ElectroClassic EV
Classic Cars Reborn into the Electric Future

Riding the Diamond

hov_sticker_onblackSince my Porsche 914 is now officially registered with Sacramento as an EV, my next step is to apply for a CAV (Clean Air Vehicle) white sticker, so I can parade down the diamond lane with impunity. The DMV offers an explanation of the white, green, and the now defunct yellow stickers on their website, and the ARB (California Air Resources Board) lists a menagerie of vehicles that are approved for either a CAV white or green sticker. Below are the basic catagories of vehicles that are covered:

ZEVs (Zero Emission Vehicles) – Either pure electric vehicles, such as the Tesla, the Fisker Karma, Ford Focus electric, Nissan Leaf, Coda, etc., or a hydrogen fuel cell car, like the Honda Clarity FCV or the Mercedes F-Cell. All of these models qualify for CAV white stickers.

Enhanced AT-PZEV (Enhanced Advanced Technology Partial Zero Emissions Vehicles) – These are mainly plug-in hybrids that will all get the green sticker. Examples are the Chevy Volt, Ford Fusion, and Toyota Prius Plug-in. Many of the older (non-enhanced) AT-PZEV vehicles that originally met requirements for the yellow sticker will no longer qualify.

ULEV and SULEV (Ultra Low Emissions, and Super Ultra Low Emissions Vehicles) – These are mostly first and second generation CNG or LPG (Compressed Natural Gas or Liquid Propane Gas) vehicles, and all qualify for a white sticker. Some earlier hybrid vehicles also fell in this catagory and got yellow stickers, but will no longer be eligible.

green_yellow_stickerAlso included are vehicles that started as gasoline-burners, and were converted to alternative fuels, like CNG, LPG and ethanol. But to qualify for CAV status, ARB requires the retrofit be performed by a certified manufacturer, which disqualifies any individual who does their own conversion. That rule is confirmed in the first paragraph on this ARB page, underlining their focus on manufacturers:

Certification of Alternative Fuel Retrofit Systems

“…A manufacturer is defined as a person who manufactures or assembles an alternative fuel retrofit system for sale in California. An individual who wishes to convert a vehicle for personal use does not fall under this definition and cannot certify a retrofit system in California.”

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personal account by EV conversion blogger Ken Chiang recounts his ongoing dialog with the Certifications Department at ARB, and included a contact number for an ARB manager. That manager told me that ARB only issues certifications at the behest of the DMV, stating that the DMV ultimately issues the CAV sticker, not ARB.

But finding DMV language that deals explicitly with individual electric conversions was a real challenge. After some serious digging, one fleeting reference turned up on a DMV FAQ (see question #12), stating that an aftermarket electric conversion can only be approved with a letter of certification from ARB. See below:

Conversions of Fuel Type

12. Q: I want to convert my gasoline powered vehicle to a qualifying fuel type so I can qualify for CAV decals. What are the requirements?

A: …”You must obtain a certification from ARB if your vehicle’s motive power was changed as a result of an aftermarket conversion (e.g., gasoline to electric). A copy of the ARB certification letter must be attached to the CAV decal application.”

It’s not explicitly stated, but the ARB requires aftermarket conversions be performed by an ARB certified manufacturer using ARB certified parts.

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There’s a bit of a Catch 22 here, and it goes like this:

The DMV runs the CAV sticker program, but depends on ARB to certify that vehicles meet emission standards before issuing a sticker. Even though the DMV has complete authority to verify and update the registration and title of an individually converted vehicle to pure electric (zero emissions), ARB paradoxically cannot certify that same zero emissions vehicle because their rules exclude individual conversions.

This was a bureaucratic cul de sac, and no amount of reason was going to yield passage to the happy diamond lane beyond. Trial and error is sometimes the best approach, so I filled out the CAV Decal application and mailed it without the required ARB certification letter, just to see what would happen. I also included a brief letter that explained my predicament, and waited for a response.

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About a month later, I excitedly tore into a letter from the DMV, only to find that my CAV sticker application had been returned as incomplete. A single checked box indicated the DMV could not issue the decal until I paid the $8.00 fee. Curiously, the box next to the ARB eligible vehicle requirement was left unchecked. Is that really all they needed? I wrote a check for 8 shmackers and returned the application.

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Another month later, I received yet another notice from the DMV that my application was incomplete, which included my undeposited check for 8 dollars. Here is a condensed list of their new requirements:

  • I must schedule an appointment with a DMV referee, who will inspect the vehicle and hopefully issue a signed Verification of the Manufacturer and Vehicle “Test Group.”
  • The referee will also fill out and sign the enclosed Statement of Facts (REG 256) form, of which, section B allows the vehicle to be smog exempted due to electric motive power.
  • Lastly, a copy of the ARB Executive Order and any Executive Order Attachments which would grant qualifying certification must be returned to Sacramento with the previous two items.

