AB8 Webinar Questions and Responses from CaFCP and CARB, 2019

Thank you for joining us for the October 30, 2019 AB 8 Webinar. We’ve tried to answer most of your questions as thoughtfully as possible and included relevant documents where necessary. In some cases, we responded directly to you. 

You can find the video recording from the webinar here, and a PDF of the presentation here.

Questions about Vehicles

How much does hydrogen cost at the dispenser?
Hydrogen is a regulated motor fuel and every station sets its own price. Currently, hydrogen is more expensive on a per-mile basis that gasoline, which is why the automakers include a debit card for fuel with the lease or sale of the car. For most drivers, the debit card covers three years of fuel.

At First Element Fuel’s Oakland station, the price of hydrogen fuel is $13.11/kg (tax included). The station is a showcase of today’s hydrogen station development as it is supplied by liquid hydrogen and has a capacity of more than 800 kilograms, which is three times the capacity of previously built True Zero stations. As a point of reference, at First Element’s older technology Long Beach station, the price of hydrogen fuel is $16.85/kg.  This shift in price is a big step towards a price of $10 per kg of hydrogen that True Zero is hoping to achieve in the future.

How many light-duty vehicles will be on the road? How will it impact platinum the station status tracked in real time?
Based on the latest information provided by a confidential survey of automakers’ future FCEV plans, CARB estimates that there will be 26,900 and 48,000 FCEVs on the road in 2022 and 2025, respectively. In addition, CaFCP’s California Fuel Cell Revolution calls for 1,000 hydrogen stations to support up to one million fuel cell electric cars, trucks, and buses by 2030. Fuel cells are also used for stationary power, locomotives, marine transport, material handling, and a dozen other uses. According to the World Platinum Council, increased demand from fuel cells will not exceed the current surplus in part because demand from the automotive sector is already declining and FCEV platinum use per vehicle is similar to that used in conventional vehicles, with companies such as Bosch and Johnson Massey announcing new fuel cell systems requiring significantly less platinum. Mercedes-Benz, when it announced its GLC F-Cell, noted that it had reduced the amount of platinum in the fuel cell by 90 percent in comparison to its  predecessor vehicle. Last, future platinum will be sourced via recycling of fuel cell stacks, just as it is from automotive catalytic converters today, with a very high recovery rate.

What is the lifetime of a fuel cell with the current purity of hydrogen?
Because hydrogen is a regulated motor fuel, it has a fuel quality standard that enabled automakers and fuel cell companies to develop fuel cells that can withstand impurities within the tolerances of the fuel. Generally, automakers of cars, buses and trucks aim for a fuel cell stack lifetime that matches the longevity of a typical vehicle engine in that category. Fuel cell stacks have been exceeding expectations, especially in the transit category, where many buses operate daily on long routes. AC Transit, for example, has been operating fuel cells in its buses for more than 25,000 hours, as have buses in Europe. This equates to approximately 200,000 miles of operation.

Figure 2 is the Comparison of On-The-Road Vehicle Counts. Is this chart only for light-duty vehicles?
Yes, Figure ES3 on page xii of the report (repeated as Figure 2 on page 15) is specific to light-duty FCEVs in California.

Please clarify if the number of vehicles in the Figure 2 includes retired vehicles, or are about 6,000 FCEVs on the road now?
There are two types of numbers reflected in Figure ES3/Figure 2. The first set is the orange and blue diamonds and associated shaded areas. These data are based on annual auto manufacturer-submitted surveys of their estimated future releases of FCEVs in California. CARB’s aggregation and projection method does account for potential vehicle retirement, following a method consistent with the EMFAC model developed by CARB. The second set of data represented by the red circles and triangles shows the then-current active registrations based on Department of Motor Vehicles registration data and are thus true counts of the number of FCEVs currently registered in the state as of the date of the data.


Questions about Hydrogen

What is the difference between renewable and non-renewable hydrogen?
Most hydrogen for industrial purposes (non-renewable) is produced from natural gas. Renewable hydrogen can be produced from solar or wind electrolysis of water, from biomass (like agricultural waste), or biogas (from landfills or wastewater treatment plants). No matter the feedstock used in production, the end product used for transportation is exactly the same—99.999% pure hydrogen, and provides real and measurable CO2 emission reductions as verified by the Argonne Labs GREET model. However, keep in mind that ALL hydrogen used for transportation meets a MINIMUM 33% renewable requirement, offering even further CO2 reductions. Last, the fuel cell and hydrogen industry have committed to achieve 100% decarbonized hydrogen for transportation by 2030.

