Comment Log Display

Comments to the California Air Resources Board
by Ronald Gremban, CalCars Technical Lead, 5/27/2009

The attached file is a formatted version of these comments.

1.	These are comments to the “Supplemental Staff Report for the
Proposed Rulemaking for Plug-In Hybrid Electric Vehicle Test
Procedure Amendments and Aftermarket Parts Certification
Requirements”
2.	Why are PHEV conversions important to California?
2.1.	Automotive emissions vs. AB32
2.1.1.	Automotive emissions make up around 40% of California’s GHG
emissions
2.1.2.	If automotive emissions decrease by only a small amount by
2020 (see below), all other segments will need to decrease by over
45% by then to make up for the shortfall toward the required
overall 30% reduction from business-as-usual
2.2.	Plug-in hybrids (PHEVs) are the only low carbon automotive
option available in the short term, requiring no huge new
infrastructure, and capable of renewable energy as the eventual
energy source
2.2.1.	PHEVs
2.2.1.1.	The electric grid has excess nighttime capacity
2.2.1.2.	Increasing renewable portfolio standards are already in
progress
2.2.1.3.	PHEV energy storage can eventually help even out
renewable energy supply intermittency to enable higher proportions
or renewables
2.2.1.4.	Only ordinary outlets (120VAC, 15A) are required for
overnight charging
2.2.1.5.	Homes with garages usually already have outlets, and
2.2.1.6.	Ordinary outlets can be added to apartment complex
garages and carports by ordinary electricians and with minor if any
local grid upgrades
2.2.2.	Biofuels
2.2.2.1.	Huge cellulosic or algae refineries, not yet proven at
commercial scale, and transport infrastructure for feedstocks and
resulting fuels, are needed to make enough biofuels to make a
difference
2.2.2.2.	As with PHEVs, most new vehicles will need to be forced
to be capable of using the fuel(s) much sooner than anticipated,
and existing vehicles will need to be converted en masse
2.2.3.	Hydrogen:  all infrastructures must be built from scratch
2.2.4.	CNG
2.2.4.1.	As with PHEVs and biofuels, vehicles will need to be
converted en masse
2.2.4.2.	Vehicle range is decreased
2.2.4.3.	Although natural gas is nearly as ubiquitous as
electricity, fueling stations with high pressure pumps and storage
will need to be built
2.2.4.4.	The 30% improvement in GHG is a dead end, as unlike
electricity, it cannot eventually come from renewable sources as
easily and efficiently as electricity
2.3.	Best-case and likely worst-case new PHEV production
2.3.1.	If 100k PHEVs are built in 2011 and production increases by
50% each year, 21% of new vehicles, and 3% of the nationwide fleet,
will be PHEVs by 2020, reducing overall CO2 emissions by about 1%
2.3.1.1.	If ¼ of these are in California, PHEVs might command 84%
of the new car market by 2020 and 12% of the fleet, still reducing
CO2 emissions by less than 4%.
2.3.2.	If PHEV new-car penetration occurs at the same rate as for
hybrids, only 2.2% of new vehicles, and 0.3% of the nationwide
fleet, will be PHEVs by 2020, reducing CO2 by only 0.1%!
2.3.2.1.	If ¼ of these are in California, PHEVs might command 8.8%
of the new car market by 2020 and 1.2% of the fleet, still reducing
CO2 emissions by less than 0.4%.
2.4.	The importance of HEV-to-PHEV conversions, despite few
hybrids
2.4.1.	There are only XXX hybrids in California after a decade of
sales.  At this rate, there will be YYY by 2020.  Converting these
will reduce overall fleet GHG emissions by only ???%.  However,
HEV-to-PHEV conversions have (and can continue to):
2.4.1.1.	Brought public attention to PHEVs
2.4.1.2.	Provided the first actual experience of PHEVs operating
in customers’ hands:  customers’ responses, actual drive patterns,
and how the vehicles perform
2.4.2.	Handling the PHEV battery reliability and endurance
‘chicken and egg problem’
2.4.2.1.	Battery reliability and endurance testing takes years for
each specific design
2.4.2.1.1.	Accelerated bench testing is expensive, time consuming,
and is too limited to be certain to apply to actual vehicle use
2.4.2.1.2.	On-road experience requires many vehicles on roads for
many years
2.4.2.2.	No manufactured PHEVs and only a few conversions have
been in consumer hands so far
2.4.2.3.	Conversions (both from HEVs and ICEs) are an
exceptionally good platform for gaining in-field battery
experience, as
2.4.2.3.1.	Many can be put in the field far faster than via new
PHEVs
2.4.2.3.2.	Each vehicle can be returned to OEM non-PHEV status if
the battery fails, minimizing the impact.  This can even be
arranged to happen automatically.
