Comments on IEPR Commissioner Workshop on Transportation Trends and Light-Duty Zero-Emission Vehicle Market Update

On July 2, the CHBC submitted comments to the California Energy Commission on the June 11 and June 12 IEPR Update workshops focused on Transportation Trends and a Light-Duty Zero-Emission Vehicle Market Update. The CHBC comments focused on the opportunities and policy issues related to accelerating light duty hydrogen fuel cell electric vehicles, as well as scaling of hydrogen production. The comments are summarized below and elaborated on here >>
  1. Strongly agree with comments made throughout the workshops that both types of zero emissions electric vehicle (ZEV) technologies – hydrogen fuel cell electric vehicles (FCEV) and battery electric vehicles (BEV) – are necessary to achieve California’s policy goals, and that reflecting this, policy discussions focused on ZEVs should include both technologies.
  2. In light of panelist consensus in Session 1 on Light-Duty ZEV Update and Trends in Larger Vehicles that popularity of SUVs and Cross-Over SUVs are a general market trend, it is important to consider global analysts’ forecasts that hydrogen fuel cell technology will be more cost effective than battery electric options in the next 5-10 years for this type of vehicle, among others.
  3. FCEVs will be key to enabling equitable and affordable access to ZEVs because multi-unit dwellings and on-street parking do not typically provide easy access to EV charging, making centralized hydrogen the more pragmatic ZEV fueling option for many Californians, including many, if not most, low-income drivers.
  4. FCEVs have superior range among ZEVs, with all models offering over 300-mile range – an important element for consumers – and lower greenhouse gas emissions at higher ranges than BEV counterparts – an important factor for the climate.
  5. FCEVs allow for far faster refueling than BEVs, making them more convenient for commuters, taxis, ride sharing fleets, and others who don’t have time to wait and compete for charging.
  6. As CARB found in their SB 498 report on state ZEV programs, public funding ought to be extended beyond the AB 8 sunset date of January 1, 2024 and beyond the legislation’s station limit of 100 stations, in order to reach the state Executive order goal of 200 hydrogen stations by 2025 and the California Fuel Cell Partnership Goal of 1,000 stations by 2030.
  7. Like with any emerging technology, cost reductions of FCEVs and fueling will come with scale driven by consistent policy support, especially as the market is maturing.