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Trouble with California HOV Sticker application

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Moderator: kchiang

Do you think home conversions should be eligible for the white HOV sticker in California?

Poll ended at Wed Sep 19, 2012 1:11 am

Yes
3
100%
No
0
none
 
Total votes : 3

Trouble with California HOV Sticker application

Postby kchiang » Fri Jul 20, 2012 11:26 pm

Recently, the California Air Resources Board (ARB) has been turning down converted EVs for receiving the white Clean Air Vehicle stickers, including my MR2 electric that is charged mainly off solar panels.

white_cav_decal.gif
white_cav_decal.gif (4.04 KiB) Viewed 10834 times


These stickers allows 100% electric vehicles to use the High Occupancy Vehicle lanes during traffic hours and also reduces the toll that the drivers have to pay to cross any of the bridges in the Bay Area.

From the DMVs website http://www.dmv.ca.gov/vr/decal.htm, the criteria for receiving a white sticker is as follows:
White CAV decals are issued according to the following criteria:

A vehicle that meets California’s super ultra–low emission vehicle (SULEV) standard for exhaust emissions and the federal inherently low–emission vehicle (ILEV) evaporative emission standard. This includes certain zero–emission vehicles (ZEVs).
A 2004 model-year or older vehicle that meets the California ultra–low emission vehicle (ULEV) standard for exhaust emissions and the federal ILEV standard.
Certain Advanced Technology Partial Zero-Emission Vehicles (AT PZEV).

I've been in contact with the ARB a few times regarding this issue, and here's a bulleted list of the key things they mentioned to me.


    * Manufactured EVs that appears on their list of eligible EVs qualify for the white sticker.
    * One up home conversions do not qualify for the certification process.


I understand why the ARB requires certification of all ZEVs before granting eligibility for these stickers, but it is item 3 that I have issue with.

If I am willing to go through the certification process to prove that my home converted electric car meets all ZEV standards, why won't the ARB allow it? If it is a resource issue, then perhaps what it takes a more streamlined procedure for doing such certifications. It is my opinion that this is unfair and discriminatory against small business that specialize in conversions as well as individuals who due to preference, may elect to convert a classic car like a Porche 911 to electric instead buying something like a Leaf. I've left a message today for the contact at ARB that is responsible for ZEV certifications (Ms. Shobna Sahni, (626) 450-6104, ssahni@arb.ca.gov) to see if it will be possible to put my 1986 MR2 electric through certification and will report back.
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Re: Trouble with California HOV Sticker application

Postby kchiang » Mon Jul 30, 2012 10:28 pm

I heard back from a Mark Williams at the ARB. As it turns out, converted EVs are eligible for certification for consideration for the HOV stickers, however, Mark warned that it could be expensive for the individual to go through the process. I've also recently learned that a couple of folks have received their HOV stickers for their converted EVs in my local chapter's Electric Auto Association. What an inconsistent process...

Here's the email excerpt from Mark.

======================
Specifically, ZEV certification is required to ensure a level playing field – that all vehicles granted access to the HOV lane meet similar levels of performance, durability, and warranty. The ARB does allow that entities other than automakers may request certification of aftermarket EV conversion kits, but John [Swanton] expects this will be done in situations where the kit is going to be used on multiple numbers of the same model or similar models and not as a one-off conversion. He expects this because the process for certifying an EV conversion kit is rigorous, requiring dynamometer testing and demonstration that durability and warranty requirements would be met; the cost of this process would make it prohibitive for a one-off conversion.

I know there are likely a few EV conversion vehicles with HOV stickers; However, I’ve been dealing with EV/CNG incentives and HOV lane questions at the ARB since about 2003, and I can tell you that the existence of these decaled conversion EVs does not reflect a change in ARB policy regarding conversion eligibility. Instead, it is more a testament to what can happen at the DMV on any given day. For example, I’ve seen yellow (hybrid) decals on an Accord V6 Hybrid even though it doesn’t meet the 45mpg requirement in the statute and therefore wasn’t on ARB’s HOV lane eligibility list. When we observe an inappropriately decaled vehicle, we report it to the DMV so that they can request the stickers back.

