Comment Log Display

The text below is from the letter, attached in PDF format, that we
also sent to:

California Air Resources Board 
Chair Mary D. Nichols
1001 "I" Street 
Sacramento, CA 95814

November 16, 2016

Re: Comments on the Volkswagen Settlement, Appendix C


Dear Chair Nichols and Staff:

Carbon Free Palo Alto (CFPA) thanks you and your staff for the
opportunity to comment on the Volkswagen (VW) Settlement, Consent
Decree, Appendix C and the California Air Resources Board’s (CARB)
presentation slides from the public input workshop held on December
2, 2016. 

Summary:
1)	We support the proposed programs in Appendix C as only relates
to battery electric vehicles
2)	Settlement funding should not be wasted on hydrogen Fuel Cell
vehicles. 

Background:
We support the proposed programs in Appendix C as relates to
battery electric vehicles.  CFPA was formed to help Palo Alto reach
its aggressive goal of 80% carbon reduction by 2030. Car
transportation is the largest single source of CO2 emissions in our
community and many others. Our city has converted to 100%
carbon-free electricity in large part to support the switch away
from fossil fuels to electricity for transportation and buildings.
Many other cities in California also have a goal to provide 100%
renewable electricity to their residents by 2030 or sooner. This
means that all funding available from the Settlement can be
productively used today to accelerate us along a proven route to
zero emissions car transportation and a flexible renewable energy
infrastructure.

Our city focuses exclusively on plug-in, battery electric
technology as the best path to carbon-free car transportation for
many reasons.

Battery electric vehicles are
•	Cost-effective automobile transportation solutions today – they
offer lower lifetime cost of ownership than gasoline powered cars
and can be charged in many existing locations
•	Flexible and available in many forms, from plug-in hybrid to full
battery electric, that cover the complete set of range and charge
time requirements
•	The lowest carbon and energy footprint, light duty vehicles 
•	True Zero Emission Vehicles, wells-to-wheels, wherever renewable
energy is on-line
•	Complementary to a flexible and resilient electrical energy
infrastructure where renewable energy can be harnessed and building
and transportation solutions can rapidly evolve
CFPA strongly recommends against funding hydrogen infrastructure
programs with public money from the Settlement. Lack of
infrastructure is often cited by industry groups as the only
obstacle to the development of a fuel cell vehicle market. However
95% of hydrogen fuel comes from natural gas and will remain so for
the foreseeable future. In addition, public investment in the
excessively expensive “fossil” hydrogen fueling network ($2M per
station) is highly speculative while vehicles are still expensive,
unproven and largely unavailable. 

There is no economical or energy-efficient way to produce hydrogen
from carbon free, renewable energy. It simply takes too much energy
(2 to 3 times as much) to generate hydrogen from water, compress
it, distribute it and fuel a high pressure tank to power a fuel
cell vehicle compared to just charging a battery electric vehicle
from the grid. Moreover, producing hydrogen from water uses
significant amounts of fresh water, a scarce resource in
California.

Fuel cell vehicles that use “fossil” hydrogen from natural gas
generate the same amount of emissions as today’s efficient hybrid
vehicles with limited scope for improvement given the technical
limitations. They should therefore not qualify as “Zero Emissions
Vehicles” (ZEV) for the purpose of directing Settlement funds.
Further, promoting hydrogen vehicles as a viable near or medium
term, low/no carbon transportation solution confuses consumers
entering the market looking for a low or zero emissions vehicle.

The following table developed by Carbon Free Palo Alto shows that
the EV market is already significant and accelerating while the
Hydrogen Fuel Cell market remains just a projection. As such, it is
highly unlikely that Fuel Cells will play a significant role in
reducing transportation emissions.  

California Count	Electric Vehicles	Hydrogen Fuel Cell Vehicles
Models for Sale*	20+	2
2016	~250,000	<500
2019	~600,000	~13,500
2022	~1,200,000	~43,600
Cost	$29k-Leaf	$57k-Mirai
Fuel $/yr**	$450	$1,250
Energy/yr**
Tank to Wheel	4.5 MWh	7.6 MWh
Energy/yr***
Well to Wheel	6.5 MWh	33-40 MWh

*   20 EV models sold in all leading CA cities in 2016. November,
2016 ICCT report. FCV models for sale  in 2016: Toyota Mirai, 8
dealers, Toyota website; Hyundai Tucson, lease only, near H2
stations, Hyundai website.
** Tank to Wheel based on 15,000 miles/yr base, Leaf: $0.10/kWH,
3.3 miles/kWH; Mirai, $5.5/kg H2, 2 miles/kWh;
https://www.fueleconomy.gov/feg/fcv_sbs.shtml
*** Well to Wheel based on renewable energy + electrolysis,
http://phys.org/news/2006-12-hydrogen-economy-doesnt.html
Hydrogen fuel-cell transportation still needs “four miracles”.
Energy Secretary Stephen Chu’s comments from 2009 are, in essence,
still true today; for hydrogen to work, “four miracles” need to
happen: 

1)	There needs to be an efficient and low-cost way to produce
hydrogen
2)	There needs to be a safe, high-density method of storing
hydrogen in automobiles. 
3)	An infrastructure for distributing hydrogen has to be built so
that fuel-cell vehicles would have ample refueling options; and 
4)	We need to improve the capacity of the fuel-cell systems
themselves

Chu concluded that achieving all four big breakthroughs would be
unlikely. “Saints only need three miracles,” he added.  

CARB responded to Secretary Chu at the time as follows:

 
Industry projections for the fuel cell vehicle market are
continually rolled back. Likewise, the present CARB projections
roll back the forecast above five more years to 47,000 Fuel Cells
by 2022.  Other technical and economic statements regarding fuel
cell vehicles contained the response have likewise failed to
materialize. This lack of progress combined with the accelerating
EV market strongly suggests that the market has already decided
that hydrogen cars are not a winning technology for the foreseeable
future. A recent Stanford study comparing the longer term scenarios
of hydrogen vs battery electric based transportation also conclude
that investing in the path toward hydrogen cars would not be a
sound investment.2

The envisaged hydrogen car market has outsized infrastructure cost,
untested products and no clear economic or environmental value. Any
public investment and promotion of hydrogen stations will likely be
seen as wasted on a “white elephant”. 



Bruce Hodge
CFPA Founder and Chair

 
CC:  	
Jack Broadbent, BAAQMD, jBroadbent@baaqmd.gov
Palo Alto City Council, city.council@cityofpaloalto.org 
Menlo Park City Council, city.council@menlopark.org 
Mountain View City Council, city.clerk@mountainview.gov   
Mark Berman, State Assembly Member Elect, marc@voteberman.com
Stephen Cue, Stanford, Former U.S. Secretary or Energy,
schu@stanford.edu
Jerry Hill, CA Senator Assembly, 1528 South El Camino Real, Suite
303, San Mateo, CA 94402

	
Notes:
   Paraphrased from: 
https://www.technologyreview.com/s/413475/q-a-steven-chu/
2  Battery cars a better choice for reducing emissions than fuel
cell cars. Stanford Precourt Institute for Energy. Nov. 14, 2016.
https://energy.stanford.edu/news/battery-cars-better-choice-reducing-emissions-fuel-cell-cars