What are the sources of renewable hydrogen at California’s stations?
There are two main sources of renewable hydrogen utilized for California’s hydrogen station network. Renewable gas (such as renewable natural gas, biomethane, wastewater treatment plant gas, or other renewables) is processed through a steam-methane reformer to manufacture the hydrogen. The second common method is splitting of the water molecule using an electrolyzer powered with renewable electricity, which breaks down the water molecule into its constituent atoms, hydrogen and oxygen.

In some cases, station operators use Renewable Energy Credits to qualify for the renewable hydrogen content. As the fuel cell vehicle market matures, we will see station operators rely less on RECs as renewable hydrogen production expands. For example, Air Liquide is building a large-scale renewable hydrogen production plant primarily to serve the vehicle market in California.

How do you calculate the carbon intensity of hydrogen?
Carbon intensity for FCV’s is measured the same way for all vehicles and transportation fuels, including battery electric vehicles. The impact of fuel is measured on a well-to-wheels (W2W) basis. The most widely used lifecycle economic and air pollution model is Argonne National Lab’s GREET model, a widely used tool for estimating W2W systems energy use and emissions. The GREET model has been modified to a California specific version, CA-GREET, which accounts for energy expenditure and emissions along all steps of fuel production and allows for mixes of California specific energy sources, like a California Mix for electricity and CARBOB, the California mix of gasoline with biofuels. Argonne  modeled a California mix of hydrogen in GREET that recognizes the 33% renewable hydrogen requirement and developed this Well to Wheels booklet to show how hydrogen FCEVs compare to other vehicles. Note that the range of FCEVs and BEVs has increased since we published this booklet.

California’s Low Carbon Fuel Standard (LCFS) program relies on the CA-GREET model. In addition, the LCFS program applies an Energy Economy Ratio of 2.5 for light-duty Fuel Cell Electric Vehicles. This represents the greater efficiency of fuel cell energy conversion to conventional internal combustion engine energy conversion. Comparison of CA-GREET analyses of hydrogen and gasoline production and distribution pathways, combined with accounting of the Energy Economy Ratio, provides an assessment of the carbon intensity and GHG reduction potential of hydrogen on a well-to-wheels basis.

You can find the Air Resources Board’s carbon intensity values for fuels covered by the Low Carbon Fuel Standard

Is it true that only 1/3 of hydrogen stations need to have renewable hydrogen
No, this is not true. This is likely a slight misinterpretation of the requirements of SB 1505. SB 1505, passed in 2006, which requires that all hydrogen fueling stations that receive State funding must dispense hydrogen with a minimum 33% renewable content. (Actual is higher) It should be noted that this requirement must be met by renewable resources in excess of those already being placed on the electric grid. As shown in Figure ES 8 on page xvii (and repeated as Figure 26 on page 53) of the report, the 64 currently funded stations are expected to have a renewable energy sourcing of at least 39% once they are all open. All stations individually (or on a company-wide average) meet the 33% minimum, but some stations are aleady 100% renewably-sourced. In addition, all stations that participate in the LCFS HRI program are required to meet a minimum 40% renewable requirement. As more stations enter that program, the total renewable implementation will continually increase.

It is also vital to understand that hydrogen with a 33% renewable resource implementation provides GHG emissions reductions on par with BEVs charged by today’s electric grid. The California Energy Commission also reports that California’s electric gird power mix was just over 31% renewable in 2018, which demonstrates that hydrogen is keeping pace with electricity as a renewable transportation fuel.

In addition, several private entities have announced intentions to far exceed these requirements and move towards highly aspirational goals like 100% renewable implementation or 100% de-carbonization. (See Hydrogen Council link above) These announcements have been made by individual station developers building California’s network and larger organizations like the Hydrogen Council, which has a goal for full de-carbonization worldwide of all hydrogen used for transportation by 2030.

How much renewable hydrogen is in the existing station network?
As stated above and as shown in Figure ES 8 on page xvii (and repeated as Figure 26 on page 53) of the report, the 64 currently funded stations are expected to have a renewable energy sourcing of a minimum 39% once they are all open in 2021, and will likely far exceed this shortly thereafter toward the 100% decarbonized goal in 2030.

What is the future (% renewables content) target for renewable hydrogen?
See above. In addition, California stakeholders are developing legislation to place hydrogen fuel on a path to 100% renewable content, much like the state has done with the electrical grid.

Do you know how many cars and stations are in Germany?
Germany has 84 stations in operation as of Jun 1, 2020 and more in development, although some are not “full retail”  stations like in the U.S. Please visit https://h2.live/en or, or our sister organization, H2Mobility, for more information about Germany’s stations.


