CARB’s Fuel Cell Detour - Part III
By Alec Brooks
Summary of CARB's Responses
CARB's response to the issues I raised has the overall appearance of grasping at straws. They continue to ignore every bit of good news about batteries, and cling to the conclusions of the 2000 battery report, which in itself was flawed as it related to vehicle energy consumption. They brush aside the issue of energy consumption of fuel cell vehicles being too high; high enough that consumers would reject fuel cell vehicles solely on the cost of the fuel. They brush aside the range problems of fuel cell vehicles, saying that there are promising hydrogen storage solutions just around the corner. They say that automakers "appear" to think there is a business case for fuel cell vehicles, but they don't wonder how this squares with automakers' unwillingness to put battery electric ZEV's on the market now and with statements by GM that hybrids don't make business sense for them or their customers.
CARB has decided that neither battery electric nor fuel cell vehicles are ready for mass production and that "time is needed" to see if they will suddenly be ready at some point in the future. They say this despite a generally positive track record for battery electric vehicles that were, and in some cases still are, in use in California. Southern California Edison operates a large fleet of EVs, some of which have passed 100,000 miles on the original battery pack. CARB now says that ZEVs should only be in very small demo programs unless they are ready for mass production. What happened to a phased rollout of vehicles with the recognition that in the beginning the technology won't be ready for mass production? CARB's strategy now is to allow automakers to stop making real ZEVs for real customers, in exchange for working up a handful of fuel cell vehicles for demo programs. In another five or ten years, CARB's expert review panel will ‘discover' that fuel cell vehicles aren't ready for mass production either. A battery supplier summed up the situation as follows: "The sole interpretation I have on the decisions made by the automotive companies is that they found a way to ‘fool' CARB for another few years in order to do something reasonable as late as possible."
The Decline of the ZEV Program
Throughout the 1990's CARB spearheaded a bold program to compel automakers to produce zero emission vehicles. A great deal of effort was expended by CARB staff, stakeholders, auto companies, and local agencies. A lot of money was spent to begin installing a public recharging infrastructure. Stakeholder meetings were held. Vehicles started to appear. But automakers didn't have their hearts in it. EVs from Nissan, Toyota, and DaimlerChrysler were not made available to retail customers. Honda offered their EVplus at so few dealers that it was a practical choice only for people that lived nearby, limiting the market. GM, on the other hand, made a giant splash with the EV1, launching it at all Saturn Dealers in several major market areas. EV1 ads were everywhere – billboards, newspapers, magazines, even one television ad. But somehow the ads always seemed a little off – as if they weren't actually trying to sell the car. The ads didn't mention where to go to get one; they didn't show people driving the cars. There is ample testimony on the record at CARB from people who were interested in the EV1, but were either turned away at Saturn dealers, or were discouraged by salespeople. GM also cultivated an image that the EV1 was for rich or famous people. One lessee explained how, in the interview process, he had to prove to GM that he was enough of a "high profile individual' to be allowed to lease an EV1. Collectively the marketing actions of GM, Honda, and Ford didn't appear to be building a real market for EVs. Instead, it appeared that the effort was aimed at spending a lot of marketing money while not moving many cars.
But one thing didn't go according to plan for the automakers. People that drove EVs actually liked them – a lot. A growing chorus was heard from people who wanted EVs but couldn't get them. The automakers have tried their best to explain the demand away – ‘sure there are enthusiastic drivers, but these people are on the fringe'. In a ‘lessons learned' page on GM's web site they (cynically) lament that they were not able to find enough customers:
|"EV1 owners are a proud, loyal group. Unfortunately, there were not enough of them. GM was able to lease only about 800 EV1s in four years -- not enough to establish commercial viability."|
I learned of GM's real EV1 strategy at the EV1's birthday party at Universal City on December 5, 1999. GM threw this lavish bash to celebrate the EV1's third birthday and to make the first deliveries of the new Gen II EV1 which had been delayed about a year due to unspecified development problems. As GM officials were ceremoniously handing over the keys to the beaming EV1 drivers, I chatted about the EV1 program with one of the GM executives present. What he said startled me, but it shouldn't have because it confirmed what I had expected: Those full page newspaper ads were not intended to sell cars and there was no way that GM was ever going to make any more EV1's after the current batch of Gen II's, no way, no how. He said they would fight CARB all the way to the Supreme Court if they had to. There was of course quite a contrast between the uplifting party atmosphere celebrating the EV1 and the GM's real plan for the demise of the EV1.
