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A cleaner way to drive

HOV stickers to be extended for electric cars in California until 2020 but not for conversions yet.

HOV lane white sticker for CalifoniaThe white HOV sticker program that allow electric cars to use High Occupancy Vehicle (HOV) lanes in California at anytime is to be extended until 2020.  The bill has just passed the assembly and is on its way to the Senate.



How about converted electric cars?

But not for converted electric cars it seems. I’ve been unsuccessful at getting my sticker despite hearing success stories from fellow EAA members about getting their stickers. Here are a few EVs sporting these stickers:
electric porche with white HOV sticker      electric vw bug with white hov sticker      electric passat with white HOV sticker


The Facts
Since this seemed to be a fairly inconsistent process, I wanted to get the facts on the program.


What I’ve done

  • I’ve contacted CARB and here’s their response.  Essentially, one-off conversions like mine are not eligible unless I go through a cost prohibitive certification procedure.
  • I took it a step further with encouragement from fellow EAASV members and tried to get Senator Joe Simitian to help.  Unfortunately, the Senator termed out last year but the staffer suggested to go after legislative change, here is his letter.  Per his suggestion, I did contact Senator Corbet’s office, but nothing substantial has come of it.
  • Earlier this year, I found out about assemblyman Blumenfield’s bill AB266 to extend the sunset of the HOV stickers for zero emissions vehicles until 2020.  I thus contacted his office to see if it would be possible to add language to include converted battery electric cars in his bill and here is his staffer, Anthony Matthew’s response.  There seems to be some confusion around the word “conversion” in his argument that some conversions have shown to pollute more.
  • Per suggestion from Mr. Matthew’s, after reading the debate cited in his email, I called the Assembly Transportation Committee’s Senior consultant, Victoria Alvarez.  She was really supportive of my issue and gave suggestions that it may be too risky to request amendment to the existing AB266 bill in the Senate in June.


Next Steps

Rather than risk delaying the passing of AB266 in the Senate, Ms. Alvarez suggested that I reach out to congress to propose a new bill in FY14 that would make these converted zero emissions vehicles eligible for the HOV sticker program.  With that in mind, I’ve drafted the following letter to encourage such a proposal.

Dear __________:

AB266 extends the sunset for white HOV stickers for certain zero emission vehicles until Jan 2020. However, it excludes converted zero emissions vehicles, specifically 100% battery electric vehicles that have been converted. I am proposing that these converted zero emissions 100% battery electric vehicles also be considered eligible for white HOV stickers.

Benefits of the proposal

1. The spirit these incentives is to motivate the consumer to invest in clean energy transportation to help cut back on air pollution. Every converted 100% battery electric car takes a polluting gas car off the California roadways and replaces it with a zero emissions vehicle and therefore supports this.

2. While 100% electric cars are still more expensive compared to their equivalent gas cars. Conversions bridge a critical gap between what certain percentages of the population can afford to buy when looking for an electric car.

Arguments against proposal and counter arguments

1. Converted 100% battery electric vehicles are not certified by CARB to be durable for use on California freeways and can lead to more degradation of HOV lanes.

Counter argument: There are many examples of converted cars that have been driving on the California highways (see them on including my electric MR2, which I’ve been commuting in for 50 miles a day for 2 years on I580 in the Bay Area. Despite the lower cost, these conversions take time and effort, the numbers are significantly lower than those of manufactured electric cars. Therefore, their contribution to HOV lane degradation is likely negligible compared to manufactured electric cars. That said, less prevalence should not mean exclusion from the same incentive if that incentive is based on motive power and emissions.

2. Modified vehicles do not have standard emissions rates with the same converter technology, and there is evidence that some converters make some cars pollute more than before they were modified.

Counter argument: While this may be true for after market plug-in hybrid electric cars, it is physically impossible for 100% battery electric cars to have any emissions and thus is not true for 100% battery electric cars.

A number of us from the Electric Auto Association of Silicon Valley ( would be willing to meet with you to answer any questions you may have on this proposal.

Thanks for your consideration,


Ken Chiang

I am not sure whether my attempt will be successful, but since the program will be extended to 2020, I think it is worth the effort. Thanks to those that have been offering great suggestions at EAASV AND PLUGIN AMERICA.  Jerry and Ron, your support has been truly helpful in this.

