The CARB ZEV loophole big enough to drive a BMW i3 through

Here in California we passed a law requiring a certain percentage of automobile sales from each manufacturer to be zero emissions vehicles, in order for the manufacturer to continue doing business in California.  That simple law has been twisted around in many ways until now it is a complicated mess of special cases.  One of those special cases will allow for a new class of “extended range electric vehicle” (plug-in hybrid) to exist that, even though it has a gasoline engine on-board, will still be qualified for the highly coveted white HOV sticker.  The white HOV sticker is supposed to be reserved for all electric vehicles, making it highly puzzling why the CARB is planning to gift BMW’s i3 (the only qualifying vehicle) with the white HOV stickers.

What’s the deal with the HOV stickers?  They allow someone to drive solo in the high occupancy vehicle (HOV) lane.  This status is a carrots California dangles in front of car buyers to encourage clean vehicle purchases.  The HOV lane has a dual purpose of reducing traffic congestion and reducing air pollution (by reducing traffic congestion).  Because the qualifying vehicles for the HOV sticker are some form of clean vehicle, the air pollution goal is still met even though solo drivers in the HOV lane subverts the traffic congestion goal.

Ten years ago the initial HOV sticker with a gold colored HOV sticker jump started the hybrid car market.  The gold stickers have long ago sold out and are even expired now, and in their place is a white colored sticker for all electric cars, and a green sticker for the plug-in hybrids.  The green PHEV stickers are capped at 40,000 total, while the white BEV stickers are not capped.

We can expect the PHEV stickers to sell out some time in 2013 given the entry of the Chevy Volt, Toyota Prius Plug-in, a couple PHEV’s (Energi) from Ford, and the Honda Accord Plug-in Hybrid.

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In Jan. 2012 the California Air Resources Board (CARB) created a new class of vehicle, the BEVx, which is an electric vehicle carrying a sort of range extender engine.  The CARB published an extensive report which included the BEVx definition (see ADVANCED CLEAN CARS 2012 PROPOSED AMENDMENTS TO THE CALIFORNIA ZERO EMISSION VEHICLE PROGRAM REGULATIONS).

BMW is set to exploit this new class of vehicle with the BMW i3, set to be introduced for sale in 2013.

A subtext in the CARB report (see link above) is the requirement in California to meet a climate change reduction goal in 2050.  The CARB staff has calculated that to meet that goal essentially 100% of California’s light-duty-vehicle fleet must be Zero Emission Vehicles (ZEV’s).  The report presents this pretty chart showing what’s required (expected) to change in the light duty vehicle market in order to reach that goal.

Source – CARB report linked above

The report describes the newest regulations as putting California on the path to meet these targets, and keeping California as the leading place for adoption of these technologies.

In section 2.1.1 the report claims that some manufacturers have lobbied for a new class of vehicle, the BEVx, or “range extended battery electric vehicles.” While the phrasing is similar to words General Motors uses to describe the Chevy Volt, this class of vehicle is expected to be very different. First, it is expected to have an electric range of about 80 miles (or more), and to have a tiny gasoline engine to provide an ability to limp to a charging station. The gas engine is an “auxiliary power unit” (APU) and would “allow drivers to find a charging location, and discouraging non-zero emission driving.”

This is much longer electric range than existing PHEV’s like the Chevy Volt, and should encourage more all-electric miles than do the existing PHEV’s. Saying that “BEVs are expected to play an important role in ARB’s long-term emissions reduction strategy, but the market for current technology BEVs might be limited,” they suggest the BEVx vehicles would give “BEV customers an extra measure of confidence about range, and if successful, would add substantial zero-emission vehicle miles traveled (VMT) to the overall California fleet.”

This is an interesting idea for an interesting class of vehicle.  Is, however, it a ZEV worthy of the white HOV sticker?  BEVx’s are gonna have a gasoline engine on-board which makes my ZEV purist self wrinkle up in anger, but I do recognize it’s a pragmatic design choice just like the other PHEV’s.

The sole qualifying vehicle for the BEVx classification expected to go on sale any time soon is BMW’s i3, which is slated for mass production during 2013.
It appears the final specs for the BMW i3 haven’t been released yet.  While it is an electric car, some versions of that car have been shown with a small gasoline engine for range extension.
While the other automakers (Ford, GM, Honda, Toyota) will be unable to sell PHEV’s that qualify for HOV stickers, BMW is expected to have an i3 PHEV that will qualify.
The basic criteria for the BEVx’s are:
  • the APU range is equal to or less than the all-electric range;
  • engine operation cannot occur until the battery charge has been depleted to the charge-sustaining lower limit;
  • a minimum 80 miles electric range; and
  • super ultra low emission vehicle (SULEV) and zero evaporative emissions compliant and TZEV warranty requirements on the battery system.

About David Herron

David Herron is a writer and software engineer living in Silicon Valley. He primarily writes about electric vehicles, clean energy systems, climate change, peak oil and related issues. When not writing he indulges in software projects and is sometimes employed as a software engineer. David has written for sites like PlugInCars and TorqueNews, and worked for companies like Sun Microsystems and Yahoo.

About David Herron

David Herron is a writer and software engineer living in Silicon Valley. He primarily writes about electric vehicles, clean energy systems, climate change, peak oil and related issues. When not writing he indulges in software projects and is sometimes employed as a software engineer. David has written for sites like PlugInCars and TorqueNews, and worked for companies like Sun Microsystems and Yahoo.

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