In the midst of all the excitement about new plug-in vehicles at the Detroit Auto Show and a new administration in Washington, momentous developments are brewing in California that could seriously threaten the viability of the nascent industry that's converting hybrids to plug in. . . .

The proposed regulations impose onerous requirements for testing procedures, emissions, warranties and related issues. It is not easy for an agency accustomed to working with large auto industry players to accommodate entrepreneurial startups often working on vehicles one at a time in search of innovative ways to reduce the emissions in existing vehicles -- but we think it's important to do this carefully and right.
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However, if CARB does go ahead, we present an example of a graduated regulation scheme 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 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

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