Comment Log Display

          PHEVIA's Comments to the California ARB

Dear Board members and Staff,

The Plug-In Hybrid Industry Association would like to submit for
your consideration the following comments on the proposed
regulations for aftermarket conversions of plug-in hybrid electric
vehicles, PHEVs (OVCC HEVs).

The Plug-In Hybrid Industry Association (PHEVIA) is an association
of aftermarket PHEV conversion manufacturers and non-profit
advocacy groups. It was formed at the beginning of the year to give
voice to the many small but innovative manufacturers who have
pushed the PHEV conversion industry into existence.


We appreciate the Board's January decision to have these
regulations revisited and we also appreciate Staff's attempt to
provide a more financially viable path to compliance. However, the
currently proposed regulations will financially bar the majority of
conversion manufacturers from selling in California for the same
reasons as the original regulations.  Therefore, we are offering
the following alternatives to make certification financially
possible for conversion manufacturers:

-Keep regulations as is, but have them not come into effect for a
period of 2 years or industry-wide sales of 14,000 units (5% of
HEVs currently on the road)

    This will give successful manufacturers the time needed to
raise funds to pay for certification while keeping the number of
conversions to a non-significant level for California's air
quality.

    We realize there are concerns with this approach, for setting
precedent in aftermarket regulations, and for having sub-par PHEV
conversions taint the public's perception of PHEVs.  We therefore
offer this second alternative:

Keep regulations very similar to those proposed, and provide
incentive for PHEV conversions by funding all successful emissions
testing. 

    This will allow successful manufacturers to demonstrate the
quality and cleanliness of their products while enforcing strict
regulations on all conversions.  It will also put California on
track for the AB32 requirements of 15% greenhouse gas emission
reductions by 2020 and put California at the forefront of President
Obama's goal of having 1 million PHEVs on the road by 2015.

    For this approach the durability to vehicle's useful life, and
battery durability test requirements, would have to be delayed from
100 units to 500 units or 3 years as this data would take at least
this long to accumulate.  Additionally testing access and
certification processing would have to be expedited, or an
in-process exemption would have to be granted, as current
certification times of 6 months to 1 year per tier would be too
long for smaller manufacturers to not be doing business.


Please consider the following environmental and economical effects
of passing the proposed regulations unmodified:

-Most conversion manufacturers would not be able to sell their
products in California, giving many a high-chance of going out of
business entirely. Includes but is not limited to, 7 PHEVIA member
manufacturers

-California dealers and installers of these manufacturers would go
out of business. Includes but not limited to 12 current member
businesses and hundreds of potential businesses.

-California distributors and contractors would loose a significant
amount of business immediately and loose the potential for an
enormous amount of business with future increased demand for
conversions. Includes but not limited to roughly 50 businesses per
member manufacturer.

-Loss of environmental benefits (emissions reductions,
electrification infrastructure improvements, etc.) from conversion
systems that would have been done in California. Includes but not
limited to projected average 300 units per member manufacturer per
year.

-Less pressure on vehicle manufacturers to produce PHEVs
themselves leading to slower mass-production.


While PHEVIA believes that the above-mentioned alternatives are
the most important changes the Board can make, and would give
conversion manufacturers access to certification, we would also
like you to consider the following issues we see with the currently
proposed regulations.

Warranty: conversion systems failing, or conversion systems
battery degrading results in stock vehicle operation and therefore
stock vehicle emissions.  While a 5-10+ year warranty on conversion
systems is something to strive for, and in the future may be
appropriate to mandate, it is not currently necessary and would
result in higher-cost conversion systems and less innovative
designs.  Both leading to less PHEVs on the road and the negative
effects of this.  We instead suggest the ARB mandate a warranty
that the conversion system will not adversely affect vehicle
emissions. Let performance and consumer protection warranties be
dictated by the private sector.

Evaporative emissions: the problem of evaporative canister purging
is one found unaddressed in all vehicles, be they conventional gas
vehicles, HEVs, or PHEVs.  While a PHEV may operate its gas engine
less, burning less fossil fuels and producing less exhaust
emissions, this does not make it responsible for the sub-ideal
design found in the stock vehicle. The PHEV is not any more
polluting then the car left in the garage on bike-to-work-week.

Emissions testing procedures: current emissions testing procedures
are outdated, based on driving patterns observed in the 70's before
HEVs and PHEVs existed. These procedures no longer accurately
reflect PHEV owners' driving which leads to PHEVs and HEVs that
have been optimized for passing tests instead of performing
efficiently and cleanly.


Thank you for your consideration.


Sincerely,

Chuck Protheroe
Representative
Plug-In Hybrid Industry Association