2.4.2.3.3.	Small conversion manufacturers can try a far wider
variety of battery chemistries, manufacturers, and products than
could possibly be brought into automotive production
2.4.2.3.3.1.	Some will fail, but in doing so will leave knowledge
in their wake
2.4.2.3.3.2.	Others will succeed that otherwise might never have
had the financial backing to make it to market via the auto
manufacturers
2.4.3.	Getting a significant number of designs on the road in the
next few years, so that
2.4.3.1.	The automotive and conversion industries discover what
works in real customer hands, and use that knowledge to ramp up
ASAP to millions of new PHEVs and ICE conversions soon enough to
significantly impact 2020 GHG emissions.
2.4.3.1.1.	GM was inspired to design the Volt via both PHEV
conversions and Tesla Motors, then to commit to building it only
after huge public response – enabled by the media response to
conversions – to the Volt prototype
2.4.3.1.2.	GM has solicited information from drivers of
conversions to help tune the Volt’s design.
2.4.3.2.	Conversion customers and the people they talk to will
help pressure the auto manufacturers to begin building, then
quickly build more and more PHEVs of all shapes and kinds
2.5.	ICE conversions are needed to meet AB32’s 2020 goals
2.5.1.	ICE conversions can target the least fuel-efficient
vehicles
2.5.1.1.	They are most cost-effective as well as most effective
for larger, less fuel-efficient vehicles:  SUVs, pickup trucks, and
vans on up through many heavy-duty trucks and buses
2.5.2.	ICE conversions can be rapidly scaled up
2.5.2.1.	Though starting more modestly, a ramp-up rate much faster
than that of new PHEV manufacture is possible, as
2.5.2.1.1.	Other than the battery, only a few components need to
be fabricated
2.5.2.1.2.	The relatively time-consuming installation process can
be farmed out to service shops throughout the state (and nation)