Suggestions and thoughts on my approach welcome and highly suggested.  You can email me at ken[at] or post comments below.  Also, I encourage you to write your congressman and suggest such proposal in FY14.

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Posted in HOV stickers, MR2EV

11 Responses to “HOV stickers to be extended for electric cars in California until 2020 but not for conversions yet.”

  • Cor says:

    Hi Ken,
    I ran into exactly the same issue trying to get the HOV stickers for my EV.
    The DMV apparently is using a different definition of “qualifying vehicles” today, where int he past they simply looked at whether the vehicle was powered by electricity, today they only allow HOV stickers for vehicles on a list. The manufacturer must provide some certification to get on that list, but the law does not mention such a requirement, so I feel that it is just some form of stonewalling. It is unfair to the vehicle owners for which the manufacturer cannot or does not want to certify the vehicle and certainly to the individuals who convert a vehicle to electric as they will not be able to certify it, while they should have a qualifying vehicle according to the law, but not DMV. So the DMV needs to be instructed to remove that burden and accept any Freeway capable vehicle that is powered by electricity alone, problem solved.

    • Ken says:


      Thanks for sharing, yes, I did notice from talking to folks that did get the stickers that the REG 1000 form actually changed fairly recently to include a box for conversions. I agree that DMV need to base qualification of vehicle based on motive power. If we can only get CARB to see it the same way as they are the ones that have instructed DMV to consult CARB’s eligibility list prior to granting privilege.

  • KO says:

    Ken; So. DId you send that letter? and if so to whom?
    I’ve done lobbying before. Best to get several groups to go up to Sacto with some AB that some rep has accepted to submit and curry support from every rep you can think of ..the clean air guys, the ca industry guys [if it weren't for DIY EVs there would be no Teslas, as that's how Tesla started- let's get the figure for how much California taxes are tacked onto the sale of each one] How leading EV component suppliers and EMPLOYERs have moved OUT of the state due to limited support from state of cal not recognizing EVs.] How much pollution is prevented by DIY EV and for HOW MANY YEARS? some since the ’70′s. We should get emission credits!! You know all those good stats.
    Talk to the road guys, that hotdog guy from Concord! EVs do not emit road dissolving exhaust. DE Saulinier, I’ve been talking to him for years. gotta keep trying.
    Find any tenuous connection to whatever committee whomever you are visiting sits on
    Point out how grateful Nisson was to get feedback for EV builders and first batch LEAF owners and use those ideas on their new model. A free think tank we are!
    Then every one take one point and present that one point – that’s why you have to go in a group. get one group per week up there and we may have a chance!
    Media humiliation seems to work well too..

    • Ken says:

      I’ve sent the letter to Senator Corbett since I live in Alameda County but have not heard anything back (it has been a couple of weeks). I’ve also sent the letter to Victoria Alvarez, whom I mentioned in my post to have offered to help and getting this to the folks on the transportation committee. I will follow up with her next week. Depending on how that goes, I plan on sending it to Assemblyman Bill Quirk as well. I don’t think it would hurt to get as many folks to send letters to their congressmen. thoughts?

  • dan says:

    Living in CA, I found this relevant to my interests. I did some digging around and I think you’d have better luck in using the DMV rules to fix the issue rather than getting Sacto to write some new rules which they will undoubtably screw up even further…

    Since you’re converting an existing car, perhaps you should take a glance at the following page: in particular, the Engine Change Section… to quote the relevant passages

    “Vehicles converted to 100% electric drive, with all power supplied by on-board batteries are considered in compliance with the engine change requirements.”


    “After an engine change, vehicles must first be inspected by a state referee station. The vehicle will be inspected to ensure that all the equipment required is in place, and vehicle will be emissions tested subject to the specifications of the installed engine.”

    So if I’m reading this correctly, a state referee station must test for emissions based on a ZEV engine.

    From post #7 the ARB rep states “The certification tests require the vehicle to follow a typical vehicle use pattern on a dyno that covers a certain distance and certain sustained speeds. So many electric vehicles, especially low-speed ones, cannot be certified as a full featured “ZEV”.

