First Name | Russell |
---|---|
Last Name | Sydney |
Email Address | main@sustainableclub.org |
Affiliation | Sustainable Transport Club |
Subject | Ten Year Warranty on Batteries |
Comment | Dear Air Resources Board Members: This is to spell out the concerns behind the ten-year battery warranty included in your ZEV regulations. In working with the manufacturers of electric vehicles it is clear to me that producing batteries and providing warranties is done by battery companies not by the manufacturers of the vehicles. These battery companies are either new companies working on new technology or they are old companies working on updating and optimizing old technologies. The old companies are working with technology that they normally can provide twelve-month full warranty replacement on those batteries. I have actually found one that gives a three-year replacement warranty and had trouble getting that honored because the battery supply was being limited to military uses in Iraq. The new companies are just now getting the technology in place to provide batteries for initial testing. The only new technologies that have been fully field-tested are the nickel metal hydrid batteries in the Toyota RAV 4. These are fading after six of seven years. The Lithium Ion batteries show great promise in the lab and in early testing but none has been field tested on a long-term basis. In point of fact very few short-term field tests have been completed successfully. There is a lot of new technology involved with lithium ion batteries that are in very early stages of development. This includes both the chemistry and construction of the batteries as well as the technology for the battery management systems and for the chargers. Buying batteries alone does not work. They have to have all three parts to be an effective source of power for and electric vehicle. Requiring that new vehicle manufacturers put their companies future on the line behind this new and experimental technology is unreasonable. The requirement means that the manufacturers are at the mercy of the companies that produce the batteries, the battery management systems and the chargers. Any of these companies could have technical flaws or management problems that means they go out of business. The battery management systems or the chargers may have problems that destroy the batteries and these may or may not be provided by the battery or the vehicle manufacturer. The vehicle manufacturers competition may buy out the battery producer. The battery producer could refuse to warranty the batteries that are not managed by their own technology. All of this puts the burden on the vehicle manufacturer in an unreasonable way as they could be left holding the bag for the warranty on a product produced by another company. Keeping the ten-year specification would require the manufacturer to increase prices substantially to cover this burdensome requirement. That in turn will reduce the demand for the vehicle and delay getting the ZEV solutions on the road. The consumers can and will take on some of the burden for replacing batteries. Experienced electric vehicle owners recognize that batteries are a consumable supply and plan on replacing them. This is the maintenance that is required on an EV. It is required much less frequently than an oil change or a tune up. The expense for changing the pack is higher than that of an oil change – a recent estimate of $1800 was given for a full speed EV including labor. That is still reasonable when you consider the energy savings and the savings on oil and brakes etc. that a good EV provides. It may be appropriate to require a disclosure notice of the estimated maintenance cost to new consumers over the ten-year period so that they know what to expect. If you want to push the technology then start by exceeding the industry standard of one year and require the current industry extreme high end of a four-year warranty. As the technology becomes proven and is developed in that time period then increase the requirement. Asking a new and developing industry to start out by giving a warranty that is more than five times the current average is just asking too much. This information is based on four years of using electric vehicles, forty years of being a business manager as well as having experience as a professional mechanic and in managing small commercial vehicle fleets. It is also based on being part of network of people and manufacturers interested in alternative vehicles. The ten-year requirement is going to delay the start of this market more than encourage it. If you want ZEVs on the road then let us know by adjusting this part of the regulations. Appreciatively Yours Russell Sydney Principle Organizer for The Sustainable Transport Club. www.sustainableclub.org |
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Date and Time Comment Was Submitted | 2008-03-25 10:13:30 |
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