2.5.2.2.	Battery availability is the limiting factor, but, unlike
auto manufacturing, which depends on high volume designs,
multi-year design and pre-production processes, and heavily
capitalized suppliers, ICE conversions can
2.5.2.2.1.	Use batteries of multiple chemistries and from smaller
manufacturers
2.5.2.2.2.	Be a venue for companies with innovative batteries to
get field experience despite being too small or new to be an
automotive OEM supplier
2.5.2.2.3.	Cause the battery industry to scale up faster and
sooner
2.6.	Though these rules are for HEV-to-PHEV conversions, we are
concerned about the implications for the ICE-to-PHEV rules that
will also be needed
2.6.1.	Poulsen Hybrid, LLC, has already been attempting to get
their ICE-to-PHEV conversion certified, so far without success 
3.	What is the nature of the industry and its innovation?
3.1.	The first are – and must be – small, experimental, and
self-funded
3.1.1.	Venture capital is not yet available
3.1.1.1.	The market is as yet unproven
3.1.1.2.	There is little experience of battery longevity in the
field until many PHEVs have been driven for many years
3.1.1.2.1.	This is a chicken vs. egg problem that a small-scale,
innovative conversion industry can help break through by getting
many possi
3.1.2.	Start-up funds from home refinancing or small business
loans – both especially difficult now
3.1.2.1.	Total funds excluding receipts from early sales are
typically within a factor of 2 or 3 of $100k
3.1.2.2.	As well as supporting development and testing, these
funds must also support the founders until sales can do so
3.1.2.3.	Therefore, compliance costs must be funded as a
percentage of sales receipts up to when the compliance is required
3.1.2.3.1.	Figures higher than 25% of pre-compliance sales
receipts will drive many entrepreneurial converters out of
business
3.1.3.	Speed
3.1.3.1.	Most pre-sale engineering must be on paper, then one
prototype
3.1.3.1.1.	Cannot afford even to buy vehicles beyond those used
for the founders’ own transportation
3.1.3.1.2.	Neither time nor money for extensive, instrumented
experiments
3.1.3.1.2.1.	To verify field usage except in customer vehicles
3.1.3.1.2.2.	To check operation in temperature and other extremes
3.1.3.1.3.	Further engineering must be done by tracking and acting
on feedback from the field
3.1.3.1.3.1.	Customer feedback
3.1.3.1.3.2.	Data from instrumented vehicles in customer hands
(more below)
3.1.3.1.4.	Much development is by field-inspired improvements,
often inspiring retrofits to the rest of the converted fleet
3.2.	As the industry matures, funding will become available and
competitively necessary
3.2.1.	For production engineering, bulk supply purchases,
production processes, dealer/installer network development,
marketing, etc.
3.2.2.	A123’s purchase of Hymotion, started on a shoestring,
illustrates one developing avenue
3.2.3.	Once a market and industry are established, venture capital
will also be possible
4.	Possibly-unacknowledged existing SULEV/PZEV high-emissions
scenarios
4.1.	Engine start-up under load due to untested but possibly
common driving regime
4.1.1.	Unconverted:  Warm-up under load occurs if accelerating
(e.g. uphill) immediately after vehicle activation (start-up)
4.1.2.	Conversions
4.1.2.1.	This is the only known non-evaporative mechanism of
emissions increase in conversions.
4.1.2.2.	There are various well-known ways of controlling this at
least as well as in the unconverted vehicles.
4.2.	Evaporative emissions due to lack of use
4.2.1.	Due to airport parking, mass transit or bicycle use,
carpooling, etc, beyond 3 days
4.2.2.	Why count pure EV trips in conversions differently?
4.2.2.1.	If pure EV trips are counted as “vehicle unused”
occasions, then conversions need only make sure to purge the OEM
canister during non-EV trips
4.2.2.2.	Otherwise, in order to purge the OEM canister, the engine
must be used for long enough on every trip, thereby always causing
gasoline use and emissions.
5.	Tier quantities
5.1.	The proposed quantities are a problem for early, necessarily
self-funded conversion companies, as design and testing must be
largely funded through sales
5.1.1.	Compliance engineering and testing costs should be measured
as a percentage of pre-requirement sales income
5.2.	Our major new proposal will show how higher numbers will not
risk higher emissions
5.3.	However, we propose a new requirement for instrumentation of
some converted vehicles and public release of anonymzed collected
data 
5.3.1.	A major value of accommodating conversions is that of
learning about driver behavior, battery requirements, and component
reliability under real road conditions
5.3.2.	Systems to collect, record, and transmit CAN bus
information to a central server are commercially available at
reasonable prices for use on a representative sample of vehicles 
5.3.2.1.	This data can be invaluable to
5.3.2.1.1.	CARB
5.3.2.1.2.	Both auto and conversion manufacturers, and
5.3.2.1.3.	All researchers working to project the value of
transportation electrification toward petroleum displacement and
GHG emissions reductions
5.3.2.1.3.1.	Projections can be refined with real data where only
unvalidated assumptions have been available up to now
5.3.3.	We propose that one Tier 1 vehicle, 5% of all Tier 2
vehicles, and 1% of Tier 3 vehicles be required to be so outfitted,
with anonymzed data made available monthly or quarterly to CARB,
which will immediately publish it its website
5.4.	Please verify CARB staff’s indication that the 5000 vehicle
total limit is for Tier 1 and 2 only
5.4.1.	On page 5 it says, "After 5,000 vehicles are converted
industry-wide, Tier 1 and Tier 2 options are no longer available. 
This limits and controls the overall potential emissions and
economic impacts for the tiers as will be discussed in the next
section."