    The testing that the cars need to undergo appears to be based on the FTP-75 cycle of which specs can be found here:

    Sounds to me like if you can meet the testing requirements, then state referee station must certify your vehicle as a conversion that meets the ZEV requirements, which can then be used to get the appropriate sticker – especially if the CA ARB writes an exception from the “list” on their letterhead.

    Of course the DMV *might* have a slightly different viewpoint. :-)

    • Ken says:

      Hi Dan,

      CA ARB is in the process of certifying a couple of conversion kits to be eligible for HOV stickers I hear. I asked the question on whether I could go through the certification procedure on my MR2 despite their warning that the procedure is likely cost prohibitive for the individual. I haven’t heard anything for quite some time.
      Thanks for the pointers to the test specs.

    • Mark Brems says:

      I was able to get my title and registration updated to Motive Power = E (electric) by an on-site inspector at the DMV. Printed out a new registration on the spot without having to go to a referee.

      The solution would be lobbying for an addition to the ARB List that included vehicles inspected and confirmed by the BAR referee as ZEV. Unless you know of a way to get the ARB to exempt the EV conversion from the List. How would that work?

      • Mark Brems says:

        Addendum – I was told by John Swanton at ARB that pure electric vehicles aren’t necessarily exempt from ARB requirements simply by virtue that they have no emissions. You ask: “Why would the Air Resources Board need to certify a zero emissions vehicle?” Because they factor in the amount of emissions created in producing the electricity. So they take into account the amount of electrical power it takes to charge the vehicle vs. the amount of use you get from the vehicle per charge. If your electric vehicle is below a certain level of efficiency, I assume it will fail. Again, we are talking about attempts by manufacturers to certify their conversion kits.


  • Mark Brems says:

    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. To think that the CAV stickers are being offered to end users as a generous gift from the state misses the point that this program is designed to lend a market advantage to manufacturers, and kick start the sales of EVs in California – 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.

    The referee program is part of the BAR (Bureau of Automotive Repair), which is routinely used to check special case vehicles individually for smog compliance in their fully equipped garages. My Ford pickup needed to be checked because the gas filler hose offered by Ford as a replacement was not the original stock part (which Ford no longer makes). The point is that once the car’s fuel/power/exhaust system is altered in any way, it needs to go to the BAR referee for smog certification before DMV can renew the registration.

    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 links above – very helpful and informative. This is a lively conversation. I wonder where it will go!


  • Mark Brems says:

    One real concern I have about all this is that we don’t end up shooting ourselves in the foot. The DMV will inspect your vehicle and update your registration to “electric,” exempting you from smog checks, and guaranteeing your registration renewal every year. It’s pretty simple.

    But if we start creating a fuss, it’s very possible that they will respond by throwing up more hoops that we must jump through before we are allowed back on the road: Are the battery racks of a certain strength?; Are the anchor points approved for this vehicle?; Is the motor mount properly installed in an approved way? If you don’t pass, your registration is not updated to electric, and you will not pass any future smog test, because the engine is not original. It could be a nightmare.


  • Ken says:

    Thanks for sharing this insight from John Swanton, though I think most converted electric cars can achieve an efficiency equivalent to those manufactured cars pretty easily. Take my MR2 for example, I have a 26kwh pack and can drive 70 to 90 miles with 20% charge remaining. The calculations comes out to between 230 – 297 wh/mile.

    Compare this with the Tesla Model S, the 85 kwh pack can do 260-300 miles. Assume they also have 20% charge left after driving the distance, their efficiency is 226 – 261 wh/mile. The efficiencies are comparable I think. How about your Porche?

    Regarding your point on charging source, in spirit, I think it makes sense to consider, if they did that, then my electric MR2 would pass easily because it charges off solar panels. However, it is impossible for ARB or DMV for that matter to enforce the source of charging for EVs.

    Mark, good suggestions on the legislation to explicitly include a “conversions” category on the CARB eligibility list that would only require BAR testing for zero emissions. It does make sense to push for this. You are right to worry about this backfiring and making the process for cumbersome for conversions to get an “E” classification, but I think that if they did that they’d be doing their job to better ensure the safety of motorists and thus reduce the risk that the converted EV will fall apart in use. Have you sent in your letter to your congressman yet? I’ve not heard anything.

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