Subject: OBSOLETE CARB ANALYSIS: Line-Haul and Passenger
Comment: Public Meeting to Consider the Draft 2022 Climate
Change Scoping Plan, June 23, 2022
June 21, 2022
by Phil Birkhahn, Co-Chair, Transportation Committee of San
Change requested p. 58, “Freight and Passenger Rail, Line
haul and passenger rail rely primarily on hydrogen fuel cell
technology, and others primarily utilize electricity”.
CHANGE “Hydrogen” to “Battery electric or
Hydrogen, depending on new analysis”, not analysis done in
Change requested, Appendix C, p. 4, Table C-1, “Line haul
and passenger rail rely primarily on hydrogen fuel cell technology,
and others primarily utilize electricity”. CHANGE
“hydrogen” to “ZEV” in all four
Battery trains are feasible now, while CARB excludes them based
on six-year-old analysis of an even older design. The only
way hydrogen trains can win, is by preventing fresh analysis of
battery trains and fair support by CARB and State of
Contrary to hydrogen advocates’ talking points and
out-of-date CARB technology assessment used to justify the hydrogen
train program, battery trains can run long distances using existing
technology. They just need a fair chance to demonstrate their
lower acquisition cost and lower operating cost. Batteries
enable low-cost, efficient direct electrification.
Hydrogen trains need three times as much electricity to provide
hydrogen by electrolysis and complete other electricity hogging
steps before hydrogen is pumped into a train. The
consequences of hydrogen’s low energy efficiency make
hydrogen no better than diesel. Hydrogen advocates go on an
on about the tailpipe emission of just water and fail to mention
problematic upstream emissions.
It is time to revisit obsolete assumptions dating from 2016,
when battery tenders for freight rail were last evaluated using a
design from 2012 (Transpower, 2012 and 2014). Batteries back
then limited the tender to 6.2 MWh of storage for a loaded box
car. That capacity was assumed in reports published in 2016
(Railtec, 2016, p. 14 and CARB, 2016, p. VI-12). After
allowing for a 20% to 100% operating range for state of charge, 5.0
MWh was left.
Then 5.0 MWh was cut in half by a mysterious railroad operating
“rule” limiting discharge to 50%, leaving just 2.5 MWh
available per battery tender. The “rule” is
probably for the two-ton lead-acid battery used to start the
locomotive’s diesel engine. Those lead-acid batteries
have an operating range of 50% to 100%. The supposed 50%
rule, if used, should apply to the 6.2 MWh total capacity, not 5
Fresh analysis by CARB must account for increases in battery
energy density since 2012. Then the result should be worked
into ZEHTRANS, which is a program of CARB, CalTrans, Energy
Commission, and Go-Biz, followed by integration with the State
Mobile Source Strategy. Because the Scoping Plan Update is on
a faster track, the language used should be flexible enough to
encompass battery-powered trains and let technology results
determine the mix of hydrogen and battery power. Call it ZEV
for now so as not to prejudice the outcome by enshrining hydrogen
trains in the Scoping Plan.
We have a head start. Fresh analysis by others was
published late last year by staff from Lawrence Berkeley National
Laboratory, UCLA Institute of the Environment and Sustainability,
and UC Berkeley Department of Agricultural and Resource Economics
(Popovich and others, 2021). Nowadays, 14 MWh of battery
storage with its power electronics fits in a standard boxcar.
LFP batteries share the 20% to 100% operating range for state of
charge, leaving 11.2 MWh, a big upgrade from 2.5 MWh.
They showed that a freight train carrying 6,806 revenue tonnes
(7,487-tons) of payload could go 150 miles with four 14 MWh battery
tenders. Such a train would weigh 15,656 tons counting the
four locomotives, rail cars, and battery tenders. Their
calculation is based on annual nationwide figures for revenue-tons
hauled and diesel consumed.
I get a similar result with basic vehicle dynamics calculations,
finding four locomotives with battery tenders (45 MWh of useable
energy) would be needed. One of the four could move a
3,900-ton train 150 miles.
CARB must change course to fully evaluate battery-powered trains
before making any total commitment to hydrogen trains by way of its
Scoping Plan. Somehow CARB dropped the ball by not keeping up
with capabilities of battery trains and shows no signs of
A 600-ton passenger train like the Surfliner, with its single
locomotive and one tender, could go all the way from San Diego to
San Luis Obispo, or maybe even farther as in the new AMTRAK plan,
all the way to San Francisco!
California Air Resources Board, Transportation and Toxics
Division, November 2016, Technology Assessment, Freight
Popovich, Natalie & Rajagopal, Deepak & Tasar, Elif
& Phadke, Amol. (2021). Economic, environmental and
grid-resilience benefits of converting diesel trains to
battery-electric: Nature Energy. 6.
RailTec, Spring 2016, Transitioning to a Zero or Near-Zero
Emission Line-Haul Freight Rail System in California: Operational
and Economic Considerations: Prepared for State of California
Air Resources Board.
Transpower, 2012, Transpower RailServer – Battery Tender
Car. Archived by ARB staff, April 2, 2012.
Transpower, 2014. Rail-Saver™: Zero-Emission Technology
for Rail Transport. Presented at the Transportation Research
Board Annual Meeting, Washington D.C., January 2014.