Why Did CARB Cave on Battery Electric Vehicles?
Alan Lloyd ran the March 2003 CARB meeting as a man with a mission. He knew what he wanted – which was to adopt the alternate compliance path that would allow automakers to meet all of their ZEV requirements with a handful of fuel cell vehicles. He was clearly almost hostile to any new testimony that would undermine this proposal. He pushed back suggestions by other board members that perhaps the number of vehicles in the alternate compliance path should be larger and that maybe some of them should be battery electric vehicles (or BEVs as they called them). There was a suggestion that some number of BEVs could be substituted, with a ceiling on the number, but not a floor. The number of BEVs would be determined by a contorted ‘fuel cell equivalent' scaling. The ‘equivalence' was to be an equivalent cost of compliance; since fuel cell vehicles were assumed to cost $1 million each, something like 10 or 20 BEVs would have to be produced to be the ‘equivalent' of a fuel cell vehicle. CARB's twisted logic goes like this: fuel cell vehicles are incredibly expensive, so one fuel cell vehicle in a demo program will be counted in the ZEV program as equally good as 10 or 20 battery electric vehicles in real customer usage.
The result of that March meeting was that Alan Lloyd didn't get what he wanted. There were many questions and concerns raised by some of the other board members, so a vote on the proposed new regulations was deferred until the next meeting, scheduled for April 24. This gave the staff time to come back with answers to the questions raised.
After the March meeting, I decided to talk to a couple of board members that had showed some resistance to Lloyd's plan. I set up appointments to talk by phone with Dorene D'Adamo and Matt McKinnon. My goal in speaking with them was to go over the written testimony I had submitted for the March board meeting. I had, perhaps naively, assumed that the board members had read my written testimony. The CARB web site instructions for written testimony says:
|If you have provided written comments on any agenda item, your submission is in the public record. Board members receive copies immediately and read them as they arrive.|
In my calls with D'Adamo and McKinnon, they apologized for not having read my testimony and assured me that they would before the April meeting. (It wasn't all that surprising that they hadn't read it – they noted that a very large quantity of written comments had been submitted). I discussed with them the main points of my submission, and found them to be quite open and interested. I got the sense that each of them was uncomfortable with the direction the rulemaking was heading. In talking with them, I got a better understanding of how the board usually operates. It was described to me as a ‘collegial' board, whereby individual board members usually look to the Chairman for the direction of the board's policies. It was quite unusual for board members to vote in opposition to the chairman. After speaking with them, it was clear that it was not going to be possible to get a majority of the board members to vote in opposition to what Lloyd wanted.
At the April board meeting, D'Adamo, McKinnon, and Mark DeSaulnier demonstrated their thoughtful consideration of the proposed rules by voting in opposition to Lloyd's plan.
From the September 2001 board meeting when the entire board strongly backed keeping a real ZEV program up through the March 2003 board meeting, Lloyd had made a slow, but complete reversal of his earlier strong support of a ZEV program that would put real vehicles into the marketplace in the near term. Although Lloyd was known as a fuel cell partisan since his days as chief scientist at the South Coast Air Quality Management District, he had shown strong support for battery EVs. But by March 2003 he had changed his tune, and to many he appeared to be caving in to the wishes of the auto industry. It was inexplicable. But a series of events around that time frame sheds some light on what may have influenced his thinking.
