers of said PHEV
modification units, and if the units are found to be “vehicle
neutral” through the onboard CANBUS or OBD system, CARB should
issue an opinion that said PHEV modification unit does not nullify
the car maker’s warranty. I realize this opinion is probably
impossible to defend in court but it could be helpful to get the
auto makers to work together with independent technology
developers.
8.	Extend the same 500 unit courtesy that Hymotion got to all
developers of PHEV modification units. It is not nice to play
favorites.
9.	In the case of R&D PHEV modification units that are bought by
an end user in the retail sector, they must take full
responsibility for any loss, failure, or warranty problems that the
PHEV modification unit causes with the full understanding that they
are participating in a technology development exercise.
10.	Production PHEV modification units – when certified - should
not carry any greater warranty requirements or loss
indemnifications that any other aftermarket part is subject to.
11.	The only way the major car companies will ever fully deploy
long range PHEVs or pure electrics is when it is absolutely clear
that it is profitable and the market is ready. The efforts of
independent technology developers – when successful – will push, or
shame, the major auto maker’s into taking action to meet market
demand. Ultimately, only large well funded auto maker’s can make
cars for a mass market so there is really no threat to the auto
industry from independent technology developers.

I have built over 200 electric vehicles in the past 25 years –
including the World’s First Electric Police Car, featured on the
Discovery Channel, and a fully functional Solar Powered City
Electric car that gets 20 miles per day on sunshine alone and goes
35 miles per hour with 4 adults on board. I have participated in
creating all electric tractors for agricultural use that are 500%
more efficient than liquid fueled tractors.

Thanks for reading the above list.

I can be reached at any time to discuss these and other vehicle
improvement issues.

Howard Letovsky
707-481-5252