First Name: | Catherine |
---|---|
Last Name: | Dunwoody |
Email Address: | CDunwoody@CAFCP.org |
Affiliation | |
Subject | Comments on LCFS as it relates to H2 |
Comment |
Dear LCFS staff, Thank you for the opportunity to provide comments regarding the draft LCFS as it relates to hydrogen fuel. Please consider these informal comments - because of the diverse nature of the CaFCP membership, I am unable to gain overall consensus on formal comments. You may also hear from individual members directly. 1. I understand that based on proposed Section 95421(b)(1), providers of hydrogen would be exempt from the LCFS until total aggregate volume of hydrogen sold for transportation in California exceeds 420 million MJ (3.6 million gge) but that hydrogen providers could generate LCFS credits if they choose. 2. Several members agreed that it is appropriate to make the regulated party the owner of the fuel when it is dispensed. I did not receive any negative comments on this point. 3. The lookup table for hydrogen should not default to liquid H2 from natural gas as this cannot be the dominant pathway in California given existing law (SB1505). Instead, use a default pathway that yields SB1505-compliant hydrogen (30% reduction in CO2, 33% renewables etc.) This approach is similar to that used for electricity, for which the look up table value is based on California marginal mix in 2010 (Table 3, page 12 of Supporting Documentation). 4. I understand that providers of hydrogen can justify a lower carbon intensity value than what is included in the lookup table if they can support it for their specific pathway. 5. Using the Honda Clarity’s USEPA certified fuel economy data to calculate the FCV EER of 3.0 is appropriate. 6. CARB’s LCFS hypothetical compliance scenarios include FCVs ranging from 70,000 to 220,000 vehicles in the total fleet by 2020. These numbers are lower than other scenarios evaluated by the National Research Council[1] and the Oakridge National Laboratory[2]. Although the CaFCP members do not have a consensus recommendation for which numbers to use in a scenario that shows the possibility of ZEVs being more heavily weighted to FCVs, CARB could look to these studies for guidance. Keep in mind these studies clearly state that significant policy and financial incentives would be required to achieve a sustained, high-volume FCV market (also true for other alternative fuels.) Please let me know if you have further questions or need more input. Catherine ________________________________________ [1] National Academy of Sciences, National Research Council, Transitions to Alternative Vehicle Technologies: A Focus on Hydrogen, 2008, http://www.nap.edu/catalog.php?record_id=12222 [2] Greene, D.L., Leiby, P.N., James, B., Perez, J., Melendez, M., Milbrandt, A., Unnasch, S. and Hooks, M. 2008, March, Transition to Hydrogen Fuel Cell Vehicles & the Potential Hydrogen Energy Infrastructure Requirements, ORNL/TM-2008/30; http://cta.ornl.gov/cta/Publications/Reports/ORNL_TM_2008_30.pdf |
Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2008-12-23 10:25:26 |
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.