With that said, the ARB appreciates the contribution that you are making to clean air through conversion of your vehicle to electric.

Regards,

Mark Williams
Air Pollution Specialist
Zero Emission Vehicle Implementation Section
Mobile Source Control Division
California Air Resources Board
916.327.5610

========================================================

I've requested information on how to go about getting my EV certified to be ZEV and will publish information that I think may help others.
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Re: Trouble with California HOV Sticker application

Postby kchiang » Tue Nov 06, 2012 6:35 am

I have not heard from anyone else from CARB on the procedure to go about certifying my converted EV for HOV lane access.

I did draft up a letter with help from my local Electric Auto Association to California State Senators asking for help in the matter. Surprisingly, an aide from the Senator Simitian's office suggested that I take the legislative approach to try to get some firm language defined in a bill amending the existing law to allow home conversion access to HOV lanes. That is unless we can get a powerful ally within CARB to change thing from a regulatory perspective. Does anyone know of someone that can help at CARB? Senator Simitian unfortunately will term out this year.

I am planning to approach other senators and assembly members again in December when the election dust settles.
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Re: Trouble with California HOV Sticker application

Postby mcbrems » Thu Feb 07, 2013 2:03 pm

Has any progress been made on this issue?
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Re: Trouble with California HOV Sticker application

Postby kchiang » Sat Feb 09, 2013 12:14 am

Yes, I emailed and called Senator Ellen Corbett's office and got a response in January from one of her aides, Alex Kobayashi.

Realistically, if we are successful at getting the law changed, it will not take effect until Jan 2014, which means we will have 1 year to enjoy the benefit (sticker program expires in 2015). That is unless it is extended again, Alex does think that there is a chance they may extend again given that they've done so in the past.

The following is a copy of the letter I sent.
==========================
Date: 12/18/2012
Senator Corbett:

I am writing as a clean energy enthusiast who believes in investing in after market conversions of existing gasoline cars into 100% electric vehicles (EVs).

Like many others, I've chosen an after-market conversions of an existing car as opposed to purchase OEM EVs because of preference for a particular car and a lower cost of ownership. My converted EV as well as others like it meet the federal zero emissions vehicle (ZEV) classification and the federal government promoted such conversions by giving a tax credit of 10% of the conversion cost through 2011. You can see a list of such vehicles on http://www.evalbum.com.

To help promote ZEVs in an attempt to curb air pollution, the California Air Resources Board (CARB) authorizes the issuance of White HOV decals for ZEVs. This privilege was recently extended to Jan 2015 via AB1500-2010; however, this signed bill introduced added language over the previous version (AB 71) that only certain commercially manufactured EVs are eligible. The do-it-yourself (DIY) converted EVs that many of us commute in everyday that are also ZEVs, are not eligible unless we go through a prohibitively expensive and lengthy certification process to prove durability and warranty equal to that of manufactured vehicles.

I think this policy at CARB is against the spirit of the original bill and argue that DIY 100% EVs should be eligible for HOV white stickers and should be exempt from CARB's eligibility list.

Requiring certification of durability for the DIY conversion is a wasteful use of CARB resources since each conversion is unique. It creates an unnecessary burden on the individual because the conversions have already gone through the scrutiny of the owner and driver. Certification of the primary motive power through existing DMV procedures to ensure that federal standards of zero emissions requirements are met should be the only criteria for eligibility.

Please help us change the law to give the HOV incentive back to DIY conversions to help speed up the adoption EVs for a cleaner California. Thanks for your attention to my request. A number of us from the Electric Auto Association of Silicon Valley (http://eaasv.org/) would be willing to meet with you to answer any questions you may have on this matter.