5.4.2.	At the recent session with CARB staff, we were led to
believe that this 5000 is a limit of all vehicles in tiers 1 and 2
-- which would allow for up to 50 manufacturers -- not a total of
all conversions.  Since Tier 3 conversions will have been tested as
per the previous non-tiered proposal, they do not have the
perceived (see our new proposal, below) potential of impacting
emissions that Tier 1 and 2 vehicles might have.  On the other
hand, if Tier 3 conversions are counted, one or two manufacturers
could easily install more than 5000 (mostly Tier 3) conversions
before other potential manufacturers get the chance to take
advantage of the Tiered system at all.  Therefore, we request that
the 5000 limit be clarified in the rules to apply only to Tier 1
and Tier 2 conversions.
6.	Warranty issues
6.1.	Does the proposed conversion warranty extend OEM vehicle
warranty in some cases?
6.1.1.	Though recent revisions have reduced the cases where this
may occur, the conversion warranty is required to extend beyond the
OEM warranty on the vehicle when a conversion is applied on a
vehicle with a shorter remaining or run-out OEM warranty.  Though
this may be clarified elsewhere, it is not clear from the
conversion standards documents whether in this case the conversion
warranty applies just to the conversion and any OEM parts that it
may harm, or if it applies to the whole powertrain as necessary to
keep it in compliance with emission requirements.
6.1.1.1.	We see the former as an appropriate requirement and no
problem.
6.1.1.2.	However, if, as part of the required conversion warranty,
the conversion manufacturer must also warranty the OEM powertrain
beyond its OEM warranty, this could pose a serious hardships, as
the converter would thereby become responsible for possibly
expensive and near-worn-out OEM parts (such as engine,
transmission, and catalytic converter components) beyond their
design life.  If this is indeed required, it would be economically
unfeasible for conversion manufacturers to allow the conversion of
vehicles without sufficient remaining OEM warranty to match the
required conversion warranty.
6.2.	PHEV battery warranty
6.2.1.	As of yet, PHEV battery longevity in actual vehicles is
somewhat of an unknown, as few if any such vehicles have been
operating for even 3 years or 50,000 miles.  Additionally, some
inexpensive batteries have expected lifetimes nowhere near the 5
year / 75,000 mile requirement, let alone the possible 10 year /
150,000 miles required of a brand new PZEV vehicle conversion.  For
example, lead-acid batteries, with an expected lifetime of 2-3
years but a low enough cost to allow for multiple replacements
during the vehicle's lifetime, are often employed because of low
up-front costs, an initial savings that would be removed by having
to prepay for the expected replacements via an extended performance
(as opposed to emissions-only) conversion warranty requirement.
6.2.2.	We suggest that the required conversion warranty cover only
whatever battery capacity or capability is required, given the
conversion’s electronics, to maintain required emissions levels
(some conversions may be able to accomplish this with a completely
dead conversion battery), not what may be necessary for any
particular level of plug-in performance.
6.2.3.	For consumer protection, require only that the vehicle work
as well as before conversion during the warranty period, and that
the conversion manufacturer state its additional battery warranty. 
 Competition will no doubt independently lead conversion
manufactures to offer additional battery performance warranties
consistent with the capabilities, costs, and developing track
records of the batteries used in their conversions.
7.	Durability testing
7.1.	Though other components may be hard to ‘prove’, the batteries
are the main issue
7.2.	It is completely unfeasible for small conversion
manufacturers to life-test the batteries that go into its
conversions, as batteries are especially difficult to test for
durability.
7.2.1.	Battery manufacturers' test data is seldom directly
applicable to PHEVs, is usually on a cell (vs. pack) basis, and is
often unavailable to small conversion manufacturers anyway.
7.2.2.	Accelerated cycle testing of packs requires large and
expensive automated test equipment, is difficult to match to
expected road use and conditions, the timeline can often be
accelerated by a factor of only 4 or 5, and the effects are
nonlinear and cannot necessarily be extrapolated from early
results.
7.2.2.1.	The Electric Power Research Institute (EPRI) has had a
major accelerated PHEV-cycle battery testing project going on for
years that has so far managed to test only one NiMH and one
now-obsolete Li-ion pack to around 3/4 of its lifetime.
