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"WHO KILLED THE PHEV" could be the next movie that results from
ANOTHER poorly considered CARB regulation.  Let's not be too hasty
to regulate after-market conversions that will reduce fossil fuel
pollution.

It appears to me that this regulation is obviously contrary to the
intended purpose of CARB regulations -- to reduce air pollution. 

As a 2005 Prius owner who is considering a PHEV conversion, I also
believe that you may be messing with the future production of PHEVs
by large auto manufacturers.  PHEV conversions are a significant
reason that auto manufacturers are now going to produce them.  And,
the growing number of conversions  demonstrates the business case
for automakers to move more quickly. Regulating conversions will
slow the number of conversions and make the business case less
enticing to large automakers.  (Are the large automakers behind
this regulation? As they were behind the electric vehicle
regulation changes?) 

Staff should reconsider this regulation in light of the positive
effects of conversions done by the nascent PHEV industry versus the
possible miniscule negative effects on air pollution produced by a
few hundred conversions.  Don't you have a lot bigger air pollution
problems to spend your time on? How about diverting some of your
staff to looking into helping reduce air pollution by stopping poor
regulations from being written?