Comment Log Display

Dear California Air Resources Board,

I would like to respectfully submit the following comments on
behalf of our startup company, 3Prong Power, our employees, our
customers and the customers we plan to serve in the years ahead. 
Our company enables owners of the popular Toyota Prius hybrid to
reduce their air and climate impact and increase their fuel economy
through the installation of an after-market plug-in electric
upgrade.

We appreciate the thoughtfulness that CARB has put into drafting
the proposed regulations and test procedures to address the newly
available class of off board charging hybrid vehicles.  We know
your agency is aware of the enormous potential for this emerging
class of vehicle, commonly known as Plug-In Hybrid Electric
Vehicles (PHEVs), to improve California's air quality and to
address global warming.

Since the last time these regulations were considered at a CARB
board meeting in January, we have met on several occasions with
CARB staff to discuss our concerns.  We appreciate the CARB staff's
willingness to meet with us and their movement toward a tiered
structure for compliance with these proposed regulations.

At 3Prong Power we believe that PHEV conversions are a crucial
first step in catalyzing a "virtuous cycle" or positive feedback
loop in the marketplace, one that steadily raises electric
driving's share of the transportation market, in foreseeable steps.
 The virtuous cycle we envision looks something like this:

    * We start by converting existing vehicles to PHEV;
    * These PHEV conversions lead to more recharging
infrastructure;
    * More infrastructure and market development lead to even more
demand for plug-in vehicles;
    * The plug-in vehicle market grows to the point where large
businesses and automotive OEM's jump in; 
    * This leads to high volumes, lower costs and improved
performance, encouraging more electric driving;
    * Growing demand spurs installation of second generation
charging technology such as fast charging, battery swap, and
vehicle-to-grid technology.


Ultimately, as batteries and infrastructure improve, it becomes
possible to dispense with the gas engine entirely and transition to
all electric transportation.  That end result represents a dramatic
paradigm shift. 

Along the way, PHEV conversions help to:

    * Clean the air;
    * Slow global warming;
    * Break our addiction to oil;
    * Foster innovation;
    * Create good, green jobs here in California.


Because it offers all these valuable benefits along the way to
ultimately transformative change, our PHEV conversion technology
merits a lighter regulatory touch than alternative technologies
whose end results are merely incremental reductions in carbon and
other criteria pollutants, technologies such as agricultural
biofuels or "alternative" fossil fuels.

In fact, though, regulation of PHEV conversions should go further,
and create incentives that grow this segment of the transportation
market, rather than chill it or even stop it altogether.

In this spirit, we welcome the conceptual shift proposed by the
CARB staff toward a tiered approach to certification in our
industry.  A tiered approach should allow small, innovative
California businesses to operate, grow, and gain important market
and technological feedback at a low and manageable cost of
compliance, while ramping at a reasonable rate toward full
compliance with necessary regulations at an appropriate stage. 

An appropriately tiered ramp-up in regulatory requirements is
crucial to the survival of these companies, which are presently
very young and highly vulnerable to significant cost burdens. 
Costs such as those imposed by the laboratory testing requirements
in Tier 2 would cripple us, and other California PHEV conversion
companies, if imposed too early. 

Unfortunately, we feel that these concerns are not reflected in
the CARB staff's current proposal. 

We respectfully request the following modifications to the
proposed regulations:

1.  Tier 1 Ceiling.  First and most imporant, we urge CARB to
raise the Tier 1 ceiling to 100 vehicles (up from 10 as currently
proposed).

Setting the first tier ceiling at only 10 vehicles, while placing
the most expensive part of compliance in the second tier, defeats
the intended purpose of the tiered approach.  All the businesses in
California currently offering PHEV conversions have already
exceeded the proposed 10 vehicle first tier limit.The one notable
exception to this pattern is an out-of-state company which has been
able to pay for laboratory testing with financial resources
unavailable to the California companies  Setting the first tier
ceiling so low would be highly disruptive to the nascent California
PHEV industry. 

