PHEV Tax Credit Question

Re: Enginer PHEV Technical Information

Enginer is working on a kit for Gen 3 Prius. Not sure aboiut the tax credit.

 

Re: Enginer PHEV Technical Information

The tax credit will be 10% of the cost of the kit and installation.

 

Re: Enginer PHEV Technical Information

Is the Tax credit a dollar for dollar off your taxes and result in a refund if you owe less then the amount of the credit? In other words, say you only owe $100 in taxes to the fed for the year, and you spent 3 grand on making your car a PHEV, would you then be getting a $200 check from the fed?

 

Re: Enginer PHEV Technical Information

Review thread PHEV Tax Credit question and check out the links they give.

 

Just wanted to revive this old thread since I've been getting some PHEV tax-related questions.

MJFrog pointed out a more detailed thread about PHEV Tax credits.
Be sure to check it out and ask your questions there.

 

Hey Guys,

As far as I can tell, in order to qualify for the federal tax credit the system must be FCC, SAE and CARB certified. This means it must undergo federal crash testing, federal emissions testing, federal electro-magnetic interference testing and general vehicle safety / stability testing. I believe at least some of the components used in the conversion must be UL (Underwriters Laboratory) certified for sale in the US (for example, the battery charger, DC DC converter)...

Also as far as I know, Hymotion is the only conversion system on the market to have completed all of these tests so far thus I believe it is the only one to qualify for said tax credit. I believe there was some sort of lobbying going on on behalf of Hymotion to get the definition of an accepted PHEV conversion tweaked to prevent competing conversion kits from qualifying (though don't quote me on that, I could have been mistaken)...

Oh, and the battery pack must be at least 5 kWhr to qualify...Anyone else find that ironic that the minimum requirement is the size of the Hymotion battery?

Anyway, I would check into this a lot more before relying on the tax credit option. It could be that some of these clauses are not actually enforced, though unfortunately I think a lot of people will be upset when they try and file for tax credits in April...

Andrew

 

Hymotion L5 is about 5kWh. I believe it is a little less than 5kWh. It did managed to qualify for the 10% PHEV tax credit.

 

Do you have a link for this requirement?

 

Hi Guys,

Here is the link to the HEV America guidelines for electric vehicles:
http://www1.eere.energy.gov/vehiclesandfuels/avta/pdfs/hev/hev_techspecs_final.pdf

Notable quote from this PDF:
"The U.S. Department of Energy recognizes the HEV America program as requisite for funding of programs involving HEVs."

Here is the expanded information page from the IRS:
Internal Revenue Bulletin - June 29, 2009 - Notice 2009-54

The certification processes mentioned on the IRS website include HEV America standard compliance--at least that's what I gather from said documents. It also mentions the requirements for the Clean Air act compliance, California Air and Resource Board compliance and federal safety testing (crash and stability testing).

This means that the only conversion on the market that would qualify would be Hymotion at present (at least, they claim compliance, I guess we'll find out in April). I know Plugin Conversions is working on compliance, but sadly I don't think I can claim the 10% tax credit for my system at this time.

I'm not a lawyer so don't quote me on any of this, but this is my understanding of the situation.

Andrew

 

As near as I can tell, the IRS information you linked to is in regards to a NEW vehicle, not a conversion kit.
I don't see any specific references to conversion kits on the IRS page you linked.

 

I believe that the standards for qualified plugin electric hybrid vehicles are very similar to those for straight up electric vehicles since they are technically electric vehicles for short trips...Thus, to qualify for an IRS tax credit I am assuming that the conversion in question must meet the requirements as defined by HEV America. Again, I'm not a lawyer...Perhaps you should contact the IRS directly?

Anyway, that is the document that Hymotion links to for their tax credit.

Andrew

 

Mmm, I stand corrected. The IRS link I sent was to the definition of a "Qualified Plugin Vehicle".

The actual document that contains the bit about conversion kits is:

Vehicle Credits

But, it says that only conversion kits that convert the vehicle into a "qualified plugin vehicle" are eligible for said tax credit, thus it is still required to meet the criteria listed in the original link I sent--I believe. Phew. I hate legalese...

Andrew

 

From the document you linked (bold added):

This would seem to disqualify my 2kwh Enginer conversion...unless I can count the OEM capacity too?

 

Hmmm, I don't know if you can count the OEM battery since it's not technically a part of the conversion /persay/...an interesting point though.

I would be more concerned about qualification from things like crash testing and UL certification. Does anyone know if the Enginer charger or DC/DC converter are UL certified for sale in the US?

Andrew

 

• Was purchased for your use and not for resale;
• Is made by a manufacturer;
• Is manufactured primarily for use on public streets, roads, and highways;

I would question these points. To me, this reads to mean the new vehicle manufactured as a PHEV, and not a conversion. There seems to be more detail in Internal Revenue Bulletin - June 29, 2009 - Notice 2009-54 found just below that block of text that's linked.

It seems... murky, about whether this can used for a conversion. The text is fairly ambiguous, and it may be worth trying. At least until you get audited .

 

Those points would relate to a new PHEV vehicle made from an OEM manufacturer, and are accordingly listed under said category (besides, the OEM Prius will comply with those requirements anyway, you aren't changing those points by installing an after-market conversion). The point of interest is that the small section actually related to plugin /conversion/ kits requires the kit to bring the vehicle up to a "qualified plugin hybrid electric vehicle" standard which includes CARB, crash and FCC testing at a bare minimum (and I still believe up to the SAE standards outlined by HEV America as a pre-requisite for Department of Energy funding)...and I'm almost positive the high voltage electronics need to be UL certified for safety and sale in the US.