In early 2003, Lloyd became the Chairman of the California Fuel Cell Partnership. He had been the driving force behind the formation of the Partnership and he clearly relished the stature of California being perceived worldwide as the focal point for fuel cell vehicles. On March 5, 2003, he testified about the Partnership in Washington D.C. at a hearing of the House Committee on Science.
The new ZEV rules were originally supposed to be considered by CARB at the February 2003 board meeting. But in January, it was announced that the February meeting would be delayed until March 23 in order to provide more time to make changes and for additional public comment.
Then at the February 2003 meeting of the California Fuel Cell Partnership steering team, several automakers dragged their feet about committing to a renewal of their participation in the Partnership. Meanwhile, back in Michigan, an initiative called NextEnergy was aiming to make Michigan the center for fuel cell vehicle development and component manufacturing, setting up a competition with California for the attention of the automakers and their fuel cell vehicles. An Automotive News headline from March 10, 2003 summed it up: "California, Michigan and Ohio are jockeying for the title of "fuel cell state."
The word on the street was that several automakers were going to jump ship from the California Fuel Cell Partnership and take their fuel cell vehicles back to Michigan if they didn't get the ZEV rules that they wanted. (What they wanted was to be allowed to meet all of their ZEV requirements with a small number of fuel cell vehicles over a number of years, with no requirement to make any more battery electric vehicles.)
In early April, there was some scrambling at CARB when a planned April 22, 2003 earth day event with the governor to tout the Fuel Cell partnership had to be cancelled. Some of the automakers in the Partnership were balking at participating. The automakers hadn't gotten the ZEV rules that they wanted at the March meeting because the vote had been deferred until the April meeting, which wouldn't be held until after earth day. In the end, an event did take place with the governor, likely on Lloyd's assurance that he would be able to deliver at the April meeting (which he did, but with three dissenting votes).
In the end, Lloyd was faced with a choice – either give up on battery electric vehicles or lose the Fuel Cell Partnership. He chose the former. A state employee later said to me "we sold out on EVs to save the Partnership."
What Needs to be Done to Fix the Mess
As this is written in April 2004, there have recently been a growing number of voices making themselves heard questioning whether hydrogen fuel cell cars are in fact something we want or need. (A number of references are included in the further reading section at the end.) The frenzy that has developed over hydrogen cars over the last few years has fed on itself, and has grown to an alarming mass dash without enough analysis and discussion on whether this is where we want to go. Below are a number of recommended steps that can help moderate the frenzy and support due consideration of alternatives.
1. Stop using efficiency ratios in comparing fuel cell vehicles to gasoline powered vehicles. Everywhere you turn, it is stated as fact that fuel cell vehicles are far more efficient than conventional cars. Usually, this is expressed as a ratio; typical values given are from two to three. There are many flaws to this kind of approach. The efficiency of converting energy from one form to another (such as with a converting hydrogen to electricity or gasoline to shaft power) is not at all the same as how much fuel does it take to drive a vehicle a specific distance. They are related, but high efficiency in itself is not sufficient for high fuel economy. The engine in a 10 mpg Lamborghini might have great efficiency at some operating points, but the vehicle still has lousy fuel economy. Another flaw in using ratios is that conventional vehicles are a moving target. It is not very likely that the relative difference in fuel economy between fuel cell vehicles and conventional gasoline vehicles will remain a fixed ratio over time. Finally, and most importantly, fuel cell vehicles have been unable to show better fuel economy than the current state of the art gasoline powered cars – hybrids. The fuel cell studies do list smaller fuel economy ratios for hybrids; but the case can be made that non-plug in hybrids like the Prius should not be categorized as anything other than a gasoline-powered vehicle. With the growing consumer demand for hybrid vehicles, the "conventional" gasoline powered vehicle in the time frame that fuel cell vehicles are said to be coming to market most likely will be an ultra efficient hybrid. Even today, hybrids beat fuel cell vehicles on fuel economy. The 2004 Prius, a midsized car, has EPA ratings of 60 mpg city, 51 highway. The 2004 Honda FCX, a subcompact, has EPA ratings (in miles/kg hydrogen) of only 51 city, 46 highway. (A kilogram of hydrogen has for practical purposes, the same energy content as a gallon of gasoline). The Prius, two size classes larger than the FCX, has convincingly higher fuel economy; the oft-claimed two to three times fuel economy ratio is in reality less than one.
