Comment Log Display

Submission to CARB on proposed PHEV test regulations


Madame Chairman, Board of Directors and Staff.

My name is Robb Protheroe and I am the President of Plug-In
Supply. We manufacture PHEV conversions in California.

I support PHEV conversions and ask that these unnecessary
regulations be delayed for several years.

There are many reasons to justify a delay but simply put, these
regulations are based on testing first generation PHEV conversions
that use Toyota EV mode and produce more pollution.

Our next generation conversions produces less pollution than the
unmodified car and do not use Toyota EV mode. There are no
provisions in these procedures to test advanced PHEV conversions.
We asked Staff for a simple test to prove we reduce emissions.
Instead we got expensive, make-work, phone book thick test
procedures. 

At the last meeting I heard the Board tell Staff to work with the
PHEV conversion industry. I attended the meetings with Staff. We
made reasonable suggestions to promote our industry and help clean
the air.  Every answer from Staff was the same: no, no and no. 

I also want to comment on the evaporative canister venting issue.
This is a red herring. This 40-year-old design is an antiquated and
primitive device found on every car. Much better designs exist.
Instead of making the car companies modernize this device Staff has
pushed it onto PHEV converters. Their twisted logic goes like this.
If a hybrid is modified into a plug-in, the car could drive around
for days, doing short trips, without using the gas engine. After 3
days of no gas engine operation the evap canister will vent
releasing a few grams of benzene. The PHEV conversion caused this
and that is an emissions increase compared to an unmodified hybrid
and not allowed. If millions of hybrids are converted to PHEVs we
will have a major problem. To solve this imagined problem they want
us to start the gas engine every time the car is used to prevent
evap canister venting. We must release a few pounds of CO2 every
time the car is used to prevent releasing a few grams of benzene
every 3 days. Every gas car that sits for 3 days vents. Following
Staff logic all cars should be started every 3 days to prevent evap
canister venting. Car salesmen should start every car on their lots
every 3 days. If I ride my bike to work the canister vents. If I
ride the bus the canister vents. If I walk to work the canister
vents. All this is encouraged but if a PHEV causes venting by
keeping a gas engine off, it’s a crime. I hope you see the lunacy
in this.

My final comment is on the cost of testing PHEV conversions. Staff
released a document: APPENDIX K TECHNICAL SUPPORT DOCUMENT FOR
ECONOMIC IMPACTS RELATED TO THE PROPOSED EXHAUST AND EVAPORATIVE
TEST PROCEDURE AMENDMENTS.  This document clearly state that these
regulations will increase the cost of testing a PHEV modified car
by 50%. And to add insult to injure, the more pure electric range
the PHEV car has the more it will cost to test.  I am not making
this up. 

I ask the Board to tell Staff that all vehicle electrification
products including PHEVs should be tested and approved for free and
the cost of gas vehicle testing increased by 50%. 

Thank you for listening to my comments today.

Robb Protheroe