Sincerely,

Ken Chiang
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Re: Trouble with California HOV Sticker application

Postby kchiang » Wed Feb 13, 2013 9:41 am

Just heard this news: Looks like the sticker program could be extended to 2025!

From the Media New Group:

Q: My husband and I are thinking of buying an electric car. I know that the carpool sticker program expires at the end of 2014, but is there any chance it will be extended for a few more years? I'm sure that would spur the sale of these vehicles.
D. Manning
San Francisco

A: Yes, there is a chance. Assemblyman Bob Blumenfield, D-Van Nuys, has introduced legislation to allow drivers of plug-in hybrids and electric cars to drive solo in carpool lanes or toll lanes until -- get this -- 2025.

MediaNews Group, 101 W. Colfax Ave., Suite 950, Denver, CO 80202

I will contact his office about the DIY HOV sticker problems as well.

phpBB [video]
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Re: Trouble with California HOV Sticker application

Postby mcbrems » Fri Feb 22, 2013 5:28 pm

I'd like to pursue this with my local representative(s). Do you have any advice before I get started?

McB
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Re: Trouble with California HOV Sticker application

Postby kchiang » Fri Feb 22, 2013 6:53 pm

Please do! I'd encourage all other EV club members to do the same with their representatives to make them aware of the issue.
One other possible avenue is to contact CARB to try to get them to change their regulatory policies, but I decided to stick with the advice from former senator Simitian's staff to go after legislative change. With this new bill introduced by the assembly man, I think the time is ripe for all of us DIY'ers to voice our opinions!
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Re: Trouble with California HOV Sticker application

Postby mcbrems » Wed Jun 05, 2013 5:42 pm

The problem here is conceptual. The CAV sticker program was originally designed to incentivize the purchase and widespread adoption of cleaner vehicles in CA, not the conversion of existing cars. The DMV administers the CAV sticker program, for which ARB has been enlisted to oversee the certification of manufactured vehicles and parts with regard to air quality concerns. The ARB is not ultimately responsible for issuing CAV stickers - It is the DMV's program and their responsibility. Unfortunately, the DMV has not provided a path toward certification for the one-off EV conversion, which is not fair to the person who has contributed to the green vehicle revolution with their own money, time and sweat.

My pure electric vehicle does not have a tailpipe, does not emit any exhaust gasses, does not negatively impact air quality, and therefore should not fall under the purview of the ARB. I understand ARB's focus on standards, warranty, and longevity of newly manufactured vehicles and parts, but that argument only reflects the limits of ARB's jurisdiction. They have no specific language, and therefore no authority over individually converted vehicles.

Here is a possible solution. The DMV uses their existing referee program to confirm that the conversion is pure electric, has no tailpipe, and therefore is emissions-free. At the moment the registration and title of the vehicle is modified by DMV to electric motive power (non-hybrid), it immediately qualifies as a Clean Air Vehicle, and is issued a sticker. This would hardly overtax the referee and DMV sanctioned garage, as there would only be a small handful of vehicles inspected every quarter.

Conceptual problem solved.

Now I need to go blog about it.

McB
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Re: Trouble with California HOV Sticker application

Postby mcbrems » Fri Jun 14, 2013 4:41 pm

So I blogged about it.

My research is complete. It seems ARB has complete say over who or who does not get CAV stickers, and that is governed by legislation. Also, it was explained to me that the CAV sticker program is an incentive limited mainly to the buyers of new ULEVs or ZEVs, or conversions performed by a manufacturer (a certified fleet manager for instance). Bottom line: It is an incentive program, not a reward program.

In order to make any policy change, it has to go through the legislature. Furthermore, there are a limited number of stickers for obvious reasons, but that makes them even more valuable to EV manufacturers, who will lobby hard to prevent anybody else from getting those stickers - Like US.

I finally posted on the subject:

http://914electric.wordpress.com/2013/0 ... e-diamond/

Make sure to click on the link to the Catch 22 clip. Pretty funny.

Cheers,
MB
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