Comment Log Display

Thank you for the opportunity to submit comments about the ZEV
independent panel report.  I write as a long-time user and
advocate of alternative fuels; I have owned natural-gas vehicles
since 1993, and in 1998 I drove my CNG Dodge van from Los Angeles
to Maine and back to draw attention to the viability of fuels
besides gasoline and petrodiesel.  Since 1998 I have maintained a
website on the topic, now at www.altfuels.org.

After reading the panel's report, I am concerned that they reached
conclusions about the relative viability of full-performance
battery EVs and fuel-cell vehicles that are driven more by the
automakers' priorities than by the inherent merits of the
technologies.  Specifically, the panel notes that no substantial
improvement in hydrogen storage will be possible without
breakthroughs in technologies that are not out of the lab yet;
they also note that the fuel cell stack itself must improve in
many different directions (higher power density, greater
durability, lower cost) that conflict with one another, so that
the simultaneous solution of all the problems will again require
technological breakthroughs.  As far as I could tell, though,
their status projection amounts to saying that "with all the
effort being expended on these tasks, success seems likely," and
their timeline for scale-up of manufacturing amounts to saying
that "once these problems are solved, commercialization will occur
quickly."

By contrast, their conclusions about FPBEVs start from the
automakers' assertion that these are too limited to progress
beyond niche-vehicle status, and they proceed from this to note
that there has not been much improvement in batteries suitable for
FPBEVs because of lack of automaker interest, nor is likely to be. 
I am, of course, aware that the panel's charter was by necessity
circumscribed, and they were charged with evaluating the status of
technologies as they found them; however, they were also charged to
make projections for scale-up of manufacturing, and this involves
assumptions about what will be as well as observations of what is.
In this case, it seems that the panel accepted at face value the
automakers' denigration of FPBEVs.

A year after "Who Killed the Electric Car?", the Air Resources
Board has an opportunity to revisit this question.  As a
pre-emptive strike against negative publicity from that film, GM
bought full-page newspaper ads and Google AdWords to drive traffic
to a blog posting defending their actions with regard to the EV1; I
posted a page at http://www.altfuels.org/misc/onlygm.html with a
detailed, point-by-point rebuttal of GM's spin.  Other automakers
are equally guilty of misrepresenting both their level of effort
to "sell" (in most cases, of course, actually only lease) FPBEVs
several years ago and also the level of consumer interest in the
vehicles.  Ed Begley, Jr., famously said that FPBEVs were so
limited that they could serve the needs of "only" 90% of the
population; the true potential market is likely smaller than that,
of course, but certainly it should include a large fraction of
two-car households.  What needed, and needs, to be done is (1) to
make the vehicles actually available and (2) to base a sales pitch
on the advantages of the vehicles, namely that even without exotic
batteries they have enough range for the vast majority of daily
driving on an overnight charge that leaves you with a full "tank"
of cheap fuel every morning, and they free you from smog checks,
tuneups, and rush-hour gas lines, and on top of that you have all
of your torque available off the line.  Automakers failed to do
either (1) or (2).

The panel concluded, without having any specific reasons that I
could divine from their report, that the huge obstacles to
commercializing fuel-cell vehicles will be overcome simply because
automakers and component suppliers are putting so much effort into
the task.  But surely it's a lot easier to change customer
preferences with public education, i.e., advertising, than it is
to fight the laws of physics!  The automakers claim they tried but
failed to commercialize FPBEVs several years ago; if, like many
observers, the Board sees through this claim, then surely it seems
reasonable that you should require them to divert some of the
resources being (in the view of many) squandered on fuel cells to
make another, honest try at tasks (1) and (2), with tighter
supervision this time to keep them from "faking it" (by making the
vehicles nearly impossible to get, by running minimal and not very
persuasive ads, etc.).  In the MOA period, automakers promised to
produce enough FPBEVs to "meet demand," which gave them an
incentive to claim there wasn't any demand to meet; then a few
years ago, they promised to ramp up FCV production starting at the
end of this decade, if only they would be let out of making battery
EVs.  Now I understand that automakers want the FCV introduction
timing stretched by another decade. "Fool me once, shame on you;
fool me twice, shame on me," but there isn't a proverb to cover
allowing onesself to be fooled three times in a row!  I urge the
Board to hold the line on the present ZEV regulations, and if
automakers can't keep their fuel-cell promises, then let them be
forced to make an honest effort this time to build and sell
plug-in vehicles.