Instead, the number of vehicles sold under Tier I should be
sufficient to allow room for product refinement, feedback from
consumers, business development, and revenue generation, before
companies like ours face the most expensive area of compliance:
laboratory testing.  If we assume $200,000 as a reasonable estimate
of the cost of testing, spreading this cost over just 10 vehicles
effectively adds $20,000 to the cost of each one.  It's easy to see
that this figure is prohibitive from the consumer's perspective --
roughly equaling the base cost of a new Prius, and more than
tripling the cost of conversion alone. 

We suggest that a Tier 1 ceiling of 100 vehicles is more
appropriate.  A Tier 1 ceiling of 100 will vehicles allow PHEV
businesses still in their infancy to continue operating in the
first Tier, while integrating customer feedback, refining their
products, developing their businesses, and generating revenue. 
Spreading the testing cost over 100 sales effectively adds just
$2,000 to the cost of each vehicle, which is manageable. 

2. Evaporative Emissions.  We request that the test procedure be
modified so that only a charge sustaining drive cycle is required
before evaporative emissions testing. 

The current test procedure calls for a short drive cycle in charge
depletion mode before testing for successful canister purge. 
Depending on the PHEV architecture, it may be possible to complete
this short drive cycle using only the electric motor.  Using solely
the gasoline engine will result in no purging of the canister and
cause the vehicle to fail the test procedure.

We believe this is flawed reasoning for two reasons.  Firstly,
real world experience has shown that most of our customers have
longer drive cycles than required by the test procedure, so that
the engine does, in fact, run in charge sustaining mode most days. 
This enables a proper purge of the canister.  Secondly, those
customers that are able to keep their driving to a minimum and
maintain the vehicle in charge depletion mode, will quickly realize
that their needs can be as easily met by an EV as a PHEV and
therefore will likely become early adopters of that technology. 
Even if that transition does not materialize, this situation is not
worse than the situation where someone decides to ride their
bicycle or take public transportation most days and leave their car
at home.

Requiring a PHEV to operate only in charge depletion mode before
testing for canister purge is analogous to requiring standard
hybrids to be parked while the driver rides a bicycle around before
testing for canister purge.  Both situations, commuting by bicycle
and driving a PHEV in electric mode only, will increase evaporative
emissions, however we believe that both situations deserve to be
encouraged not prohibited due to technicalities of a test
procedure. Therefore we request that the test procedure be modified
so only a charge sustaining drive cycle is required before testing
for evaporative emissions.

3. Warrany Issues.  The warranty requirement should explicitly
exclude a performance warranty on the battery.

The staff recommendations continue to focus on the length of the
warranty, and seek to hold PHEV supplemental batteries up to the
high standard set by the HEV industry.  We do not disagree with the
warranty length as recommended.  However, we believe that what
exactly is covered by the warranty should be more clearly spelled
out.  Specifically, for current HEVs, the hybrid battery warranty
does not warranty against degradation of the battery capacity over
time.  It warranties that the vehicle will run and that it will
meet emission requirements.  We believe that the supplemental
battery should be held to that standard, i.e. to warranty that
emissions will not be impacted and that the vehicle will continue
to run.  Performance degradation of the battery over time should
not be interpreted as a reason to replace the entire battery under
warranty.  The exact nature of the warranty requirements are not
explicit in the staff proposal.  We request that an explicit
exclusion of performance warranty on the battery be included.


Thank you for the opportunity to provide this input on how to
create a set of regulations for PHEVs and ZEVs that will best
provide Californians with increasingly clean alternatives for
personal transportation.

We hope very much that you will choose to adopting the changes
requested here.  We believe these are the best ways CARB can
support the California consumers who want to drive Plug-In Hybrids,
the young California companies that provide the technology, our
employees, and clean air and a healthy climate for everyone.  With
your help, we'll do all we can to advance California's transition
to electric driving as smoothly and quickly as possible.


Respectfully submitted,


Daniel Sherwood

President, 3Prong Power
Daniel@3prongpower.com