http://autos.groups.yahoo.com/group/calcars-news/message/780
Click the link above to read the full document along with other observations. Here is the Memo copied from that link:
FULL TEXT OF TOYOTA'S MEMO "PHEV CONVERSIONS"
Charles E. Ing, Director, Government Affairs Toyota Motor North America
Both with respect to safety and emissions, PHEV converters should
comply with existing standards governing second stage manufacturers,
if applicable, and, NHTSA and EPA should be required to establish new
regulations for certification of conversions of used vehicles. In
other words, the product liability and warranty risk, should be
assumed by the converter. The government should assure that there be
no degradation in emissions and vehicle safety before it provides
taxpayer incentives.
Following are the reasons why:
Based on Argonne National Lab testing of two converted Prius hybrids
to PHEVs -- the Hymotion and Energy CS PHEV conversions -- both
generate significantly higher NOx and total HC emissions when
compared to a stock Prius. This is particularly evident after cold
start, when Prius emissions are virtually zero. (See the attached
chart.) This raises the question of whether the government should be
paying people to make their cars dirtier?
The primary problem with plug-in hybrid electric conversions (PHEV
conversions) is that the modifications to the factory-built vehicle
take the vehicle out of compliance with the Federal Motor Vehicle
Safety Standards ("FMVSS"). After-market converters do not perform
crash testing to certify that the converted vehicle meets or exceeds
FMVSS. The risk is highest in terms of rear-end collisions because
these vehicles are generally converted by adding a substantial number
of batteries in the trunk or cargo section of the vehicle.
General potential risks are as follows:
Increased Risk of Fire:
Toyota equips its hybrid vehicles with nickel metal hydride
batteries. PHEV conversion vehicles are typically equipped with
either lithium-ion batteries or lead-acid batteries. Lithium-ion
batteries carry a higher risk of fire. Toyota recently decided
against using lithium-ion batteries in the next generation of hybrid
vehicles due to concerns that these batteries can overheat and catch
fire. Similarly, lead-acid batteries contain sulfuric acid which can
escape the battery and can burn occupants in an accident.
Other Increased Risk of Injury in an Accident:
Because the converted vehicles are not tested for compliance with
FMVSS 301, which deals with fuel tank integrity and related
crashworthiness issues, there is a risk that the aftermarket
batteries can compromise the fuel system and/or crashworthiness. This
can happen due to the composition of the batteries as well as the
added weight and placement of the batteries in the trunk/cargo area.
The mass of these batteries can often extend into the zone of the
rear bumper, increasing safety concerns. These added batteries can
become projectiles in an accident.
Adverse Effect on Rear Suspension:
Because these batteries often weigh hundreds of pounds in total and
add weight to the rear of the vehicle, the rear suspension and
handling and stability of the vehicle is compromised, increasing the
risk of accident.
Compromised PowerTrain/Voiding of Warranty:
In order to add the extra battery capacity, converters have to hack
into and modify the software in the hybrid's Engine Control Module.
Such modification may damage the battery pack and engine; it also
voids the express warranty provided by Toyota at the point of sale.
Increased Risk of Electrical Shock:
PHEV conversions are generally used with a home outlet. However, we
are aware of no testing (such as compliance with UL standards) done
to ensure compatibility between these batteries and home electrical
wiring. This poses a risk of electrical shock and even fire.
Removal of Spare Tire:
Many converters use the entirety of the trunk and cargo area and
either remove the spare tire completely or make it inaccessible. This
poses a risk in the event of a flat tire in an emergency situation.
Noncompliance With EPA Regulations:
Toyota's hybrid vehicles are compliant with EPA regulations on
emissions. To the extent hybrid plug-in converters interfere with the
ECM and the vehicle's emissions, the vehicle may then not be in
compliance with EPA regulations.
Toyota Reveals Concerns on Prius Conversions
Discussion in 'Prius, Hybrid, EV and Alt-Fuel News' started by priusFTW, Jun 29, 2007.
Comments
Discussion in 'Prius, Hybrid, EV and Alt-Fuel News' started by priusFTW, Jun 29, 2007.
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