A BEV is a Zero Emission Vehicle (ZEV). Industry people understand that a BEV must meet all vehicle safety regulations (FMVSS). That makes sense. But the vehicle emits (virtually) no emissions. At least, not from the vehicle. So, how tough could it be to receive EPA (CoC) and ARB (EO) documents?
It turns out that, there is still significant work required to earn agency documentation, certifying that the vehicle does indeed, comply with emission related regulations.
Pilot Systems recently won a contract to lead a vehicle manufacturer, of a fully electric vocational delivery truck, through EPA and CARB emission certification.
As with the certification of an ICE (Internal Combustion Engine) vehicle, a certification plan must be developed and approved by EPA and ARB. An EV Cert Plan still identifies applicable regulations and explains how the OEM intends to comply with these regulations.
First, Pilot, working with the OEM and EPA, developed a cert plan. In a matter of weeks, an EPA Certificate of Compliance (CoC) was awarded to the OEM. As it happens, this was the first ever CoC earned for a Class 3 BEV.
Next, Pilot worked to earn an Executive Order (EO) from California’s Air Resources Board (CARB). Again, Pilot worked with the OEM and the agency to agree on the ARB regulations that would apply to this vehicle. Pilot then developed a Cert Plan to accomplish compliance.
For ARB, vehicle testing was required, primarily to determine the EV mileage range of the vehicle. This required that the vehicle be “stabilized” (2000 miles of “representative” vehicle operation). Next, testing was performed to determine the “drag coefficients” of the vehicle (RLCD). These are needed to program the dynamometer at the RD (Range Determination) testing facility. Once this was completed, we moved the vehicle to a “1066” compliant test facility and conducted RD testing (remaining consistent with the Cert Plan).
Once this is complete, a significant submittal of documents will be made to ARB’s document management system. We expect the OEM to have their EO by the end of June 2020.
Areas of Expertise: Pilot Systems' Senior Emission (EPA & CARB) and Safety (FMVSS) engineers are available to speak with you. A broad range of support is available; from benchmarking, to product development, to Cert plan writing and submission, to coordination of vehicle testing, to completion of Certificate of Conformity (EPA) and Executive Order (CARB) submittals.