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ARB Approves Modifications for Test Procedures for Plug-in Hybrids and Fuel Cell Vehicles, Defers Decision on Certification of PHEV Conversions

The California Air Resources Board (ARB) today approved amendments to exhaust and evaporative emissions test procedures for plug-in hybrid electric vehicles as well as a new method for determining the range of fuel cell vehicles.

The Board deferred a decision on ARB Staff’s proposal for certification and warranty requirements for plug-in hybrid electric vehicles. Concerned that the rule as proposed would have been too onerous for conversion start-ups, the Board directed staff to work more with the industry to develop a ruling that will do more to address the need to maintain a viable conversion industry.

PHEV Exhaust Emission Test Procedures. Automotive criteria emissions are controlled with catalysts which operate most efficiently when warm. Most emissions from vehicles occur at the start of combustion engine operation (a “cold start”).

The current California test procedures for conventional vehicles and conventional hybrid electric vehicles measure emissions produced from cold starts and “hot starts” (IC engine at optimal operating temperature) using driving schedules that simulate a range of low and high speed vehicle operation.

For both conventional HEVs and conventional vehicles, the engine operates most of the time and typically there is only one cold start. PHEVs, on the other hand, can cycle the IC engine on and off several times throughout the operation. Depending on the operating conditions, these vehicles are capable of multiple cold starts throughout a test drive cycle.

To address this, ARB staff proposed new methods that are aligned with the emerging SAE recommended practice for measuring the exhaust emissions and fuel-economy of hybrids (SAE J1711). SAE J1711 includes procedures for determining emissions and all-electric range of PHEVs.

The SAE J1711 revisions will not be completed in time for ARB regulatory requirements, with several auto manufacturers urgently working towards near-term deployment of PHEVs. Therefore, ARB staff began a parallel SAE-ARB Exhaust Test Procedures development effort. SAE J1711 must also cover additional procedures that the ARB Exhaust Test Procedures do not, for example, the development of fuel economy test procedures for hybrids.

The newly approved ARB Exhaust Test Procedures incorporate a method for testing all types of PHEVs to determine the vehicle’s electric range contribution, to accurately quantify exhaust emissions, and determine if vehicles qualify for the zero-emission VMT or advanced componentry allowances described in the ZEV regulation.

The new Exhaust Test Procedures will be required for the 2011 model-year. Manufacturers may opt to use the proposed Exhaust Test Procedures for model-years prior to 2011.

Specifically, the amendments institute a new urban charge depleting range test, and a highway charge depleting range test, each of which continue until the charge sustaining range is reached (two consecutive cycles for urban, one cycle for highway).

The new Exhaust Test Procedures also include two methods to determine if a PHEV qualifies for a Type F or Type G HEV advanced componentry allowances under the ZEV regulation.

Evaporative Emissions. Gasoline-fueled vehicles use a canister to capture fuel vapors. Under operation, the engine purges the canister, burning the vapor in the engine. If the engine is not used, the canister is not purged, and it can overflow with resulting hydrocarbon emissions to the atmosphere. This is a non-linear event, noted Tom Cackette, ARB Chief Deputy Executive Officer, during the hearing. “You can get a huge amount of hydrocarbons coming out of vehicles” in that event.

Because PHEVs can theoretically go for long periods of time with operating the engine, evap emissions are a concern.

Manufacturers are exploring various evaporative emission system designs for controlling evaporative emissions in response to the control challenges presented by PHEVs. Staff believes that manufacturers will ultimately select designs that use a “non-integrated refueling canister-only” system because this design provides some technological advantages over conventional systems for effectively managing the real-world evaporative emission conditions.

In terms of test procedures, the revisions attempt to simulate real world conditions and capture worst-case emissions.

Fuel Cell ZEV Range Determination. The current all-electric range test procedures were developed in the 1990s based on battery EVs. The test assumes that vehicles under test are “fully charged” and runs until the vehicle cannot maintain the cycle.

With hydrogen fuel cell vehicles now showing ranges of 300 miles or greater, running the old test procedure could take more than 20 hours.

The new regulations incorporate the newly revised SAE J2572 “Recommended Practice for Measuring Fuel Consumption and Range of Fuel Cell and Hybrid Fuel Cell Vehicles Fuelled by Compressed Gaseous Hydrogen”. This SAE Recommended Practice addresses both the hydrogen measurement challenges and the impractical duration of the current AER Test for fuel cell EVs by reducing actual dynamometer testing to only two UDDS cycles (about 15 miles) with one 10-minute soak.

Hydrogen consumption is measured to within one percent accuracy, used, along with the usable hydrogen storage capacity, to calculate range. For a 300-mile hydrogen ZEV, this revised procedure would result in a reduction in dynamometer test time from 21 hours to 54 minutes.

The new test procedure is not applicable to higher-range battery EVs  because of additional challenges in consumption and capacity measurements for batteries, ARB staff said. In addition, battery depletion may not be linear with mileage.

SAE may develop a similar abbreviated procedure for high-range battery EVs, and ARB may consider its inclusion at a later date.

PHEV Conversions. The element of the multi-part proposal considered this morning that generated the most discussion both before and during the hearing was the proposed certification of aftermarket plug-in conversions.

Conversions are considered aftermarket parts, and as such legally require exemptions from anti-tampering requirements, with the exception of the handful of vehicles given an experimental exemption for development purposes.

Certified conversion systems—such as CNG or propane—are required to meet original emission certifications, exhibit durability, and meet OBD requirements.

