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Response to CA Air Resources Board's Proposed PHEV/Conversion Regulations

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  • Felix Kramer
    This formal reply to proposed regulations by the California Air Resources Board was written by CalCars Technical Lead Ron Gremban following discussions with
    Message 1 of 1 , Aug 1, 2008
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      This formal reply to proposed regulations by the California Air
      Resources Board was written by CalCars Technical Lead Ron Gremban
      following discussions with the individuals and companies involved in the
      Open Source EAA-PHEV (Electric Auto Association - Plug in Hybrid
      Electric Vehicle) project, some of whom have also submitted testimony.
      It's a good overview of the business and technical issues surrounding
      regulation of aftermarket conversions.

      Here's how we summarize the message: "Let's be very careful of
      unintended consequences of too-early and too-specific restrictions,
      which could inhibit invention. Right now the auto industry is benefiting
      from new ideas that could help them make money producing clean cars. And
      conversions have already stimulated discussion about public and private
      incentives for these "green-tuned" vehicles and for the even better
      mass-produced versions that will follow them. Let's take this step by
      step and not shut down the small innovators."

      Find the EAA-PHEV group at http://www.eaa-phev.org
      <http://www.eaa-phev.org/> and the specific sections on Prius
      conversion at http://www.priusplus.org <http://www.priusplus.org/> .
      The message archive can best be seen at

      <../../../../eaa-phev/> July 31, 2008 from Ron Gremban:
      Dear CARB members. I'm writing this in response to the emboldened draft
      regulations below:

      At http://www.arb.ca.gov/msprog/zevprog/hevtest/hevtest.htm
      <http://www.arb.ca.gov/msprog/zevprog/hevtest/hevtest.htm> :

      The ARB is modifying the existing exhaust & evaporative test procedures
      for Light Duty & Medium Duty Hybrid Electric Vehicles (HEVs) to better
      characterize emissions from all types and architectures of Hybrid
      Electric Vehicles including Plug-In hybrids. Information regarding this
      process and the proposed modifications are shown below. To receive
      information on postings to this website please sign-up on the ZEV list

      July 16, 2008
      * Meeting Agenda
      (conference call information provided)
      * Staff Presentation
      * Draft Test Procedures
      * Draft - California Evaporative Emission Standards and Test
      Procedures for 2001 and Subsequent Model Year Vehicles
      * Draft - California Refueling Emission Standards and Test Procedures
      for 2001 and Subsequent Model Year Vehicles
      * Draft California Exhaust Emission Standards and Test Procedures for
      2011 and Subsequent Model Years ZEVs and HEVs
      * Draft EV Charging Requirements
      * Draft Aftermarket Parts Certification Requirements

      * Meeting Notice
      I commend these efforts to tackle the necessary regulation of a complex
      and potentially extensive and valuable area of our transportation

      Like Andy Grove, who just proposed the conversion of 10 million trucks,
      SUVs, and vans into PHEVs nationwide within the next four years, I
      strongly believe that our automobile manufacturers not only will not,
      but cannot even begin to, build enough PHEV vehicles in the next decade
      to create -- by replacing existing and yet-to-be-sold low-mileage
      vehicles -- the level of oil consumption and greenhouse gas emissions
      reductions that our economy, environment, and California state law
      requires. Even iif auto manufacturers were to move exceedingly fast,
      e.g. by converting a full 1% of their new vehicle production to PHEV in
      2011 (the expected first full year of any PHEV production -- it took 10
      years to reach this point with hybrids), then to double that production
      quantity each year thereafter, it would take 10 years to reach 90%
      production penetration, 16% on-the-road penetration, and a likely 8%
      (that year only, not cumulative) greenhouse emissions reductions.

      This means that large numbers of existing vehicles, and not just the
      small percentage that are hybrids, will need to be partially electrified
      to come close to meeting the IPCC's and California's greenhouse
      emissions and oil displacement goals. Of course California will need to
      be careful to avoid, in the process, moving backwards in criteria
      emissions and vehicle safety. However, I submit that although the auto
      manufacturers have generally higher technology capabilities at their
      disposal than entrepreneurs, they tend to move toward implementation of
      new propulsion technology in production -- especially technology that
      they don't yet see as an economic windfall -- at a glacial pace,
      sometimes even when their very existence is threatened by avoiding doing
      so (as from today's fuel prices).

      Because of this, hybrid-to-PHEV and the upcoming ICE-to-PHEV conversion
      technologies have so far been created and brought to market by
      non-profit and entrepreneurial companies and loosely organized groups of
      engineers on shoestring budgets. I believe that, if we are to have a
      significant electrification of the vehicle fleet within a decade, this
      must be allowed to continue and even be incentivized. While
      conversions, when sold in significant quantities, will need to prove in
      some way that they do not increase criteria emissions, I believe, in
      order to avoid a high cost of entry that would prevent small,
      innovative, shoestring-budget operations from starting out, there is
      high value in tolerating the creation and even sale of smaller
      quantities of conversions with lower-level oversight. Such small
      operations can innovate new conversion solutions, sell a few once they
      work, then use the proceeds and the field experience to test against and
      meet progressively carefully monitored regulations as a part of both
      improving the product and increasing sales. At some point some products
      and organizations will reach the point where they get noticed and funded
      for high-cost production engineering, testing, and serious levels of
      production, as has Hymotion. At this point, the proposed certification
      requirements (subject to suggestions below) would be appropriate.

