Comment Log Display

To the Chair and Members of the California Air Resources Board:

Plug In America strongly believes that plug-in hybrid electric
vehicle conversions will play an important role in the next five
years toward helping California meet the ambitious goals set forth
in AB32. We are also listening to the voices of our constituents --
consumers who are eager to get behind the wheel of a
highway-capable vehicle that is fueled by the state's clean
electricity grid, as well as viable plug-in hybrid conversion
companies that are eager to meet reasonable standards.
 
We believe that the plug-in hybrid vehicle conversions offer
consumers a faster and more affordable way to get into plug-in
vehicles while the general public waits for the plug-in automobiles
which are expected to be introduced by the OEMs starting in late
2010 and beyond. 
 
With this forward-thinking position in mind, Plug In America is
also 
cognizant that even well intentioned mechanic shops may be
entering into unfamiliar territory. We have always taken the
position that plug-in hybrid conversions of both existing hybrids
as well as internal combustion engine vehicles should adhere to
standards of health and safety involving both emissions and
crash-testing. 
 
We encourage CARB to take an approach in adapting regulations to
balance the desires of consumers while creating opportunities in
the marketplace for green businesses, small and large, to meet
reasonable standards of battery warranty, emissions and OBD II
compliance. We believe that staff has worked hard to deal with the
complexity of these issues and will be able to clarify them so that
plug-in hybrid conversions can truly deploy to consumers.

Plug In America has identified three themes in the current
rulemaking that need either clarification or comment:
1. How hybrid conversions are expected to meet the new
regulations.
2. How non-hybrid conversions are expected to meet the new
regulations.
3. OBD II standards.

It is important for the marketplace, for consumers, and for air
quality, to be very clear and specific about battery warranty
requirements for different types of conversions. As long as a
converted vehicle's original emissions standard is maintained
during the original emissions warranty period, we propose that CARB
should certify the conversion. For plug-in hybrid conversions that
do not modify the existing hybrid battery, there should be a
separate and shorter warranty requirement.

Some significant private companies in California are not
dismissing the possibility of converting thousands, if not millions
of internal combustion engine vehicles to plug-in hybrid vehicles.
In this case, there would be no prior batteries needing warranty
clarification. It is important for ARB to delineate its
requirements for conversions of existing hybrid cars versus ICEs.
It is also important for ARB to be clear on its warranty range
requirements for aftermarket conversions in these two different
scenarios.
 
With regard to OBD II standards, the biggest issue is that many of
the OEMs have proprietary data that is not available for during the
testing process. Since you are offering gradual phase-in of OBD II
standards as per the language in the Appendix of the Staff Report,
you may want to consider making this more openly visible to all of
the parties.
 
Given President Obama’s support for plug-in vehicles and the
possibility that the upcoming Federal stimulus bill may include
funding for aggressive deployment of fully electric and plug-in
vehicles into the marketplace, it would be unfortunate if
California's standards were too onerous to allow California
consumers and companies to take advantage of this opportunity. We
encourage the California Air Resources Board to act in a way that
encourages the widespread development and deployment of plug-in
hybrid conversions.

Thank you for your time and consideration of our comments.

Sincerely,

Jay Friedland
Legislative Director
Plug In America