Comment Log Display

I urge you to reconsider the regulations that you have proposed for
Plug-in Hybrid Electric Vehicles. 

I own a 2005 Prius that I recently had converted to a Plug-in by
3ProngPower in Berkeley. My husband and I are thrilled to have this
vehicle, which we charge from electricity generated by solar panels
on the roof of our home. Our Plug-in Prius allows us to reduce our
CO2 production and use less gasoline. If the regulations that CARB
has proposed are put in place, the nascent Plug-in conversion
industry would be effectively squelched and others would not be
able to make the choice to reduce their carbon footprint in this
way.

It is also important to me to reduce emissions that contribute to
smog. Therefore, I appreciate the concerns expressed by the CARB
engineering staff about the issues of multiple cold starts and the
evaporation of gasoline in cars that are not started within a three
day period. These are issues that I was not aware of. However,
these issues can be easily addressed by maintaining the initial
engine run sequence
on startup that is currently programmed into all Hybrid Vehicles.
Simply having this as the one and only requirement would alleviate
nearly all the concerns raised by the CARB engineering staff
without requiring any expensive testing and regulation. I can
attest to the fact that my Plug-in Prius doesn’t go three days
without the engine starting, except when I am away on vacation. 
Please keep this issue in perspective! The emissions coming from
evaporating gasoline from all the CA vehicles that are not started
every three days is MUCH more significant than the emissions coming
from a very small number of Plug-in Hybrids, whose owners are very
motivated to reduce the emissions. 

As I understand it, part of CARB's mandate is to promote low
carbon transportation.  The proposed regulations seem to be
contrary to this mandate.  CARB should be doing everything in it's
power to encourage Plug-In Electric vehicles, not spending it's
resources in premature restrictive regulation.

Please consider keeping a low level of restrictive regulations
regarding PHEV building, testing and marketing.  At this formative
time in the PHEV technology, unnecessary regulation will only serve
to hamper the advancement of the state of the art.  The educated
consumer is fully capable of making a prudent decision provided all
the facts are known. The proposed rules could drastically slow
growth of the conversion industry, and it  could prevent further
progress with components, software and usability. 

I urge the Air Resources Board to exercise restraint in its
efforts and remember that the benefits from these emerging PHEV
technology is of great value to society and the planet.

Thank you for your time and consideration of this very important
issue.

Cindy Evans Trueblood