Comment Log Display

Testimony
Of
Mercedes-Benz
Before the California Air Resources Board
On Possible Amendments to the Zero-Emission Vehicle Program
March 27th, 2008


Walter Puetz
Director, Regulatory Affairs


Thank you, Madam Chairman, members of the board and ARB staff for
the opportunity to testify before you decide on the issue of
possible amendments to the Zero-Emission Vehicle Program.

My name is Walter Puetz, and I am Director of Regulatory Affairs
for Mercedes-Benz.  Over the years, Mercedes-Benz introduced many
of the technological and safety features that have become common
in modern vehicles.  Mercedes-Benz is owned by Daimler AG.  In the
US Daimler brands also include Freightliner trucks, Orion and
Thomas built bus and smart car.  World wide Daimler employs over
300,000 people dedicated to the transportation industry.

Mercedes-Benz is researching, developing and commercializing a
portfolio of technologies that will increase fuel efficiency and
reduce tailpipe emissions ultimately to zero.  One of these
technologies that I would like to highlight today is hydrogen fuel
cell vehicles.

We believe fuel cell vehicles have the best chance of giving
customers what they want, 300 miles or greater range and fast
refuelling.  So far we have spent over one billion dollars on fuel
cell vehicle development.  Recently top management made another
historic decision and that is to launch a small series of fuel
cell vehicles in 2010.  We are on a path that by 2015 a fuel cell
vehicle produced in an annual volume of 100,000 or more can be
equivalent in cost to a diesel hybrid vehicle.   However, there is
one critical component of the commercialization plan that we have
little to no control over - The deployment of a hydrogen fuelling
infrastructure in California.  

Through the California Fuel Cell Vehicle Partnership we worked
with ARB staff the auto industry and energy industry to identify
the location of 40 – 50 fuelling stations that are needed for the
next phase of commercialization of fuel cell vehicles in
California.  Recent events including the closure of several
existing fuelling stations and statements by energy companies that
there is no interest in deploying new fuelling stations have us
very, very concerned.  

Mercedes understands and appreciates the attempt in the proposal
of the revised ZEV mandate to be technology neutral and have the
auto industry deciding with which technologies to use ZEV
requirements be fulfilled.

Unfortunately, the proposal might be understood as a signal from
CARB, fuel cell technology is not of interest any more.
Why?
The new proposal allows OEMs to achieving all Gold credits with
Plug in Hybrids and BEVs.  As a result of this, energy companies
see higher risk in investing in a hydrogen infrastructure.

Therefore we kindly ask the Board: 
	
1	As a clear signal of a CARB commitment,  keep a certain number
of  FC vehicles      
      mandatory in the revised ZEV regulation;
2	Increase the number of gold credits for fuel cell vehicles to
reflect their current high and long-term consumer benefits.
3	Develop a plan that we can count on to ensure there is a
hydrogen infrastructure in California.

We thank you for your time and we are open for further discussing
this issue with you.