CHBC Submits Comments to CARB on Innovative Clean Transit Regulation
July 27, 2018 – The California Hydrogen Business Council (CHBC) submitted comments to the California Air Resources Board (CARB) to express our support for the proposed ICT regulations. If
enacted, the CHBC’s envisions these regulations will provide the hydrogen and fuel cell industry with clear opportunities for deployment of fuel cell electric buses (FCEBs), hydrogen
fueling equipment & additional demand for hydrogen fueling. It will enable investments to meet market demand and reduce cost of zero-emission buses like FCEBs, for fleet operators.
Specifically, the CHBC called out its support for several aspects of the proposed ICT Regulation proposal, outlined below:
- The CHBC supports higher bonus credit given for FCEBs (compared to Battery Electric Buses, or BEBs) deployed before deadline, as this would recognize the higher initial cost to deploy fuel cell electric buses including hydrogen infrastructure. This would provide critical to support early adopters.
- The CHBC also recommends preserving the restrictions on combustion vehicles from qualifying for ICT goals and encourages conversion of renewable liquid and gaseous hydrocarbon fuels to zero-emission hydrogen. Conversion to hydrogen eliminates emissions at the tailpipe and completely eliminates criteria air pollutant emissions, maximizing reduction in criteria pollutants in the neighborhoods served by transit buses.
- Higher upfront cost for FCEBs allows for lower cost at larger scale at a later time. Overall, all zero-emission vehicles, including fuel cell electric buses, will continue to improve in performance and decrease in cost, especially with increasing adoption among transit agencies at larger scale. As their costs begin to approach low-emissions combustion vehicles’, the cost for
charging and fueling these vehicles will remain an obstacle, at least as challenging as procuring and operating these vehicles, unless significant efforts are made now to nurture this infrastructure.
The CHBC proposed the following modifications to the proposed regulation to maximize the successful transition to zero emissions transit by 2040:
- Transit agencies (initially large ones) should be required to develop a ZEB plan, in which they assess and plan the build-out of utility generation, distribution and transmission infrastructure to suit the transit agency procurement plans, as submitted by the transit agencies for the 2020 deadline. These assessments would include consideration of ALL new transportation and industrial electrification efforts and their required generation and T&D capacities, quantifying the utility-related costs. An analysis of ratepayer cost should be included in the plan to provide cost transparency and resiliency impacts and costs must also be assessed.
- Equivalently, all hydrogen-powered vehicle procurement plans must show cost, time and environmental impact assessments for build-out of hydrogen production, distribution and dispensing.
- ARB should establish a deadline for the completion of these ZEB and fuel infrastructure plans in concert with procurement plans by 2023.