An online search turned up a list of ARB Executive Orders, which covers Zero Emission Vehicles under the Z-series subcategory. The ARB website gave a complete list of contacts for the ZEV program, so I picked a couple that seemed relevant and called them for clarification. The friendly, helpful, and frankly chagrined representatives said that the reference to a Vehicle Test Group indicated the DMV did not understand my vehicle was a conversion, and that the requirement for an ARB Executive Order only applied to manufactured vehicles. This underlines a bug in the DMV’s system that automatically directs CAV applications to ARB without regard to whether the vehicle is an individual conversion, which ARB ultimately cannot process.

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Digging deeper through the Sacramento phone roster led me to John Swanton, an ARB manager whose broad perspective on the EV industry explained the strange incongruities described above. In a nutshell, legislators created the CAV sticker program solely as an incentive for the sale of low-emissions vehicles. There are a limited number of stickers printed for distribution, so auto manufacturers lobby vigorously to protect how and to whom these stickers are issued. These stickers are like gold to an automaker, because diamond lane access could sway a skeptical consumer to become an EV owner for the first time. These sales are critical to automakers, since the federal government requires them to produce and sell a quota of low emissions vehicles, frequently at a loss. So the CAV sticker program is designed to incentivize producers as well as buyers. These measures were designed to spur an entire industry by luring people into buying new EVs, not to reward them for simply owning, driving, or for that matter converting an EV. Given that perpective, why would Sacramento sacrifice a valuable worm to someone who has already swallowed the hook, when there are hungry automakers still fishing for buyers?

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It is understandable that EV converters feel unfairly denied the same privileges afforded to those who buy a manufactured EV. Sadly, Sacramento has not provided any acknowledgement or incentives for the individual who has converted their vehicle to clean fuel with their own money, sweat and time.

But here is a simple solution: The DMV could use the existing Bureau of Automotive Repair (BAR) Referee program to confirm an EV conversion is emissions-free.  A new category is then added to the ARB’s Eligible Vehicles List that includes ZEV conversions that are confirmed by the BAR Referee. ARB can then certify the vehicle, and DMV can issue a sticker. Ironically, the most vocal opponent to this idea will be the EV manufacturers, who are fighting to keep those stickers available to buyers of their own vehicles. Perhaps the state could print a limited extra run of the white stickers solely for EV conversions, or designate a special new color. Metallic gold would be awesome.

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There are many others like me who bear the same opinion. The moderator of EV Club, Ken Chiang, has written a letter to the California state legislature. It pointed out that the state confers rights, privileges and incentives to owners of factory-produced electric vehicles, but not to the owners of EV conversions. Those who fork over the money for a Leaf, Volt, Focus, Coda, or even a Tesla deserve kudos for promoting an exciting new way of driving. But building an EV from scratch demonstrates a serious commitment to solve the problems of zero-emissions motoring, and that commitment should be acknowledged with similar privileges.

During my Sacramento phone tree adventures, it became clear that making a difference in how the state rewards investors in EV technology means taking it directly to the state itself. Lobbying our elected officials is the likeliest way to effect change in these policies.

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California Assembly Member Bob Blumenfield from the 45th District in Van Nuys has made green automotive technology and infrastructure part of his platform. Below are the state bills that he is currently proposing:

AB2405 – Allows single occupant zero-emission vehicles with Clean Air Vehicle stickers free access to carpool lanes that are converted to toll lanes.

AB2502 – Allows car dealers to incorporate the cost of a level 2 charging station into the car loan.

AB2853 – Requires the state to develop a plan to equip state-owned parking lots and Park and Rides with charging stations.

These are all exciting developments, and a step in the right direction, but they don’t address my incentives and privileges as an owner of an EV conversion. I borrowed as much as needed from the aforementioned letter, and wrote my own.

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Providing an ARB Certification Path for ZEV Conversions

Dear California Representative,

I am an Angeleno who promotes clean energy by having converted my own gas-powered car to a zero-emissions electric vehicle (ZEV). I am among a growing number of people who are building or buying aftermarket EV conversions because they cost less to own than a factory EV, and they also represent an environmentally friendly re-use of a vehicle that might otherwise be sent to the scrapheap. An extensive catalog of these converted vehicles can be viewed online at  http://www.evalbum.com.

