Comment Log Display

Below are comments from GreenPower Motor Company and we appreciate
CARB's interest in future changes; however, action must be
immediate.  

MHD Infrastructure Crediting Application: 

The proposal currently only recommends Hydrogen.  This is not
adequate and is not moving us forward to N-79-20. The reasoning per
CARB was that they had mainly only heard from the Hydrogen
technology group on this need.  This does not justify what is
necessary in the field to meet and support the requirements of the
mandate. 

This needs to support and align the MHD fleet operators' needs and
to continue to develop an ecosystem.  The EV Medium-Duty sector and
vehicles can immediately perform the fleet route and jobs.  As
such, we need to continue to meet the needs of the small size
fleets, private, and independent drivers whereby infrastructure to
support them is critical.  Truck and Bus Dealerships and Garage
Services and support centers can do this and it makes practical
sense to have an application for MHD on both ZEV technologies
including EV Fast Charging.  

We recommend the following modification and to include EV MHD
Charging Infrastructure applications.  Consideration to include EV
MHD infrastructure for the EV MHD vehicle deployment goal needs to
anticipate the scaling needs and accessibility for these larger
vehicles with larger battery packs.  It is critical to align with
the CI targets and ZEV MHD mandates with EV Charging station
locations and immediately.  For example, MHD commercial enterprise
dealerships have an interest and have the opportunity to improve
their business model as they face implementing a program to support
EV technology.  They depend on parts and services as their main
revenue source and they have locations that could bundle programs
to include charging as they tend to be located in urban and densely
populated hub areas and already implement a program to support
customers with MHD buses and trucks.  Additionally, these centers
have space for these larger vehicles.   This will harmonize a
solution with the mandates and an integrated EV charging model for
dealerships allows for a new revenue stream from the EV charging
and capacity credits.   

This could or could not be available to public access, in general,
I suggest a program that encourages public access at some
reasonable level in the design.  

An MHD program will likely prove to be more cost-effective than LDA
toward the unused capacity which the current program generates. 
Further, MHD charging infrastructure could benefit and perfectly
align with your new battery storage business consideration and I
would encourage a % of battery storage to be included for Peak Time
use Hours (maybe a 2-hour window) to continue to support grid
constraints at Peak time and establish smarter designs that benefit
the technology, end-users, and utility and society.  

Update to the EER data:  

An EER data update is required to establish EV Vehicle Standards
with the MHD Class vehicles under the baseline method.  

The Current program does not logically result in a method that
supports the best and most efficient MHD EV's. 

We need to begin developing awareness toward an EV MHD fuel economy
standard for each MHD class whereby the most efficient kWh/mile
achieves more credits and more opportunities toward increased
revenues.  For example:  

Class 4-6 as one category
Class 7-8 as one category
Instead of currently all Class 4-8 in one category.  

The Fuel economies from the MHD should create a standard for the
specific vehicle class as the amount of battery storage that is
installed in the vehicle is similar to the class size.    OEM's
should design the technology with quality and with the best
engineering judgment and components that achieve the best fuel
economy.  This directly impacts the fleets and ensures the
technology creates a cost-per-mile benefit.  

I do not object to the fuel density equivalent method.  What needs
updating is another step for converting the kWh/mile efficiency to
a result that is higher and better for the most efficient class of
MHD EV vehicles.  Moreover, with this change, the less efficient
vehicles will NOT continue gaining more credits as they currently
can generate  (see figure in attachment).

Essentially creating consideration for an average fuel economy
standard for each MHD class is necessary and this will result in
the best and most efficient vehicles with the most credits.  

~Lisa McGhee
GreenPower Motor Company