Questions about Station Locations

How do you determine where the next stations will be located?
The location of any new hydrogen fueling station is determined by several factors. In past grant solicitations, the Energy Commission utilized various analytical models to help inform determination of areas with the greatest need for new stations. Applications would then be scored against these analyses. In addition, applicants have been encouraged to provide their own analysis and information they have gained from on-the-ground interactions and discussions with auto manufacturers and local permitting agencies to provide perspectives that cannot be captured by an analytical model. Auto manufacturers have also published a list of their preferred locations, which have been referenced in application materials.

For the proposed concepts of the next solicitation, much of this would be the same though the use of analytical modeling would be streamlined. In addition, the opportunity offered by the newly available LCFS HRI credits offer station developers financial incentive beyond government subsidies and represent an economic pathway to hydrogen economy self-sufficiency. Under this program, many of the requirements are similar, though station developers’ proposed locations are not assessed against an analytical model. Rather, developers are asked to provide narrative descriptions and data demonstrating that the capacity and location proposed for their specific location is reasonable and justifiable. The requirements of the narrative address many of the same considerations as the analytical models used by CARB.

Why didn’t CARB build a hydrogen station at its new facility in Riverside?
It would be challenging to install a retail hydrogen station at CARB’s Riverside facility, and a preexisting retail hydrogen station exists in Riverside that can provide this fueling service for CARB employees and other customers in the general public who drive FCEVs in the area. At the moment, the Riverside station is undergoing renovation, and stakeholders are working to ensure that it re-opens soon.

As the hydrogen station network continues to grow throughout the state, and in southern California specifically, additional fueling stations are expected to enter the market in and around Riverside. In fact, the Area Classification system CARB proposes for the next hydrogen station grant solicitation identifies Riverside as an eligible area under the Market Initiation category and further analysis projects a future need for high-capacity stations in the area  (see Figures 14 and 15 on pages 33 and 34 of the report).

What about mobile fueling for the sake of reliability?
Mobile fuelers have been considered and may provide value under certain conditions, however, they have limited capacity and do not replace the need for a sound, full function network of appropriately sized (high capacity) and distributed stations.

Where can I find information about hydrogen safety incidents?
The Center for Hydrogen Safety is global non-profit dedicated to promoting hydrogen safety and best practices worldwide to more than 60,000 safety professionals worldwide. The Hydrogen Safety Panel reviews safety incidents and makes its findings available on the website.


Questions about Future Growth

The report indicates that in five years, 52 stations were built. Is it possible to build 200 stations in 10 years?
First of all yes, it is possible. However, a point of clarification, Figure ES2 on page xi shows a projection for the end of 2019 of potentially 52 stations open by the end of the year. As discussed in the webinar, updated information indicates the actual number will likely be less than 52. The goal of 200 stations is derived from Executive Order B-48-18 signed by Governor Brown in January of 2018, which calls for this number of stations by 2025. This pace of station development can also help put the California’s network on a path towards 1,000 stations by 2030 as indicated in the California Fuel Cell Partnership’s Fuel Cell Revolution document. CARB Staff indicate that both CARB and the Energy Commission are working to ensure that the combination of AB 8 funds and LCFS HRI (Hydrogen Refueling Infrastructure) credits can provide sufficient financial support to fund 200 stations as directed.

CaFCP Industry members point out that new station openings have consistently been behind the  pace of FCEVs entering the market, which creates stress to the existing network of retail hydrogen network and making the network particularly vulnerable to disruptions. Loss of one station can impact all stations in the immediate vicinity; disruption of the wholesale hydrogen supply chain impacts California’s entire hydrogen fueling network. This is why automakers and station developers are asking the state to help bring more stations online faster which will help alleviate this supply-demand imbalance.

Gas stations serve about 2,500 cars per day and hydrogen stations about 250 cars per day. Why build more stations now?
Simply put, the station network is behind the market needs. Figure ES 4 of the report (repeated as Figure 23 on page 46) displays a comparison of the fueling capacity of the currently funded 64 hydrogen station network (green shaded area) and the auto manufacturers’ FCEV future release data (blue diamonds and yellow bars). Current vehicles on the road exceed the supply too often, and as early as next year, the deployment of FCEVs could present an even greater demand imbalance  for hydrogen than the currently funded network, assuming FCEV deployment matches the larger deployment numbers received for 2020. By 2023, there is a near certainty that the current network would be further stressed beyond capacity. This is a clear indication that station development needs to be accelerated and continue in order to maintain FCEV deployment pace and allow other OEM’s to introduce new models and platforms. With a goal of 200 stations by 2025, the State is working to encourage deployment beyond maintaining historical pace and enable accelerated FCEV deployment.

