First Name | Michael |
---|---|
Last Name | Tosca |
Email Address | michael.tosca@utcpower.com |
Affiliation | |
Subject | Zero Emission Bus Regulation – Modified Text and Resolution 06-28 |
Comment | August 10, 2007 Clerk of the Board Air Resources Board 1001 I Street Sacramento, CA 95814 RE: Zero Emission Bus Regulation – Modified Text and Resolution 06-28 UTC Power greatly appreciates the efforts of the California Air Resources Board (CARB) members and staff to address concerns regarding the proposed revisions to California’s zero emission bus regulations. We also appreciate the opportunity to submit these brief comments on the modified text and Resolution 06-28. UTC Power has been involved in fuel cell bus applications since 1998 and our PureMotion power plant has provided propulsion for buses deployed in Washington, DC, Spain, Italy, Belgium, California, and Connecticut. We have been an active participant in the subject proceeding and testified before the Board on this matter on October 19, 2006. We have consistently stressed our concerns regarding the potential chilling effect changes in this rule could have on fuel cell supplier confidence and investment as well as the need to sustain market demand while technology validation efforts continue. UTC Power would like to comment on the Board's direction to staff to consider implementation criteria for Durability/Warranty and Reliability. The Durability/Warranty criterion of 20,000 hours is a very high bar to set for an emerging bus drive train technology. Suitable validation for such a criterion would require several years of fielded bus operation with a statistically significant number of buses fielded (validation fleet). The delay in the California zero emission bus purchase requirement will postpone the introduction of a meaningful validation fleet, hence slowing the validation that would support a 20,000 hour warranty or life prediction. A 20,000 hour power train warranty rivals the extended warranty offered for internal combustion engine bus drive trains that have been in development and production for over 100 years. UTC Power requests that the revised Zero Emission Bus regulation emphasize that the 20,000 hour criterion is a commercial product requirement and that fuel cell technology that is demonstrated to be improving at a rate that would allow full commercial life in the future would be a candidate for a minimum purchase requirement in California. UTC Power would also apply this same logic to the 10,000 miles between propulsion related road calls (MBPRC) reliability metric. That figure is representative of today's commercial products and will only be properly field validated after several years of operation with a statistically significant population of fuel cell buses in operation. It is very unlikely that field validation to support a 10,000 MBPRC metric will be complete when the board considers the staff recommendations in mid-2009. In summary, UTC Power would like the Durability/Warranty and Reliability implementation criteria to be considered in the spirit of a developing technology where the trajectory of these criteria is given as much consideration as the absolute value during the 2009 staff evaluation. Additionally, we ask that the criteria be lowered in accordance with the practical limits of field validation between now and the staff evaluation. Specifically, we ask that the Durability and Reliability criteria be lowered to >10,000 hours and >5,000 MBPRC (the lower threshold for today's diesel fleets), respectively. Thank you for the opportunity to comment. Please feel free to contact me if you have questions regarding this issue. Sincerely, Michael Tosca Senior Product Marketing & Sales Manager UTC Power 195 Governor's Highway South Windsor, CT 06074 860-727-7324 michael.tosca@utcpower.com www.utcpower.com |
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Date and Time Comment Was Submitted | 2007-08-10 10:46:54 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.