      Once again, I emphasize that regulation alone is insufficient to get
      auto manufacturers to do things that are in the public interest but that
      they don't want to do. This was established as true with the original
      ZEV mandate (I believe 10% of new vehicles by 2004 were going to be
      ZEV), and continues with the Pavley bill tied up in court after a
      federal denial as well as due to a suit by all the auto manufacturers,
      including even 'green' Toyota. In contrast, what CalCars has discovered
      does work is a combination of:
      * Laws and regulations, such as feebates, creating strong
      incentives/disincentives for desirable/undesirable end-user behavior
      * Very public demonstrations that show the viability and availability
      of the technology to the public, generate large amounts of media
      exposure, and educate the public to the technology's advantages, both to
      the individual and to society
      * Development and sales of conversion systems, first to early
      adopters, then to more mainstream customers, at an ever-increasing scale
      that the auto manufacturers cannot ignore, and that will provide much of
      the promised value of PHEVs far sooner than could possibly occur through
      increasing penetration of new PHEV vehicles alone.
      * Emissions and safety regulations that allow this conversion
      penetration to begin entrepreneurially while expanding in an
      increasingly controlled way.
      * Grants, including to small groups that have specific unique things
      to offer, to help stimulate the needed technical, financial, business,
      and marketing innovation
      I propose that aftermarket conversions be required to follow the
      following progression:
      1. Once such standards are created, conformity to a set of safety
      engineering standards to be established by a to-be-determined consortium
      of EV and aftermarket automotive experts, similar to the industry
      standards the very successfully safety-conscious FAA now requires of
      Light Sport Aircraft manufacturers.
      2. Before sales of more than 25 conversions, justify on paper in an
      application to CARB why the converter believes that the conversion will
      not raise emissions, given national laboratory tests of emissions levels
      of other conversions.
      3. Before sales of over 100 conversions, submit one converted vehicle
      to CARB (temporarily) for testing and (if further crash safety
      regulations beyond the federal regulations already in place for
      aftermarket vehicle additions and for batteries) show the results of a
      software-simulated crash test.
      4. Before sales of over 1000 conversions, the whole CARB procedure
      specified in the draft procedures (as updated with suggestions) must be
      1. Conversions of multiple makes and models should be considered a
      single conversion type when vehicle parameters do not vary significantly
      (e.g. Prius 2004-2008 models are essentially alike, and Escape and
      Mariner hybrids are also essentially the same vehicle).
      2. Testing for conversion longevity against warrantied lifetime is
      far too time-consuming (ultimately requiring many years) and beyond the
      capabilities of any organization without the deep pockets of top-tier
      auto manufacturers. Some shortcut(s) must be acceptable, such as
      demonstrating that battery deterioration either will not cause increased
      emissions or will be detected and force repair.
      3. Other than against emissions increase, it should be up to the
      conversion manufacturer as to how long to warrant the conversion and/or
      parts within it. This will allow the use, for example, of batteries
      that can make conversions more affordable though they may need
      replacement one or more times during the remaining life of the converted
      4. It is unrealistic and extreme to require that the addition of a
      conversion to a vehicle will reset its mileage for warranty purposes to
      5. Actual crash testing must be required only upon embarkation of
      volume sales.
      Draft Aftermarket Parts Certification Requirements

      The "Draft Aftermarket Parts Certification Requirements" document
      contains this potential showstopper for small business: to get approval
      to sell conversions in CA, a manufacturer must not only warranty a
      conversion for the expected lifetime of the converted vehicle (section
      7), as specified by other regulations -- 10 years or 150,000 miles, I
      believe, for an AT-PZEV like the Prius -- but the conversion must be
      tested and proven to not increase emissions for that full lifetime
      (section 5b, especially 5b.vii), either in a converted vehicle, or via
      approved laboratory aging (to the vehicle's lifetime, or can that be
      projected?), with test in a converted vehicle before and after the
      laboratory aging.

      Unless I misread this, it means that conversions will not be able to be
      approved for sale in CA until such testing is completed, which is an
      expensive and time-consuming process. Even accelerated aging, if deemed
      acceptable, would take years to reach the equivalent of 10 years or 150k
      miles! And what about battery packs that are known not to last that
      long, but that can provide significant fuel displacement while they do
      last? A possible out is to show that in conversions that do not replace
      the original battery, even a worn-out conversion will not increase the
      emissions beyond those of the unconverted vehicle -- but that out will
      not work for battery replacement conversions.

