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Requiring low volume plug-in hybrid conversions to under go
expensive certifications is obscene and against the public
interest.

The companies performing these conversions are leading the way
forward. The benefit of them is that they are helping to change
public opinion about plug-in electric vehicles, and are spurring
major manufacturers to follow their example.

Low volume conversions is already very expensive, much of the aim
is to get major manufacturers to follow suit with high volume OEM
plug-in hybrid electric vehicles. Only then does the economics
really make sense. Requiring volume OEM testing is normal, and
sensible.

If required to make major capital expenses for testing this will
inhibit development. Each new conversion would require new testing,
thus limiting innovation. Companies would either have to pass on
the cost to customers, thus further deterring potential customers,
or smaller companies may have to cease doing business.

The aim of these companies is to act as a spear head, not to
produce high volumes. Additional costly testing will only blunt the
spear head.

Would CEPA require me to have my vehicle (re)tested if I simply
installed a bigger battery in it? What about if installed a bigger
electric motor?

A compromise might be after 10,000 units sold per manufacturer
testing might be required. Another compromise if CEPA thinks
testing is so necessary is for CEPA to pay for testing, and then
charge $20 per unit sold, or to limit the cost of testing to no
more than the cost of one conversion (about $10K). If not enough
units are sold, then CEPA takes the loss.

Would CEPA take into account the lower and even emissions when
driving electric only? Does CEPA have evidence that harm is being
done, and that a remedy is required? If not how about CEPA pays for
evidence to be gathered before writing new rules?

Also intuitively, a plug-in conversion is going to reduce
emissions.