In a memo sent to the US Senate Finance Committee during their deliberations, Toyota outlined its concerns with the conversion of existing hybrids such as the Prius to plug-in hybrids (PHEV) in the context of proposed incentives to spur PHEV adoption. CalCars published the document.
Toyota’s view, according to Charles Ing, Director, Government Affairs Toyota Motor North America, is that PHEV converters should comply with existing standards governing second-stage manufacturers; that NHTSA and EPA should be required to establish new regulations for the certification of conversions of used vehicles—thereby putting the product liability and warranty risk onto the converter; and that the government should assure that there be no degradation in emissions and vehicle safety before it provides taxpayer incentives for conversion.
At the top of Toyota’s list is the concern over the degradation of emissions (higher NOx and total HC emissions) exhibited by a converted Prius PHEV than by a stock Prius. (Earlier post.)
This raises the question of whether the government should be paying people to make their cars dirtier?—Toyota memo
Toyota also expressed a specific concern over converted PHEVs being out of compliance with Federal Motor Vehicle Safety Standards (FMVSS), noting that after-market converters do not perform crash testing to certify that the converted vehicle meets or exceeds FMVSS.
Toyota also cited a number of general concerns:
Increased risk of fire from lithium-ion batteries. This may particularly resonate with Toyota given its delay of introducing lithium-ion batteries in the next-generation Prius, reportedly due to thermal management problems.
Increased risk of injury in an accident. Aftermarket batteries, Toyota argues, can compromise the fuel system and/or crashworthiness, even becoming projectiles in an accident.
Adverse effect on rear suspension. The addition of hundreds of pounds of extra weight in the rear of the vehicle compromises the rear suspension and handling and stability.
Compromised powertrain and voiding of warranty. Toyota charges that converters “hack into and modify” the software in the engine control module, which may damage the battery pack and engine, and also voids the warranty.
Increased risk of electrical shock. Toyota said it was unaware of any testing to ensure compatibility between the conversion kit batteries and home electrical wiring.
Removal of spare tire. Removing the spare tire to allow placement of the battery “poses a risk in the event of a flat tire in an emergency situation.”
Non-compliance with EPA regulations. To the extent hybrid plug-in converters interfere with the ECM and the vehicle's emissions, the vehicle may then not be in compliance with EPA regulations.
In response, CalCars founder Felix Kramer commented that the bill’s definition of “qualified plug-in electric drive motor vehicle” means they must meet environmental, as well as National Highway Traffic Safety Administration (NTSA) and Federal Motor Vehicle Safety Standards. Most of Toyota’s objections, in other words, will not apply to eligible vehicles as defined in the bill.
CalCars values conversions because they increase awareness and support for PHEVs. At the same time, they offer a partial response to the intense demand for PHEVs from people who can’t believe we have to wait for years for something we should already have. Our strategic goal in promoting conversions is to motivate, pressure and incentivize carmakers to build PHEVs. Of course, once automakers finally do sell PHEVs, there will also be many hundreds of thousands of hybrid candidates for safe, affordable, warranted retrofits.
Our large international car companies are the ones who should be resolving the issues raised—they can do the job right!—Felix Kramer