The EPA has issued an update to their alternative fuel certification requirements. I have often wondered how these affect us as electric vehicle converters and system designers and more importantly in the plug-in hybrid side of things. If you would like to dig through the whole thing, you can find it here:
- Fact Sheet: EPA Announces Final Rulemaking for Clean Alternative Fuel Vehicle and Engine Conversions
- Final Rule (PDF) (186 pp, 742K, March 2011)
- Response to Comments (PDF) (65 pp, 833K, EPA-420-R-11-002, March2011)
and the guidance letter that was released on October 28, 2010:
After digging through it, I found these statements at the end of the guidance letter:
22.1 What are EPA’s policies with respect to converting hybrid electric vehicles to plug-in hybrid electric vehicles?
Ans. EPA’s conversion policy applies to hybrid electric-to-plug-in conversions. Certification is required to ensure that the converted plug-in hybrid will meet applicable emission standards and will remain clean and durable for its full useful life. This is necessary because any change to an OEM-certified configuration could affect the emission control system and could be considered a tampering violation. In the case of an aftermarket plug-in hybrid conversion, for example, it is possible that the altered interaction between the internal combustion engine and the battery electric system could cause more “cold starts” of the internal combustion engine, thereby increasing emissions relative to the OEM vehicle.
22.2 What are EPA’s policies with respect to converting vehicles to full battery electric?
Ans. Vehicle conversions to full battery electric (no on-board source of combustion emissions) do not require alternative fuel vehicle certification as protection from a possible tampering violation.
So, pretty clearly, It seems that an all electric battery conversion of any car looks to be clear of concern at this point. However, if you are installing PHEV kits for say… a Prius… you will need to point to the certification for that kit. Now, I’m off to ask Enginer where they stand on said certification…