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,
with our technology enabling the popular Prius hybrid to reduce its
air and climate impact and increase its fuel economy through the
installation of an after-market plug-in electric upgrade.  
I appreciated the thoughtfulness that CARB has obviously put into
drafting the proposed regulations and test procedures to address
the newly available class of off board charging hybrid vehicles.  I
am certain that 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 our state air quality and
fight global warming. 

I urge CARB to revise their proposed regulations so they are not
at cross purposes.  As currently written the proposed regulations
will serve to stifle the nascent California based PHEV industry. 
The aim of CARB is to improve air quality and vehicle
electrification is an essential part of the solution.  In the
upcoming Plug-In Hybrid Electric Vehicle Test Procedure Amendments
and Aftermarket Parts Certification Requirements the agency needs
to strike a balance between regulating for air quality and allowing
room for PHEV innovation to continue to flourish.
After attending CARB’s September workshop on test procedures for
hybrid electric vehicles, I was concerned that CARB may not have
adequately considered how best to foster the innovation,
development, and market adoption of increasingly electrified hybrid
vehicles.

It is through innovation by nimble, progressive small businesses
and non-profits here in California that many basic system design
elements have come into being and evolved.  Further design
evolution is absolutely necessary to bring these environmentally
beneficial vehicle technologies to mass market scale.  Small, local
companies will play a leading role in proving and developing the
consumer market for this emerging technology.  This offers an
environmental benefit with gigantic leverage: history has
repeatedly shown that only when a mass market opportunity is
well-established and proven will major international automakers
step in to exploit and serve it.


I therefore respectfully urge CARB to set requirements and test
procedures that will achieve the most environmentally beneficial
balance between clear guidance on vehicle air quality regulations
and the fostering of innovation in this field.

Specifically, we are concerned about the following proposed
changes to CARB’s regulations:

Evaporative Test Procedures

The draft evaporative test procedures call for up to five vehicles
to be made available to CARB for testing purposes.  While it is
important that the effects of “always plugging in” be accounted
for when testing an ORVR device, a readily available alternative
exists: simply running the combustion engine at startup, as all
hybrid vehicles currently do, will resolve this issue.  

CARB’s proposed requirement that 5 vehicles would be utterly
prohibitive for a bootstrapping startup like us.  We hold only one
operational vehicles in inventory that is used to demonstrate the
technology to our customers.  A requirement to provide multiple
vehicles for testing without providing a funding source for these
vehicles would instantly put us out of business, choking off the
vital technical and market development we are working hard to offer
to California’s environment and consumers.

After Market Part Warranty Requirements 

The after market parts requirement for providing a warranty
equivalent to the vehicle warranty period is inappropriate for the
vehicle battery.  While some manufacturers have been able to obtain
impressive battery longevity in hybrid electric vehicles, the same
battery lifetime will not be matched if the battery is used more
intensively, as is typical in an off-board charging duty cycle. 

Also, the most widely available, affordable and easily re-cycled
battery technology remains lead acid batteries, which have been
used for decades in electric vehicle applications.  These batteries
clearly can not achieve a 7 year lifespan.  Instead, as long as
consumers are made properly aware of realistic battery lifespan
expectations, there’s no need to bar the use of a proven,
commonly available, and affordable technology that has a lifespan
shorter than 7 years.

Exhaust Test Procedures

There is no reason to believe that after market vehicles will fail
the urban drive cycle test procedure as long as they maintain the
initial engine run that is programmed into all hybrid cars as
described above.  Again for a small after market parts manufacturer
providing vehicles for expensive testing is an overly onerous
requirement unless further data is provided to suggest that there
is a problem.

OBD Minimum Frequency Requirements

The OBD requirements were not created with PHEVs in mind.  It may
not be possible for plug-in hybrids to meet the minimum frequency
for OBD measurements of engine related functions.  It is valuable
to keep in mind that the minimum frequency requirements are
designed to keep engine emissions low, with a PHEV the engine
operates a fraction of the time compared with standard vehicle. 
While this may cause a PHEV to not meet the minimum frequency, the
overall benefits of PHEVs to air quality outweigh this concern. 

In addition, all HEVs are currently exempt from smog testing and
therefore the OBD log data does not serve a useful function in
detecting problems with the emissions systems.      
We urge CARB to drop this requirement from the test procedures as
it is nearly impossible to work around, difficult to test and will
not have a significant impact on air quality. 

In General

My company respectfully requests and urges that before adopting
these regulations CARB first join us and other stakeholders in a
conversation so that we can jointly identify a mutually, socially,
and environmentally beneficial pathway that fosters the innovation
needed in this area until the industry is mature enough to pay the
costs of the kind of extensive testing and certification we would
all like to see eventually.

We would also encourage CARB to work with the non-profit
organization CalCars.org, by adding to their existing open source
design repository any modifications to the run
cycle or vehicle components that would allow modified HEVs to
satisfy clean air requirements.

Finally, we would like to request an exemption for small
manufacturers selling very small quantities of cars or conversions,
such as fewer than 500 in a year, from these requirements.  We
think this is a reasonable request so long as the number of
modified cars remains statistically negligible, as is the case
today.

Thank you for the opportunity to provide this input on how to
create a set of testing and regulations for PHEV and ZEV that will
best provide Californians with increasingly clean air standards
while promoting clean emission alternatives for personal
transportation.  

Respectfully submitted,

Daniel Sherwood
President, 3Prong Power
Daniel@3prongpower.com