Comment Log Display

Having reviewed the proposed ZEV regulatory changes for 2010, I
have a suggestion for a way to attain the targets much sooner than
planned, by expanding the scope of the regulations to also
encompass aftermarket systems.

ElectraDrive is a plug-in drivetrain solutions provider.  We are
developing an Add-On Electric Drive which will give gas-guzzling
utility vehicles, such as trucks, a plug-in electric capability of
up to 40 miles of range without compromising the factory
powertrain.  This solution is expected to reduce fuel consumption
and emissions by 50-70 percent in mixed driving.  Our core
integration technology is able to traverse different OEM platforms
and operate up and down the size spectrum.

ElectraDrive's reference customer, Alameda County, operates a
diverse fleet of trucks whose emissions they seek to reduce, while
extending the lives of the vehicles themselves.  In this they are
typical of many public fleets in California.  

ElectraDrive recently calculated the project cost-effectiveness on
an Add-On Electric Drive for the first of several pilot projects
with Alameda County, on a Dodge Dakota.  This calculation was
performed to determine whether to apply for a BAAQMD Advanced
Technology Demonstration grant to support the project.  The BAAQMD
requires project cost-effectiveness be calculated based on the
projected reduction in criteria emissions, using CARB EOs as
reference.

It turns out that this specific project is not cost-effective
based on consideration of criteria pollutants alone.  The truck in
question is not a heavy emitter of criteria pollutants.  However,
it is a heavy emitter of carbon dioxide.  The project is extremely
cost-effective when CO2 is factored into the equation.  The problem
up to this point has been that BAAQMD has not been permitted to
consider CO2 as a determining species in cost-effectiveness.

It is good to see that CO2 is finally being brought into the
regulations.  However, a turnover rate of about 6 percent in the
general vehicle population means that the replacement of CO2-heavy
drivetrains, such as in light trucks, with low-emission
alternatives will be far slower than what is actually needed to
satisfy the requirements of present and future legislation.  

The penetration of clean drivetrain technologies by the
incorporation of CO2 into the regulations can be vastly accelerated
by expanding the regulations to encompass aftermarket technologies
that can be fitted to existing vehicle platforms.  In many cases
(ElectraDrive's included) the aftermarket system will cost less
than a new vehicle.  Customer ROI for our solution projects to 3-5
years, which is well within the extended service life of the
vehicle.

Institutional fleet customers want these solutions today, as a way
to accelerate their clean-fleet programs during the roughly ten
years it will take for a wide range of OEM solutions to become
available.  The market for these solutions can receive a
significant stimulus if the ZEV regulations are expanded to
encompass aftermarket drivetrain solutions.

I understand that such a modification may necessitate the merger
of programs presently in different areas.  I would encourage CARB
to consider this.  After all, the problem is not with the vehicle
platforms themselves but with the drivetrains contained inside
them.  The regulations should pertain to and refer to 'drivetrains'
rather than 'vehicles'.

Thank you for your consideration.

Fraser Murison Smith
CEO, ElectraDrive