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The intent of CARB and the independent developers of PHEV systems
are the same, to improve gas mileage and reduce emissions. With
each conversion to PHEV there is an improvement toward the stated
goal. Your actions are very important and can move the vehicle
fleet toward that goal OR you can kill the PHEV Conversion
alternative. We don't want a repeat of the California Air Resources
Board killing the ZEV for the hydrogen fuel-cell. That fact is your
legacy, you need to do much better this time. 

I suggest:  

1. Register a PHEV developer as a "PHEV Conversion Program" until
volumes become significant, the first 1,000 conversions. Safety and
original emissions control function should be the only
requirements. 

2. When the volumes get to 10,000 units you can start to implement
your proposed plans for function. 

3. CARB should require original vehicle manufacturers to maintain
responsible for warranty issues that are not caused by the
conversion to PHEV. 

  

The major automakers have been too slow to respond to our need to
clean the air (and to get off oil). They have shown we need
innovation and options from an independent source. It is clear that
there are only EVs and PHEVs in development at the auto companies
today because of independent developers like Tesla showing it can
be done. A successful PHEV conversion business would show it can be
done. 

Your decision is more important than you might think. If in 2003
the ZEV decision had been to maintain an annual 500 EV
demonstration fleet, there is a good chance a transportation
alternative would have prevented oil from going above $60/bl.  

Due to bureaucratic reasons tying up votes in the House and
Senate, Congress has failed to move us forward.  CARB should not
wait for them to act, it is your responsibility to act as
independent agents and move us in the correct direction.