Comment Log Display

H. E. Christian (Chris) Peeples
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At-Large Director
Alameda Contra-Costa Transit District
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4037 Howe Street
Oakland, CA  94611-5211
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(510) 851-0968, Fax: 658-1425
E-mail: chris_peeples@yahoo.com
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	5 August 2013

VIA E-MAI. TO:  www.arb.ca.gov/cc/scopingplan/2013comments.htm

Chair Nichols and Members
California Air Resources Board
1001 "I" Street
Sacramento, CA 95814
P.O. Box 2815
Sacramento, CA 95812

	Re.:	2013 Scoping Plan Update — Heavy Duty Fuel Cell Fleet
Vehicles

Chair Nichols and Members Of The Board:

	I am an elected at–large member of the Alameda–Contra Costa
Transit District Board of Directors and am a member of the Sierra
Club’s Energy and Climate Change subcommittee.  These comments are,
however, my own.

	In your scoping plan update I urge you to take seriously the
potential of heavy duty fuel cell fleet vehicles to dramatically
reduce emissions of both criteria pollutants and GHGs in that
segment.

	As you know, at AC transit we have an extremely successful program
operating 12 full-size 40 foot fuel-cell buses in daily revenue
service.  These are 24,000 pound vehicles that can operate 18 or 20
hours a day and be refueled in 15 min.  They produce virtually zero
emissions at the bus (a small amount of water vapor only) and
dramatically lower emissions “well to wheel.”  We produce about 65
kg a day of hydrogen using solar cells (enough to fuel
approximately 2 ½ buses) which generates zero GHGs.  Even when
producing hydrogen in the “dirtiest” fashion – high temperature
steam reformation of natural gas – we produce 40% less GHG’s then
if we used the natural gas in an internal combustion engine.

	Thus far, our fuel cell buses have proven to be quite reliable and
dependable.  Our longest – lasting fuel-cell has more than 13,000
hours on it and none of them, as of yet, have failed and needed to
be rebuilt.

	As you know, our numbers have been verified by the Department of
Energy’s National Renewable Energy laboratory (“NREL”) (Links to
the NREL reports and other information regarding our program are
at: 
http://www.actransit.org/environment/the-hyroad/archives-and-links/

	During the joint Transportation and Energy Ministerial Conference
held by the Asia-Pacific Economic Cooperation (APEC) in San
Francisco in September of 2011 our fuel cell buses were pressed
into service to take the ministers and their staffs from the ferry
terminal in Alameda to a demonstration at FedEx at the Oakland
airport.  As part of that exhibition, there was a class 8 fuel cell
drayage truck tractor from a small group of such tractors that are
being used in the ports of Los Angeles and Long Beach.  Although I
have not read any reports that were verified by NREL, what I was
told by the people at that demonstration was that they, also, had
been quite successful.

	The issue is high capital costs.  All of these vehicles are
produced in very small quantities with no benefit of mass
production.  The cost curve is, however, moving in the right
direction.  Our first 40 foot buses were approximately $3.2
million.  The buses we have been running for the past four years
were about $2.5 million.  I am told that the latest equivalent
buses that were delivered in Europe were about €900,000 (about $1.2
million).  Both European and American manufacturers have said that
$900,000-$1 million per vehicle is possible in quantity 100 (our
last “buy” was from a quantity 16 production).  I assume, without
detailed knowledge, that the cost factors for trucks are in the
same ballpark.  That is moving in the right direction, but is still
substantially more than the equivalent diesel bus.

	Obviously, it will be a long time before there is infrastructure
for either heavy duty or light duty hydrogen vehicles roaming
America’s highways.  Nevertheless, there are a substantial number
of vehicles that operate in fleets that come to a central fueling
location regularly (urban buses, delivery trucks, port drayage
trucks, etc.).  In many cases, particularly with urban buses and
delivery trucks and port drayage trucks, those vehicles operate in
areas where there are high rates of criteria pollutants and thus
there is a dual benefit of reduced criteria pollutants along with
reduced GHG’s.  If appropriate funding can be found, those fuel
cell fleet vehicles could begin to be used in significant numbers
in the 2020 time-frame rather then later.

	It would be important for your scoping plan to both mandate the
increased use of the fuel-cell technology and to find a funding
source for the additional capital expense that they represent.

	If I can provide you with any further comments or information,
please do not hesitate to contact me.

		     Very truly yours,


								                           / S /

	       H. E. Christian Peeples 

Cc	AC Transit Board Of Directors
  	AC Transit General Manager David J. Armijo
	California Fuel Cell Partnership
	Jaimie Levin, Senior Project Manager, Director        West Coast
Office, Center for Transportation and the Environment

HECP/win
[G:ip_Non_LglActCLN-FULH2_Fuel_Cellac-carb_scop_5Aug13.wpd]

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