      Another issue included in that document is that up to 5 in-use converted
      vehicles of each conversion type must be made available to CARB (I
      believe yearly) for an unspecified length of time by each conversion
      manufacturer. Since small conversion manufacturers may themselves own
      only one or two vehicles, this could present a very difficult economic
      challenge, despite the fact that CARB would foot the cost of the testing
      unless the vehicles failed the tests. I would propose that this be
      changed to one vehicle plus one more for each 1000 conversions sold, up
      to a maximum of five total.

      Section 3 says that these requirements "shall apply to all OVCC
      (Off-Vehicle Charge Capable) conversion systems to be certified for
      installation on CA-certified HEVs." What about conversions of non-HEVs?

      Depending on how it is interpreted, section 3a could make it difficult
      to get approval for systems that replace the Battery ECU, that change
      messages between it and the rest of the hybrid system, or that rely on
      resetting the OEM system at various times (though the relevant data
      could be automatically read out and saved as needed). It depends on
      what is meant by "an analysis showing that these modifications will not
      adversely affect OBD performance."

      Section 3b says, "The driveability of a vehicle equipped with a
      conversion system shall not be degraded in such a way as to encourage
      consumer tampering." It may be CARB's interpretation as to whether or
      not an optional low-performance but zero emissions Forced EV mode would
      still be allowed.

      Altogether, it appears that these regulations would increase the cost of
      entry into this market to a point where only large corporations could
      participate, thereby totally locking out the very entrepreneurial
      startups that have been and are very likely to continue to be the best
      sources of innovation for technology that the auto manufacturers have
      been resisting. How about increasingly stringent regulations that
      become effective after set numbers of each manufacturer's conversions
      are sold in CA, and that reach the proposed level only after e.g. 5000?
      Otherwise, the $500k one might spend on meeting the full requirements
      would have to come from often nonexistent start-up capital, and would
      still amount to $500 per conversion after the sale of 1000 conversions
      -- both of which are far beyond the early capabilities of every
      conversion manufacturer I know of, including Hymotion before its
      purchase by A123 (A123 has now spent mid-six-figures on such testing),
      and that sale would not have happened if Hymotion hadn't already been
      selling viable conversions.

      Draft EV Charging Requirements

      There are two issues here, both having to do with eliminating the
      exception to more stringent requirements for vehicles that are capable
      only of "level 1" charging at up to 1.44 kW from an ordinary 15A, 120VAC

      Instead, the proposal is that all plug-in vehicles be required to
      conform to J1772 REV ?2009, including the use of a Yazaki plug (although
      the availability of an adapter to allow plugging into an ordinary outlet
      may also be required), and that they all be required to have charger
      capacity to provide a full charge in 4 hours (though battery chemistry
      is allowed to prolong the charging).

      First, requiring the Yazaki plug may not be a bad idea, as it will
      enable public charge stations with a standardized Yazaki jack to charge
      all EVs including PHEVs. But, for "level 1" charging, an ordinary 120V
      plug must be allowed as well, so that one need not rewire his home after
      buying a PHEV. Public charge stations are unlikely to be important for
      PHEVs, but could eventually lead to more charging, e.g. at on-street
      parking spots frequented by people without garages, and at hotels and
      other overnight locations.

      However, the requirement of 4 hour charging is a potential problem and a
      puzzle. The document says that "...7-8 hours ... time duration would
      extend beyond preferred late-evening low-cost Utility rate schedules",
      but PG&E's E-9 off-peak rate is from midnight to 7am, 7 hours, not 4.
      In fact, if all vehicles started at the start of off-peak rates, the
      load would be better spread out, at least until the advent of a
      full-blown smart grid, by a 7-hour charging rate rather than a 4-hour
      rate. Also, though CARB's document shows that a PHEV-25 could charge
      from a 120V 15A circuit in 4 hours, that applies only to a compact or
      efficient sedan and doesn't include charger inefficiencies. A PHEV-40
      sedan or a PHEV-20 SUV or pickup truck could reach only a 6 hour rate on
      120V, thereby triggering the requirement for a higher power 240V
      charger, at more cost and to what advantage?

      Draft California Exhaust Emission Standards and Test Procedures for 2011
      and Subsequent Model Years ZEVs and HEVs

      My comments so far are actually from the Staff Presentation slides,
      which are a condensation of the other documents, and Argonne Labs'
      presentation at the 2008 SAE Hybrid Conference, as I have not yet read
      this document.

      Presentation slide 26 says that "Only one required charge for PHEV
      testing if AC Energy to fully recharge is within +/- 1% between the
      Urban and Highway CD Range tests...". 1% is also mentioned on slide 23,
      slide 27, and in other places. This seems unusable, as at least 5%
      differences between separate discharges and charges are common after
      similar driving conditions.

      Thank you for your consideration of my comments.

      Ronald Gremban, CalCars' Technical Lead

      -- -- -- -- -- -- -- -- -- -- -- --
      Felix Kramer fkramer@...
      Founder California Cars Initiative
      -- -- -- -- -- -- -- -- -- -- -- --

      [Non-text portions of this message have been removed]
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