2. When regulators and government agencies talk about hydrogen, they need to stop saying that everyone agrees that a hydrogen powered vehicles and the hydrogen economy are inevitable and are the end-game. There are a broad range of well considered points of view in this area that are different and need to be heard and considered.
3. CARB needs to undo the damage it has caused to the ZEV program. If CARB wants zero emission vehicles they should not pick in advance which kind of vehicle they think will win in the long run. Let the market decide that. CARB should decide on a reasonable percentage of vehicles that can be zero emission, and ramp that number up slowly over time, and go back to one vehicle, one credit. The only requirement for the vehicle would be that it is a ZEV and is certified to federal motor vehicle safety standards for a passenger car or truck. CARB should also recognize that as these vehicles are built initially in small numbers, they won't be ready yet for mass production, and costs to manufacturers will be higher than they will be in the future when volumes are higher.
4. The environmental leaders of the California state government should put the brakes on the Hydrogen Highways Initiative. They need to have a careful look at the cost, energy, greenhouse gas, and pollution impacts before jumping to the conclusion. (And a hydrogen powered Hummer is just a bad idea; it would barely have enough range to drive between one hydrogen highway fuelling station and the next).
5. It is time for some new faces in the CARB board. The board needs to be reinvigorated with a few new members that are engaged, ask probing questions, and have a real understanding of the new frontiers of automotive technology.
6. Re-launch the California Fuel Cell Partnership as the California Zero Emission Vehicle (ZEV) Partnership. The new California ZEV Partnership should bring together all kinds of zero emission vehicles, and would require participants to disclose the key performance parameters of their vehicles; range, energy consumption, acceleration etc. These parameters would be measured at driving events such as the recent "Rally through the Valley" and reported on the Partnership web site. The friendly competition and cross pollination (a good feature of the existing partnership) will help speed the spread of knowledge of what is working and what isn't.
7. Create ZEV-friendly market conditions in California. Economic incentives, user privileges, infrastructure support, outreach and marketing, and assistance for qualified low-volume manufacturers and sellers are all required to boost the demand and supply of ZEVs. The original ZEV mandate became an unproductive CARB-vs-the-OEMs showdown. The OEMs won this round. CARB needs to work with the OEMs and also work around them via the market and alternative businesses.
8. Bring energy issues front and center. Energy impacts must be considered along with emissions in the regulation of automobiles and fuels. Transportation energy use requires state-, national-, and international-level policy analysis and coordination. CARB, an air quality agency, is neither authorized nor qualified to address energy issues. The CEC, PUC, and other agencies need to be involved.
Tom Gage, "The EV Business: A Post-Mandate Perspective"
Joe Romm, "The Hype about Hydrogen"
Joe Romm, testimony to Congress
Stephen and James Eaves: "A Cost Comparison of Fuel-Cell and Battery Electric Vehicles"
Baldur Eliasson and Ulf Bossel, "Future of the Hydrogen Economy, Bright or Bleak?"
Ulf Bossel, "The World Needs a Sustainable Energy Economy, not a Hydrogen Economy http://www.efcf.com/reports/E09.pdf
Ulf Bossel, "Efficiency of Hydrogen Fuel Cell, Diesel-SOFC-Hybrid and Battery Electric Vehicles"
Ulf Bossel, "Well-to-Wheel Studies, Heating Values, and the Energy Conservation Principle"
Robert Uhrig "Engineering Challenges of the Hydrogen Economy"
Wilson, "(The Truth about Hydrogen, A Response to Amory Lovins' "Twenty Hydrogen Myths")
EPRI battery report, March 2003
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