Part of ARB staff’s concern is that the vehicles being targeted for conversion are originally PZEVs, warranted for emissions by the vehicle manufacturers for 15 years or 150,000 miles. The battery is considered an emission control part and is considered a zero-emission energy storage device used for traction power. As such, the battery is warranted for 10 years or 150,000 miles. The battery on non-PZEV HEVs, which may also be converted, is warranted by the vehicle manufacturer for 7 years or 70,000 miles.

PHEV conversions impact the way the target vehicle was designed to operate. More electrical energy means less internal combustion engine operation with potential for higher cold start emissions, reduced emission canister purges causing higher evaporative emissions, and higher loading on existing electrical components, such as an electric motor, possibly leading to faster component wear and tear. Conversions also impact operation of the OBD system.

The original proposed warranty schedule for PHEV conversions. Click to enlarge.

ARB staff proposed a certification process similar to that already used by alternative fuel Conversion System Manufacturers. They would require Conversion System Manufacturers to submit an application package to initiate the certification process, perform emission, durability, and in-use testing, and provide documentation of consumer warranty. These new procedures also require that Conversion System Manufacturers meet OBD requirements.

The area of greatest concern for the conversion industry was the warranty terms, which, as many conversion companies and supporters said in both written testimony submitted prior to the hearing and orally during the hearing, would price them right out of business.

The corresponding concern from the Board, as voiced by chairman Mary Nichols was “Are we stifling a process [PHEV conversions] that is going to increase the amount of partially electric vehicles out there?

ARB staff was taking the approach that there is a potential emissions issue that needs to be addressed.

The question becomes is this just a procedural necessity, or is there a real concern. I think the general public view is that it’s [conversions] got to be good.

[Based on past experience with CNG and propane] it turned out that it wasn’t good if you didn’t do it right. It made NOx go up. The certification procedures had a purpose to make sure that people who do not have the engineering and financial resources to do the kind of job of design of an OEM have to go through some level of testing to ensure that they haven’s messed up the original emissions limits.

With the plug hybrid, it’s the same situation. We have data from people, they run an emission test, emissions are higher.

We don’t want to put to much of a burden on a converter, but at the same time, we don’t want to take a whole piece of the lattice to say you don’t have to do this one or that one...On the other hand, we don’t want to be so seeking perfection that we kill the opportunity for people to evolve.

—Tom Cackette

Based on the very low volumes of PHEV conversions currently in California, on the desire to encourage innovations, and by some accounts to keep pressure on the OEMs to continue to develop and improve their PHEV work, the Board remanded the proposal back to staff for further development. 

The sense among the Board at the hearing seemed to be that there might be a tiered approach to certification for conversions companies (along the lines of a Calcars proposal made to ARB on this topic), although the specific vehicle thresholds would still need to be worked out.




They should cut the PHEV modders some slack - they are doing research that would cost hundreds of millions.

The way to handle PHEV mpg and CO2 numbers is to publish a curve rather than a single number.

This would have data taken at 5 10 20 30 40 50 60 80 100 200 300 miles (or whatever).

With a battery EV, you mightn't make it all the way.
With an ICE, it would be flat, or

You could put city driving in the first 20 miles and highway driving after that.

This would give interesting curves for HEVs, PHEVs and ICEs.

George K



Excellent report! Here's what we said after the Friday hearing. (See previous postings at The CalCars-News Archive.)

Today the California Air Resources Board Listened to Converters

In this week of unprecedented change in Washington, we can also report progress in Sacramento at the agency that is most responsible for the future of PHEV conversions -- whose rules are precedent for many other states, watched by all others and the federal government, and closely tracked by the auto industry. Here's our statement:

We're very pleased to report that at today's California Air Resources Board hearing, the CARB Board decided to take another look at the implications for the aftermarket conversion industry tof proposed staff regulations for PHEVs. (See our previous postings at­news-archive.html .) In a move with very positive implications, CARB took action to keep alive the possibility that an industry of converters of both hybrid and non-hybrid vehicles can grow and flourish, helping to reduce greenhouse gases in cars that are on the road, creating new local jobs, and further motivating the auto industry to mass-produce plug-in hybrids and all-electric vehicles.

Board Members showed they had read the testimony and proposals submitted in advance, and listened carefully to those who testified. Members repeatedly cited the issues raised by companies and advocates. They spoke in highly complimentary terms about the positive past impact of conversions in motivating the auto industry to build PHEVs, and also about the strategies and proposals made by CalCars and others to address the regulatory issues. Veterans of past CARB hearings on plug-in vehicles who had been expecting bad news said they were very encouraged by today's actions.

The Board detached the aftermarket conversion issues from the general test procedures for new PHEV manufacturers and then approved the latter. For retrofitters, the Board Members directed its staff to review options for rules that would promote innovation and foster new business and job formation. The ball is once again in the court of the aftermarket companies, their allies and potential customers, who now have some weeks or months to respond fully and develop workable solutions with the staff.

We'll have a fuller report and comments as soon as we can. Meanwhile, we owe a tremendous thanks and all our appreciation to the Board Members who agreed in a unanimous voice vote to keep the process open for additional input. Six of eleven members were in attendance: Mary D. Nichols, Chair; Daniel Sperling, Automotive Related Member; Ken Yeager, Bay Area AQMD Member; Dorene D'Adamo, Law Member; Sandra Berg, Public Member; John G. Telles, M.D., San Joaquin Valley APCD Member (see­board/­members.htm for profiles). Primarily speaking for the staff were Executive Officer James Goldstene and Chief Deputy Executive Officer Tom Cackette, who echoed the desire to promote innovation.

Our thanks also to all of you who sent in comments and suggestions, and to those who showed up and testified.

-- Felix Kramer, Founder, The California Cars Initiative

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