Current California law offers privileges to consumers of manufactured zero-emission vehicles (ZEVs), but those laws unfairly do not extend to individuals who have converted their own vehicles to zero emissions at their own effort and expense. Those privileges include tax incentives, charging equipment rebates, and access to freeway HOV lanes.

The California DMV promotes the use of low or zero emissions vehicles on our highways by issuing Clean Air Vehicle (CAV) stickers that provide access to HOV lanes. As part of that program, the California Air Resources Board (ARB) is entrusted to certify those vehicles for CAV eligibility.

Understandably, ARB’s mandate is to hold EV manufacturers accountable to clean air standards for the protection of consumers and the general public. But the focus of their CAV certification program is mainly on manufacturing, quality and performance standards for new vehicles and aftermarket parts. They are not oriented or equipped to evaluate the great variety of individual EV conversions that are currently possible. So a path to certification for owners of individual EV conversions has not been provided, excluding them from the same benefits and privileges afforded to the owners of store-bought EVs.

What is the remedy? I propose that individually converted vehicles applying for CAV stickers be directed to the Bureau of Automotive Repair (BAR) referee program for inspection and confirmation of their zero emission status. A new category that includes BAR approved individual conversions can then be added to the ARB List of Eligible Vehicles for CAV certification. This moves the task of dealing with individual vehicles to the BAR, where it is most appropriate, and finally gives individual ZEV conversions a path to certification through ARB.

Furthermore, I would propose that CAV certification for an individual EV conversion would confer the same rights, privileges and tax advantages as those of a manufactured EV, including tax incentives based on conversion costs, as well as relevant discounts on charging equipment and all other existing benefits, present or future.

Please help us amend the law to give individual EV conversions the same benefits and privileges as all other Clean Air Vehicles in our state. Such legislation will help speed the adoption of EVs for a cleaner California and America.

Thank you for your attention in this matter.

Sincerely,

Mark Brems

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Below is a list of California representatives and public servants that were sent this letter. If you own or plan to own an EV conversion, a factory EV, or are just green-minded, you are welcome to use any or all of the above text to lobby for the benefit of all EV owners.

Assembly Member Holly Mitchell, D – Assemblymember.Mitchell@assembly.ca.gov – 54th District

Assembly Member Bob Blumenfield, D – Assemblymember.Blumenfield@assembly.ca.gov - 45th District

Assembly Member Richard Bloom, D – Assemblymember.Bloom@assembly.ca.gov – 50th District

Senator Dianne Feinstein, D – https://www.feinstein.senate.gov/public/index.cfm/e-mail-me

Senator Barbara Boxer, D – http://www.boxer.senate.gov/en/contact/policycomments.cfm

Governor Jerry Brown, D - http://gov.ca.gov/m_contact.php

Caltrans Director Malcolm Dougherty – Caltrans.Director@dot.ca.gov

Acting Secretary, Business, Transportation & Housing Brian P. Kelly - us@bth.ca.gov

Attorney General Kamal Harris, D - http://oag.ca.gov/

Secretary of State Debra Bowen, D – secretary.bowen@sos.ca.gov

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14 Responses to “Riding the Diamond”

  1. When can you come visit my office? We have a new Tesla in my group as well as my Karma….

    Ed

  2. Hi Mark,

    Just read your post, nice research and perspective on the HOV sticker issue for conversions. I had the same sense that ARB has the final say on who gets stickers based on my research too. I like your catch 22 reference of the situation.

    I don’t get the incentive vs. reward description of the sticker program though. Should someone not be incentivized to take a gas car off the roads and converted it to a ZEV? If I want to invest in a clean 100% battery electric car and I am choosing between a Nissan Leaf or convert a classic Porche 911, why should I get the incentive in one case but not the other equally appealing case (if not more appealing for some folks)?If the goal is to get people driving clean electric cars that don’t pollute, it makes sense to incentivize both cases equally. This seems a bit unfair to the small businesses that provide such service to allow only the big manufacturers to have the “reward” of added incentive for consumers to buy their cars, which are equally clean to someone that convert a gas car to electric.

    I know I am twisting your words a bit here, but I think you see my point. Update from me on the letter to the Senator and others. Have you heard anything? I did get an interesting comment Here:

    http://blog.mr2ev.com/hov-stickers-to-be-extended-for-electric-cars-in-california-until-2020-but-not-for-conversions/#comment-1119

    If we can find a way to get our cars certified by ARB efficiently, then we can officially get the certification letter from ARB and get the stickers no problem. The tough sell is within ARB to work with us individuals to qualify our cars, seems too expensive for them to dedicate staff for this.

