Comment Log Display
Below is the comment you selected to display.
Comment 43 for Electrify America's proposed Cycle 2 ZEV Investment Plan (vw-zevinvest-c2bd-ws) - 1st Workshop.
First Name: Ranji
Last Name: George
Email Address: easy7blue@gmail.com
Affiliation:
Subject: ARB should allow H2 FCEV to compete with BZEVs
Comment:
It is with great sadness to note that ARB is showing open bias and partisanship towards one form of ZEVS (namely Battery ZEVs) and ignoring the other form of ZEV, namely hydrogen fuel cells (H2 FCEVs). BZEVs offer numerous air quality benefits but so do hydrogen fuel cells. However Hydrogen fuel cells offer substantial more advantages than BZEVs. Let me list the top 4: Advantage 1) Disposal issues. Hydrogen fuel cells don't have the same scale of battery disposal problem at the end of battery life. Each BZEVs have 4 battery packs with numerous cells in each pack. These batteries will be consumed in 10 to 12 years, after which these may be used in stationary sources for few more years. Then what? These HUGE number of spent batteries (in the tens of millions) have to be recycled. How many recycling plants have been built? Currently, lead acid batteries have very advanced recycling plants but these recycling plants emit lot of toxic waste: in air, groundwater, solids. Lithium ion batteries may not emit that much but still there is a potential for serious environmental discharge. Has there been any estimates of how many recycling plants that need to be made? Why is ARB not addressing this issue? The fact that air pollution is reduced with batteries, but solid waste and air waste are created when batteries are recycled should awaken our senses Advantage 2)Potential recycling plants in EJ communities. Recycling plants are constructed where land is cheap and labor is plentiful. These are typically in EJ communities. Beverly Hills and Bell-Air will not allow battery recycling plants in their neighborhood. California has done a tremendous job in highlighting the environmental distress currently present in EJ communities . By emphasizing BZEVs, at thee expense of H2 FCEVs, we are indirectly creating another hazardous waste generating recycling plant industry in EJ areas. Let's be cognizant of this danger. Advantage 3)Spent batteries may end up as waste. There is no assurance that recycling plants will be constructed in enough numbers and on a timely manner to recycle ALL of the spent batteries emanating from BZEVs. As a result, many batteries (we are talking millions here) may find itself being disposed off in the landfill, waste or shipped to third world countries for disposal. Is this fair? Aren't we creating a major environmental crisis - potentially on the scale of plastic disposal crisis we have today? Advantage 4) Lithium availability. Lithium availability for large scale penetration of BZEVs is not assured given that lithium mines are spread out in diverse sometimes politically unstable geographical regions. One or two countries can defacto take over these mines and can create a cartel like situation where general availability can be severely limited. Such restraints do not exist for H2 FCEVs. Platinium is used in H2FCEVs but the quantities are limited and are mainly sourced from South Africa and other stable countries. Summary. Given (1)the serious disposal concerns of tens of millions of spent batteries, (2) the potential for creating a hazardous recycling industry in EJ communities, and (3) that raw lithium may face an OPEC cartel type of situation, I would urge ARB to give H2 FCEVs adequate funding for infrastructure. H2 FCEVs is more sustainable over the long term than BZEVs. Thanks Ranji George Please note, while I was at the SCAQMD, under Dr. Alan Lloyd who later became the chairman of ARB, I was heavily involved at the formative stages for both BZEVs and H2 FCEVs. I support both technologies, BZEVs for the short term and FCEVs for long term.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2018-10-26 15:44:30
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.