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Comment 2 for Proposed Advanced Clean Cars II Regulations (accii2022) - 15-1.

First NameKenneth
Last NameJohnson
Email Addresskjinnovation@comcast.net
Affiliation
SubjectEV conversion kits?
Comment

Has CARB given any consideration to EV conversion kits, which GM and Ford are now selling [1,2]? Probably other manufacturers would also enter the EV retrofit market if  regulatory incentives encourage them to do so.

An EV conversion upgrade of an ICE vehicle could provide the same environmental benefit as a new EV, and should be given the same regulatory credit. That would be the case even if the converted vehicle has limited remaining lifecycle VMT because the EV motor and batteries would probably far outlast the vehicle and could be sold for reuse in another car.

CARB's Clean Cars program seems to be limited in scope to new vehicles, but EV conversion kits could facilitate accelerated retirement of existing ICE engines. Moreover, EV conversion kits could enable low-income drivers, who cannot afford a new car, to share in the economic benefits of EV technology. Government subsidies and financing for EV vehicles might have a much bigger environmental impact, and could better serve less affluent drivers, if they are applied to EV conversions rather than being limited exclusively to new vehicle sales.


[1] Retrofitting Older Cars with Electric Motors Could Transform Transport, Discovery, by Robin Fearon, November 01, 2021
https://www.discovery.com/motor/retrofitting-older-cars-with-electric-motors-could-transform-tra

[2] Converting Your Gas-Powered Car to Electric, Treehugger, by Justin Thomas, May 22, 2022
https://www.treehugger.com/converting-your-car-to-an-electric-vehicle-4858603


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Date and Time Comment Was Submitted 2022-07-13 20:30:33

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