    Let’s keep working on this to see if we can find a solution.

    • Hey Ken,

      Just a couple things in response to the above.

      First, the CAV stickers are limited in number, and are coveted more by the commercial EV makers than by the individual EV owner. This program is designed to lend a sales advantage to manufacturers, and kick start the sales of EVs in California on a large scale – nothing more. Getting you to work 10 minutes earlier using the diamond lane is not their concern. In fact, I’m sure that falls under an entirely different department.

      It may be unfair to the small business that does a limited number of conversions per year, but the state isn’t really concerned with incentivizing the sales of vehicles on such a small scale. They really want to see the widespread adoption of commercially manufactured EVs on a large scale.

      I do think that small fry like us should be offered some sort of incentive to convert vehicles to ZEVs. I think the issue is just a matter of emphasis at this point. This is all so new, and moving so quickly, that the entry of large EV makers into the arena has totally changed the game and made greater demands on ARB. Public perception is that EV sales are meager, and the EV economy is teetering, so the state is going to do what it needs to get this party started.

      I really think that getting vehicles qualified through ARB’s existing relationship to the Bureau of Automotive Repair is the way to go. In the case of an EV conversion kit, the BAR is also used to confirm that a manufacturer’s parts all work as advertised before they approve, and ARB can certify the product line for CAV status. The ARB is not equipped to deal directly with real life vehicles, which is why they are sent to BAR for any hands-on testing.

      I contend that legislation can be written to allow ARB’s List of Eligible Vehicles to include an additional category for “Conversions that have been confirmed as zero emissions vehicles by BAR.” Agents of the ARB will say that that testing by BAR is too expensive to make it worth performing on one vehicle alone (rather than by a manufacturer on an entire product line). But I think legislation could be passed to simplify tests for pure electric conversions, and provide a different fee structure for one-off conversions.

      Thanks for the link above – very helpful and informative. This is a lively conversation. I wonder where it will go!

      Best
      Mark

    • Hey Ken,

      My impression is that the ARB cannot act on it’s own, and that any change to the system will need to be legislative. I think our battle cry to our elected officials should be “Add one-off EV conversions that pass BAR inspection to the ARB Eligible Vehicle List.” That process at BAR has already been established to approve manufactured conversion kits and parts for certification. That process should be streamlined, simplified, and made available to individual converters at a reduced cost.

      • I agree. Have you sent your letter to your congressman? I’ve not heard anything.

      • I’ve received some electronic receipts for the emails I sent, but no reply except for a form letter from Kamala Harris’ office stating the role of the Attorney General, and a suggestion to contact my representatives.

  3. I got a set of white (silver) stickers for my converted miata back in 2010: http://evmiata.blogspot.com/2010/01/zev-stickers.html?m=1 I was initially denied then sent in the form again with my BAR report and a nice letter explaining that my car was a conversion. Maybe they just didn’t know they were suppose to deny me? Or maybe it was a “Miracle on 34th Street” moment – “if the California Bureau of Automotive Repair, a department of the State of California DMV recognizes this vehicle as electric then how can the ARB to deny this claim?”

    • Thanks Pat,

      I admire your persistence. I suppose I could take another whack at it and set up an appointment with a BAR referee, then send in the DMV application again. The sticker at this point would be more a badge of honor and accomplishment rather than of any use on the freeways where I live. If they did issue a sticker to me, I would like to think that it would provide a clear and reliable path for other converters to also get stickers. But my experience so far is that the state officials don’t really have any set procedure to deal with us.

      Mark

  4. Hey mark this is off topic, however I could not get a good email address for you. We met at the Santa Monica Alt Car Expo, we chatted about your car and my 40kw Kart that I am building. Since I have started to work on a really cool project called Zero South. We are looking for volunteers to help convert the first Zero-Fossil fuel vehicle to the South Pole. Please see link for details.

    Thanks,
    Brock

  5. This is all very disappointing… I just finished covering my Honda Civic to electric, and I love it! However, it sure would be great to be able to use the carpool lane. After the DMV inspection and BAR “alternative fuel verification” inspection the car is fully classified as an EV, though they won’t issue a CAV sticker as a 1996 Honda Civic EV is not on their list…

    • I was also given the reason that the quantity of stickers are limited, and so they need to dole them out carefully to those who actually were incentivized to buy an electric vehicle. But I have also gained information (much after the fact) that this only applies to the green HOV stickers, and that the white stickers are unlimited.

      Since I am able to park in the best spots as an EV, I completely lost interest in banging my head on the diamond sticker wall.


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