Comment Log Display

Dear LCFS staff, 

Thank you for the opportunity to provide comments regarding the
draft LCFS as it relates to hydrogen fuel. Please consider these
informal comments - because of the diverse nature of the CaFCP
membership, I am unable to gain overall consensus on formal
comments. You may also hear from individual members directly.

1.	I understand that based on proposed Section 95421(b)(1),
providers of hydrogen would be exempt from the LCFS until total
aggregate volume of hydrogen sold for transportation in California
exceeds 420 million MJ (3.6 million gge) but that hydrogen
providers could generate LCFS credits if they choose. 
2.	Several members agreed that it is appropriate to make the
regulated party the owner of the fuel when it is dispensed. I did
not receive any negative comments on this point. 
3.	The lookup table for hydrogen should not default to liquid H2
from natural gas as this cannot be the dominant pathway in
California given existing law (SB1505). Instead, use a default
pathway that yields SB1505-compliant hydrogen (30% reduction in
CO2, 33% renewables etc.) This approach is similar to that used for
electricity, for which the look up table value is based on
California marginal mix in 2010 (Table 3, page 12 of Supporting
Documentation).
4.	I understand that providers of hydrogen can justify a lower
carbon intensity value than what is included in the lookup table if
they can support it for their specific pathway. 
5.	Using the Honda Clarity’s USEPA certified fuel economy data to
calculate the FCV EER of 3.0 is appropriate. 
6.	CARB’s LCFS hypothetical compliance scenarios include FCVs
ranging from 70,000 to 220,000 vehicles in the total fleet by 2020.
These numbers are lower than other scenarios evaluated by the
National Research Council[1] and the Oakridge National
Laboratory[2]. Although the CaFCP members do not have a consensus
recommendation for which numbers to use in a scenario that shows
the possibility of ZEVs being more heavily weighted to FCVs, CARB
could look to these studies for guidance. Keep in mind these
studies clearly state that significant policy and financial
incentives would be required to achieve a sustained, high-volume
FCV market (also true for other alternative fuels.)

Please let me know if you have further questions or need more
input.
Catherine
________________________________________
[1] National Academy of Sciences, National Research Council,
Transitions to Alternative Vehicle Technologies: A Focus on
Hydrogen, 2008, http://www.nap.edu/catalog.php?record_id=12222 

[2] Greene, D.L., Leiby, P.N., James, B., Perez, J., Melendez, M.,
Milbrandt, A., Unnasch, S. and Hooks, M.  2008, March, Transition
to Hydrogen Fuel Cell Vehicles & the Potential Hydrogen Energy
Infrastructure Requirements, ORNL/TM-2008/30;
http://cta.ornl.gov/cta/Publications/Reports/ORNL_TM_2008_30.pdf