Comment Log Display

      I am Dave Goldstein, President of EVA/DC,  the Electric
Vehicle Association of Greater Washington since 1980, with more
than 30 years of diversified experience with electric and hybrid
vehicles and advanced battery systems.  I have served on a number
of U.S. Department of Energy advisory committees, including many
years as a member of the Ad Hoc Advanced Battery Readiness Working
Group (ABRWG.) 

     Thank you for the opportunity to review the 2007 ARB
Independent Expert Panel Report on the Status and Prospects for
Zero Emission Vehicle Technology.  Although I have not had
sufficient time to review the entire 207 page report, I have read
through  a great deal of it, and have been generally impressed
with the depth of this effort to characterize the current state of
energy storage, its metrics and implications for
California, and effectively, for the entire world.   

     The panel has painstakingly characterized each technology,
its strengths and weaknesses, market potential and presumed market
penetration.  It has done a particularly admirable job in
describing the various Lithium-Ion battery chemistries and fuel
cell challenges.  

     In so doing, however, the panel has, by nature of the
questions posed, relied heavily upon industry sources and opinions
to gather and produce this information.  In the process – no doubt
inadvertently – an unfortunate but pervasive automotive industry
bias is evident throughout this report.  Several statements and
key assumptions, particularly with regard to economics and
consumer attitudes, are highly questionable and should be reviewed
with a critical eye by ARB staff, noting that industry opinions and
regulatory actions are inherently at odds with one another,

     Properly informed regulatory decisions, on the other hand,
ultimately benefit both industry and consumers, by rationalizing
the market, creating meaningful standards, accelerating critical
mass in emerging technologies and thereby creating new business
opportunities as well as consumer choices while ultimately
providing cleaner air for all of us.   

     I do not envy the challenge before ARB staff.   We are
running out of time.  Yet we are aiming at a moving target –
Energy Storage – which has challenged us for most of the past
century and which will likely challenge us for most of this one as
well.  Thus, a fundamental question that may or may not be properly
framed by this report is, or should be: “When is good enough good
enough?”  It is up to ARB to decide.

    Within that context, here are a few statements that I believe
should be critically reviewed:

   Page 3, NIMH costs  –  The panel states that “high costs remain
the greatest challenge for battery and HEV manufacturers” as well
as Medium Power and High Energy NiMH, then states that costs would
be significantly reduced in 1 million systems per year to roughly
40 percent to no more than $2,500.  This is about the cost of a
premium sound package and/or GPS system in many vehicles and is
more than eclipsed by the added cost premium of an SUV compared to
a pickup truck or minivan.  Yet consumers make that choice every
day.  If the value proposition is there – overlooked, apparently,
by this panel, then why should “cost” remain the greatest
challenge?  

Page 3, etc. – The panel repeatedly compares initial battery
prices to “lifetime fuel costs.”
While this may be one metric applied by consumers, it is not the
sole determinant of consumer demand, and hence, market
opportunity.  Rather, it is a false argument presented by OEMs
that do not presently offer hybrids in any significant numbers. 
In fact, – a more appropriate comparison would be lifetime vehicle
costs including batteries (and for PHEVs, electricity) vs. lifetime
costs for ICEVs, including fuel and maintenance.

Page 3, etc, -- Li-Ions are claimed to offer “lower specific
costs,” yet the numbers shown for Medium Energy/Power Li-Ion
batteries in mass production are about the same cost as  NiMH’s in
mass production.  In fact, this matches the predictions of an EPRI
study that found that both chemistries in mass production would
ultimately cost about the same (approx. $250-300/kWh.) Yet the
panel seems to be suggesting that OEMs – and hence CARB  –  should
wait for Li-Ions to be perfected rather than to allow or encourage
NiMH to accelerate the early adoption of PHEVs.  Again, this is an
OEM argument for delaying implementation of technology-forcing
standards until battery technology is “mature.”   

  NiMH technology, as the panel correctly states, is relatively
mature, as the panel states, and has already demonstrated.  Now
the argument seems to be, “Let’s wait for the next technology to
come along before proceeding.”   

  Unfortunately time has run out to submit further comments.  I
would welcome the opportunity to continue this analysis with
regard to Li-Ion, which indeed is a very promising near term
technology.

  But I must end my analysis here.

  Regards,

  Dave Goldstein
  President, EVA/DC
  Tel: 301-869-4954