7.2.3.	Vehicle lifetime testing therefore takes years per possible
battery pack, each of which is obsolete by the end of the test and
may or may not end up acceptable anyway.
7.3.	It is totally unfeasible for largely-sales-financed small
conversion manufacturer to be able to show vehicle-life durability
beyond a few thousand miles prior to selling 100 conversions and
requiring Tier 3 certification to continue, as -- unless a special
deal can be reached with a taxi company -- to do so would require
both paying drivers to put miles on a converted vehicle nearly 24-7
and prematurely wearing out the multi-thousand-dollar vehicle
itself.
8.	CalCars’ major new proposal to minimize testing costs to
validate low conversion emissions
8.1.	There are only two known sources of added emissions in
HEV-to-PHEV conversions
8.2.	There are simple solutions to each of these problems that
have already been demonstrated to work (though at the cost of less
gasoline displacement), and innovative new solutions can be
validated as necessary
8.2.1.	Engine warm-up under load
8.2.1.1.	Do not disable engine start-up and warm-up upon initial
vehicle activation.  Then, force periodic restart of the engine to
ensure maintenance of the catalytic converter’s (CAT’s)
temperature.
8.2.1.1.1.	Periodic restarts can be timed for pauses no longer
than the maximum encountered in unconverted vehicles, or
8.2.1.1.2.	The CAT temperature can be measured, and a restart
initiated before its temperature falls below a specified ignition
temperature
8.2.1.2.	To run the vehicle as a pure electric, with no engine
start, engine start must be inhibited until a no-load warm-up
period is ensured, or until the vehicle is deactivated and
reactivated in a mode where the engine is immediately started and
warmed-up.
8.2.2.	Reduced purging of evaporative canister
8.2.2.1.	Do not disable engine start-up and warm-up upon initial
vehicle activation
8.2.2.2.	Once every day (or every X days, as decided by CARB),
force engine operation for long enough to purge the canister
8.3.	The validation that a conversion reliably uses a
known-to-work solution for each of the two areas of concern is much
easier and just as effective as full emissions testing
8.4.	Once ICE-to-PHEV conversions are shown to have a similar
small set of areas of concern, they, too, should be subject to
similar abbreviated certification requirements
8.5.	Our proposal
8.5.1.	To be certified Tier 1, a conversion must be shown on paper
to reliably incorporate a known solution to each of the two areas
of concern, or to incorporate another method that is logically
proven to CARB staff to also solve the problem.
8.5.2.	As above, we propose a new requirement for instrumentation
of some converted vehicles and public release of anonymzed
collected data 
8.5.2.1.	A major value of accommodating conversions is that of
learning about driver behavior, battery requirements, and component
reliability under real road conditions
8.5.2.2.	Systems to collect, record, and transmit CAN bus
information to a central server are commercially available at
reasonable prices for use on a representative sample of vehicles 
8.5.2.2.1.	This data can be invaluable to
8.5.2.2.1.1.	CARB
8.5.2.2.1.2.	Both auto and conversion manufacturers, and
8.5.2.2.1.3.	All researchers working to project the value of
transportation electrification toward petroleum displacement and
GHG emissions reductions
8.5.2.2.1.3.1.	Projections can be refined with real data where
only unvalidated assumptions have been available up to now
8.5.2.3.	We propose that one Tier 1 vehicle, 5% of all Tier 2
vehicles, and 1% of Tier 3 vehicles be required to be so outfitted,
with anonymzed data made available monthly or quarterly to CARB,
which will immediately publish it its website
8.5.3.	To be certified Tier 2, the operation of these solutions
must be demonstrated to CARB staff, either by direct demonstration
or by results from an instrumented Tier 1 conversion
8.5.4.	Tier 3 certification will require ongoing verification of
the solutions on instrumented Tier 2 and Tier 3 vehicles
8.5.5.	We believe this proposed alternative to CARB staff
proposals greatly reduces the potential for emissions from
conversions while simultaneously greatly reducing the costs to
conversion manufacturers.  An additional advantage is the
availability of valuable operational data for use by many parties.

Thank you.