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Dear Air Resources Board Members:

This is to spell out the concerns behind the ten-year battery
warranty included in your ZEV regulations.

In working with the manufacturers of electric vehicles it is clear
to me that producing batteries and providing warranties is done by
battery companies not by the manufacturers of the vehicles. These
battery companies are either new companies working on new
technology or they are old companies working on updating and
optimizing old technologies.

The old companies are working with technology that they normally
can provide twelve-month full warranty replacement on those
batteries. I have actually found one that gives a three-year
replacement warranty and had trouble getting that honored because
the battery supply was being limited to military uses in Iraq.

The new companies are just now getting the technology in place to
provide batteries for initial testing. The only new technologies
that have been fully field-tested are the nickel metal hydrid
batteries in the Toyota RAV 4. These are fading after six of seven
years. The Lithium Ion batteries show great promise in the lab and
in early testing but none has been field tested on a long-term
basis. In point of fact very few short-term field tests have been
completed successfully.

There is a lot of new technology involved with lithium ion
batteries that are in very early stages of development. This
includes both the chemistry and construction of the batteries as
well as the technology for the battery management systems and for
the chargers. Buying batteries alone does not work. They have to
have all three parts to be an effective source of power for and
electric vehicle.

Requiring that new vehicle manufacturers put their companies
future on the line behind this new and experimental technology is
unreasonable. The requirement means that the manufacturers are at
the mercy of the companies that produce the batteries, the battery
management systems and the chargers. Any of these companies could
have technical flaws or management problems that means they go out
of business. The battery management systems or the chargers may
have problems that destroy the batteries and these may or may not
be provided by the battery or the vehicle manufacturer. The
vehicle manufacturers competition may buy out the battery
producer.  The battery producer could refuse to warranty the
batteries that are not managed by their own technology.   All of
this puts the burden on the vehicle manufacturer in an
unreasonable way as they could be left holding the bag for the
warranty on a product produced by another company.

Keeping the ten-year specification would require the manufacturer
to increase prices substantially to cover this burdensome
requirement. That in turn will reduce the demand for the vehicle
and delay getting the ZEV solutions on the road.

The consumers can and will take on some of the burden for
replacing batteries. Experienced electric vehicle owners recognize
that batteries are a consumable supply and plan on replacing them.
This is the maintenance that is required on an EV. It is required
much less frequently than an oil change or a tune up. The expense
for changing the pack is higher than that of an oil change – a
recent estimate of $1800 was given for a full speed EV including
labor.  That is still reasonable when you consider the energy
savings and the savings on oil and brakes etc. that a good EV
provides. 

It may be appropriate to require a disclosure notice of the
estimated maintenance cost to new consumers over the ten-year
period so that they know what to expect.

If you want to push the technology then start by exceeding the
industry standard of one year and require the current industry
extreme high end of a four-year warranty. As the technology
becomes proven and is developed in that time period then increase
the requirement. Asking a new and developing industry to start out
by giving a warranty that is more than five times the current
average is just asking too much. 

This information is based on four years of using electric
vehicles, forty years of being a business manager as well as
having experience as a professional mechanic and in managing small
commercial vehicle fleets. It is also based on being part of
network of people and manufacturers interested in alternative
vehicles. 

The ten-year requirement is going to delay the start of this
market more than encourage it. If you want ZEVs on the road then
let us know by adjusting this part of the regulations.

Appreciatively Yours

Russell Sydney
Principle Organizer for The Sustainable Transport Club.
www.sustainableclub.org