Ron at CalCars 
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Re: “Who's Killing the Plug-In Hybrid?

Addendum by Ron Gremban, CalCars Technical Lead (what I forgot to say):

CalCars believes the HEV-to-PHEV conversion industry is still too embryonic to survive the serious regulation required for mature industries, and that the hundreds to thousands of conversions that may be installed by entrepreneurial companies in the next 2-3 years will make a much more significant contribution to the progress of efforts to reduce greenhouse gas emissions than the possible cost of their worst case contributions to smog.

Also, whatever is decided for HEV-to-PHEV conversions may well apply to future ICE-to-PHEV conversion efforts, which, though even more embryonic, will be needed en mass to meet CA requirements for 2020 and 2030 carbon emissions, because even automaker PHEV ramp-up 25 times as fast as has occurred for hybrids would fill only 7% of CA's automotive fleet with PHEVs, and reduce carbon emissions and oil use by maybe 3%, by 2020.

Instead of CARB's current proposal, we recommend immediate rules for registration of conversion manufacturers, with provisions for industry-government dialog along with probable collaborative research and testing aimed at coming up, as the industry grows and matures, with regulation that best satisfies the state's combined needs for clean air, customer protection, and the most rapid and effective possible reduction of vehicular carbon emissions and oil consumption.

However, if CARB does go ahead, here is an example of a graduated regulation scheme that could continue to allow grass roots innovation by holding compliance costs to around $500 per already-sold conversion -- a high but not insurmountable hurdle:

* A company enters the conversion business by presenting CARB with an engineering proposal showing how it will avoid increased criteria pollutants; it then shows a running prototype. Each completed conversion is subject to an ordinary end-user smog test for that model of unconverted vehicle. Buyers sign a contract acknowledging the level of warranty accompanying the product, accepting a level of risk for an 'experimental' conversion, and perhaps committing to periodic ordinary smog tests that are not otherwise immediately required of SULEV vehicles for several years.

* After selling 10 conversions, the manufacturer explains how the now-current version(s) avoid mechanical, reliability, and emissions problems, and shows on paper how the system preserves known OEM OBD functionality.

* After selling 100 systems, one vehicle undergoes the most basic manufacturer emissions testing, and the conversion manufacturer shows how known OEM On-Board Diagnostic System (OBD) functionality is both preserved and enhanced with similar capabilities warning of conversion components needing service.

* After selling 1,000 systems, the company complies with CARB's whole set of production conversion rules.

Posted by Ronald Gremban on 01/16/2009 at 9:44 PM

Re: “Who's Killing the Plug-In Hybrid?

By Ron Gremban, CalCars Technical Lead: This is a great article!

It did seem to imply that all plug-in hybrids (PHEVs), or maybe just all conversions, are limited to 34 mph and modest acceleration without the engine, which is not true; converters have even managed to drive Prius conversions electrically to 52 mph despite Toyota's limiting software.

I believe that CARB wrote their proposed rules as if the PHEV conversion industry is a huge, mature industry like auto manufacturing, which has a billion-dollar cost of entry and 5 year development cycles. In contrast, all conversion manufacturers, except Hymotion once it was bought by A123, are entrepreneurial, funded largely by sales of evolving, often one-of-a-kind conversions.

The proposed CARB rules would require all design, testing, and certification efforts to be done up front before selling any conversions. Because this conversion industry is so embryonic, the market hasn't been established and suppliers -- especially smaller battery manufacturers without the cash to compete for auto manufacturer contracts -- have no real-world automotive experience with their components for which CARB would require proof of longevity. This means sufficient venture capital is hard to come by, so innovators must for now remain largely self-funded, making cost of entry prohibitive with such rules.

As mentioned in the article, the rules would (for good reasons, but with draconian results) require converters to include SULEV-level warranties. Worse (and not mentioned), for vehicles 6 years old or newer at the time of conversion, conversion would reset the vehicle's mileage and date of manufacture back to zero for the warranty!

One more thing, Onboard Diagnostics (OBD), required of all vehicle manufacturers, would be required to be fully understood, modified as necessary, and extended by a converter. The problem is that OBD internals, including the information needed to be sure to avoid lessening the effectiveness of the OEM OBD, appears to be proprietary data not available to anyone but the original manufacturer and government entities.

For more specifics related to the original CARB proposed rules -- though not the minor modifications that came as later amendments, please see my August 2008 formal comments to CARB at .

Posted by Ronald Gremban on 01/16/2009 at 5:32 PM

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