Crash testing is a big area where I see problems for the majority of the conversions out there as Hymotion is the only one to have passed so far (to my knowledge). The original Hymotion battery box failed crash testing miserably because it went too far toward the back end of the vehicle and interfered with the crumple zone of the trunk. They had to completely redesign the box and make it significantly shorter in order to keep it out of the crumple zone to pass. This means that conversions like Enginer, which use the entire trunk area, have a significant design problem in this area...Don't forget that after the vehicle is crashed they will turn the vehicle completely over and see if /anything/ falls out of the trunk.

I hate to sound so skeptical, but I don't think it's realistic to expect all conversions to qualify for the rebate. I know I'd love for mine to, but not all conversion companies have the resources available to them that Hymotion does (eg, the full backing of a multi-million dollar battery manufacturer [A123] that makes batteries for the big boy car companies). I know some companies are working on it, but it takes a lot of resources and planning to fully comply with all these regulations. Even Hymotion had to try several times before they got it right.

That said, I see no reason not to try to qualify, but I also see no reason to get your expectations and hopes up. These standards, while annoying (and expensive...) to comply with, serve a very important function to keep these sorts of things safe on the road so that people don't get hurt.

Andrew

 

Note: I was not one whom originally posted those bulleted points above yonder, merely replying to them. However, the only text on that page that seems to relate to a conversion is

I don't really see where any of the regulatory information pertaining to crash testing is included anywhere in there? It basically looks like ONLY OEM offerings are going to get the 2500-15000 credit offering, where a conversion is worth 10% total conversion cost. It'd be great if you could get something like 3200 back for installing an 8kwh enginer kit valued at 5200, but it looks like it will only ever qualify for 10%. Except, maybe, if an individual state decides to start offering rebates? Isn't that what's happened in Florida in regards to the hymotion kit? We're talking about federal guidelines here though.

 

The regulatory information is in the terminology. The term "qualified plug-in drive electric vehicle" refers to a conceptual product that meets said criteria (see the documents previously linked to for the department of Energy's definition of "qualified plug-in drive electric vehicle"). If you think about it, the government needs some way to establish that the kit they are providing a tax rebate for isn't going to make the roads less safe or end up /increasing/ emissions (as some sadly do).

Generally the way things work in the emissions world is that most states implement the policies laid out by CARB (California Air and Resource Board) over time, thus I would expect most other state tax rebates also require similar certifications.

Andrew

 

Hi Guys,

I tried to contact the IRS directly today but I got lost in their phone web...labyrinth....I think I may have accidentally filed for my tax returns during the whole ordeal actually.

Anyway, since I couldn't get a hold of a real person, I did more research on their website for this particular tax credit option. What I discovered was that there are two other documents of interest.

First, this is the instruction information for filing for the alternative fuel tax credit:

http://www.irs.gov/pub/irs-pdf/i8910.pdf

At the bottom of page -2-, you can see the section for qualified plugin hybrid electric vehicles. This redirects you to section 30B of the IRS bulletin 2006-9 which is available below:

http://www.irs.gov/pub/irs-irbs/irb06-06.pdf

If you scroll down to page 23 of the PDF (414 of the actual document) you can see the parts about qualified hybrid vehicles. Since the term "plug" or "phev" or anything of the sort did not show up in the entire document, I assume they lumped them together with hybrids.

If you read through the page, around the middle there is a section (1) All Vehicles, that contains information that is associated with all vehicles covered by said tax credit. Under this header we find three things of interest:

1) (section i, j, k) Mandatory CARB and Clean Air compliance and proof (statement and copy of certification) of said compliance. To my knowledge, Hymotion is the only conversion that has this certification (Since people asked, Enginer does not have this at this point and I'm pretty sure they have to have the tests completed and passed by the time of installation--sorry folks). In order to comply with CARB standards, Enginer will likely need to disable / remove the OEM EV mode switch.

2) (section L) Mandatory safety compliance. This links to the following document:

Title 49, United States Code Chapter 301 Motor Vehicle Safety

In short, this requires safety inspection of said conversion system post installation and no doubt requires federal crash testing approval. It also requires proof (statement and I would assume copy of certification) of compliance with said safety standards. Again, Hymotion is the only conversion that has this certification to my knowledge (Again, sorry folks--I don't believe Enginer has this at this point. The way their box is designed it's near impossible to pass crash testing due to the way it interacts with the crumple zone in the trunk. You see, they turn the vehicle up-side-down after the actual impact and if anything falls into the cabin area it's grounds for immediate failure). It requires compliance with all safety standards listed on that website (articles 30101 - 30169).

3) (section m) "A declaration, applicable to the certification and any accompanying documents, signed by a person currently authorized to bind the manufacturer (or, in the case of a foreign vehicle manufacturer, it domestic distributor) in these matters, in the following form:
Under penalties of perjury, I declare that I have examined this certification, including accompanying documents, and to the best of my knowledge and belief, the facts presented in support of this certification are true, correct, and complete."

I'm no lawyer, but I think that means they won't be happy if someone were to lie about compliance with the above requirements...I'd rather not be on the bad side of the IRS.

Conclusion:
Sorry to burst any bubbles and/or shatter any specific dreams but I thought you guys would want to know: Unless you're buying a Hymotion system, I wouldn't expect to see a tax credit.

In order to qualify for federal tax credit, the conversion must be CARB certified and safety (crash) tested.

Disclaimer:
I am not a lawyer, nor do I have any aspirations to be one. I interpreted the information I found in a manner I believed to be realistic and correct based on what I know about hybrids and federal standards. I could be wrong.

Side note to Hymotion customers:
Has Hymotion provided you with any sort of certification documents for filing with your taxes? According to this, I think they should be...I guess I just assumed that Hymotion went through all the hurdles necessary, you guys may want to follow up and check with the IRS and Hymotion directly too before filing.

Andrew