Subject: LCFS Change, GreenPower Motor
Comments: Adjusted CI. MHD FCI station w/ No LDA. EER
update
Online Docket: due 8-8-22
https://www.arb.ca.gov/lispub/comm/iframe_bcsubform.php?listname=lcfs-wkshp-jul22-ws&comm_period=1&_ga=2.263571141.890565268.1657343988-1413733057.1586491489
We
appreciate CARB's proposal for meaningful changes in the
future. Below & attached are comments
from GreenPower Motor Company
(GP).
Adjusted CI:
The staff needs to
present the adjusted CI model in a table that includes the details
year over year thru 2045. This should include all of the
components impacting the credit values (EER, CI Electricity Fuel
pathway, Energy Density, CI Benchmark standard, LCFS Credit
Value).
The CI Electricity
fuel pathway will decrease annually based on the power mix of the
grid at 60% renewables by 2030 and 100% clean energy by 2045.
Therefore, the CI benchmark standard when decreased (adjusted CI)
impacts that credit value. This is critical information as
historically this information has created a signal that has driven
private investments and a future decreased CI coupled with a
cleaner energy grid will reduce the value of the base LCFS
credit.
MHD FCI Infrastructure Crediting
Application:
The proposal to
include the BEV MHD FCI stations is necessary and can be well
justified due to the various ZERO Emissions mandates that the MHD
commercial vocations must meet. They face strict ZEV vehicle
procurement mandates tied to their vehicle composition. An
MHD program will likely prove to be more cost-effective than LDA
toward the unused capacity that the current LDA program
generates.
The BEV Medium-Duty
sector and vehicles can immediately perform over 90% of the fleet
routes and jobs when supported and designed with fast charging and
even more specifically high voltage fast charging. This
program will help to meet the needs of the small size fleets,
private, and independent drivers whereby this infrastructure is
critical to support their ZEV procurement. Truck and Bus
Dealerships, Garage Services, and Warranty support centers could be
well aligned to implement MHD FCI stations and maybe some of the
best locations to do so. 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.
We recommend the
following in the program and consider the specific needs of the BEV
MHD vehicle deployment applications and future scaling needs.
We do not recommend the program to include or be shared with
LDA vehicles. The two different vehicle types and use-cases
are black and white, they are not at all closely related.
The LDA cars on average travel 40 miles per day with the
current BEV technology. The average new LDA BEV gets up
to 300 miles per charge and averages 3 miles per kWh; thereby the
LDA BEV only needs to charge on average 1 x week. The average
fast-charging public station rate is $0.43 per kWh which results in
$0.143 per mile for LDA.
However, this program
should focus on MHD specifically. The MHD drivers and
vehicles need ingress and egress accessibility for the larger size
vehicles. They have an immediate need to get reliable access
due to their larger-size battery packs that require longer charging
sessions. The BEV MHD vehicle technology averages 55-200
miles per charge and will likely need to charge daily and sometimes
2 x per day for high volume mileage vocations and applications that
go beyond the range and or share a vehicle. The charging
experience and reliability are critical to this sector. The
design and needs of the MHD sector are vastly different than the
needs of the LDA. There is no synergy between these two
different sizes of vehicles. We need to focus on this sector
before considering a mix. This sector is sensitive to the
range and long charging sessions and the experience & up-time
of the BEV early adopters require a focus to get it right.
Additionally, the station cost can be more cost-effective if
focused on larger size commercial vocations versus mixing a design
for two vastly different needs and requirements.
I suggest a program
that has an incentive to encourage hub sharing for small-size
fleets versus focusing on public access. There needs to be an
incentive for neighbor fleets to have access to charging that could
likely be installed by larger entities. Such an incentive
could increase site utilization, and cost-effectiveness, local
charging will reduce miles traveled, and the increased utilization
could put downward pressure on the effects of demand or
subscription fees. The program could include a plus-up
incentive to add resiliency to the site for a 2-3 hour window
during the peak hours, for example, battery storage or renewables
generation, this could reduce grid constraint or capacity upgrades
by the utility.
A 5-year crediting
period should be the minimum, if battery storage is included the
program could be either longer or shorter depending on what
considerations should take place to achieve fairness for the
additional investment.
The nameplate should
be on a case-by-case basis. However, the Electrify America
stations have been very successful. The chargers should be at
a minimum of 150 to 350 kW.
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, utility, and society.
Evaluate the site
based on its location, its ability and willingness to share the
hub, open hours, parking for MHD size vehicles, and bandwidth
connectivity to support DCFC charging including in more rural areas
& a program to maintain specific maintenance & tolerance to
keep all equipment available (running) as there is no consequences
for equipment that is not available.
Update to the EER
data:
We recommend an EER
data update, this 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 EVs.
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. OEMs 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 attached pdf)
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