Do you expect that plug-in fuel cell hybrids will change the station deployment projections—numbers or locations?
There are currently no announced plans to release fuel cell plug-in hybrid vehicles in the California market.

How was the minimum capacity per station for initial deployment determined?
Early station funding programs were reflective of the state of the industry and technology development at the time of their completion. Several years ago, the market was still pre-commercial, station developers and equipment providers did not yet have the means to propose and develop stations as large as those currently entering California’s market, and there was not as much information available about the relative economics of larger and smaller stations. While this meant that early stations were smaller, it also indicates positive momentum and development in the industry as new stations are being developed to allow four vehicle simultaneous refueling with much larger capacity.

Can existing stations add capacity?
In many cases, yes. Stations could upgrade their capacity as long as there is sufficient “footprint” and especially if they have been designed for upgrades. The capability to accomplish this at any specific location must be determined by a detailed engineering analysis and market needs.

In practice, the cost to upgrade a station may be less feasible than reconstructing the station for far higher capacity.

Do any of the existing stations have utilization of 50% or more?
Yes, a number of the highly utilized stations do today. The utilization of any given hydrogen station varies by day of week and season, just like gasoline stations, so evaluation of utilization depends in part on the time over which it is being evaluated. Still, it is true that generally there are stations that  see over 50% utilization multiple days of the year. In the 2018 Joint Agency Staff Report on AB 8, it was reported that the average utilization of the network in Q3 2018 was 38%. Of the 34 stations open in that quarter 12 (36%) had quarterly average utilizations above 50%. There have even been stations that see over 100% utilization (this is possible by scheduling additional hydrogen deliveries to the station in excess of the normal operating strategy). There is growing evidence that stations are being more heavily utilized the more the station network grows and FCEVs are released.

How does CAFCP work with Electrify America to support the fuel cell industry?
The Volkswagen Environmental Mitigation Trust provides about $423 million for California to mitigate the excess NOx emissions caused by VW's use of illegal emissions testing defeat devices in certain VW diesel vehicles. The fund focuses on buses, trucks, and marine vehicles and infrastructure and has  funded a few fuel cell vehicles and hydrogen stations.

Volkswagen has two separate mitigation plans in California. The Electrify America ZEV Investment Plan has four cycles of funding that were designated to help enable  zero emission vehicles. CaFCP staff and many members give public testimony at workshops and hearings about the investment plans explaining the need and benefit of investing in hydrogen and have spoken with Electrify America directly. Cycle 1 and Cycle 2 funding plans mostly ignored this testimony and were almost exclusively designated for plug in electric vehicles. Cycle 3 planning has not started yet.

Finally, on February 20, 2020, the Energy Commission approved the use of $5million sourced from the NOx mitigation portion (commonly referred to as "Appendix D") of the Volkswagen Consent Decree to be added to the funding for its current light-duty hydrogen fueling station solicitation.

Question #25: How do we go from 200 stations in 2025 to 1,000 stations in 2030?
CaFCP’s Revolution report describes the actions necessary for hydrogen station growth. Released a year ago, two actions are already underway: a new renewable production facility and LCFS provisions for hydrogen capacity. These actions implement mechanisms that incentivize private investment into the development of hydrogen fueling stations, which, combined with a reduction in the price of fuel and an increasing FCEV population, create a virtuous cycle of economic growth of this new energy economy.

Why does the State continue to invest in light-duty FCEVs when plug-in vehicles are so far ahead?
Because both are ZEV’s and consumers want choice. One size, one technology does NOT fit all.  Also, California has aggressive GHG and criteria pollutant emission reduction targets. To reach these targets, a rapid transition to ZEVs will be required in the transportation sector. Moreover, California’s vehicle fleet is the largest in the nation. Taken together, the challenge presented by these goals is enormous. It will require enabling all Californians the ability to switch their vehicle(s) to ZEV options at a rapid pace. In order to achieve this, ZEV options will need to be available that meet the needs of all consumers who drive conventionally fueled vehicles today. These consumers have a variety of needs in terms of vehicle design and passenger and cargo loading capacity, towing capability, range, refueling time, access to zero-emission refueling options, and other considerations.

Meeting such varied needs for the entire marketplace is a major challenge, unlikely to be satisfied by a single vehicle/fuel option. BEVs and FCEVs each present respective strengths in terms of meeting customer needs, and where one faces challenges the other typically excels. In this way, the two technologies complement each other well for achieving a completely decarbonized transportation market that relies on ZEV options. Supporting both technologies increases the overall chance of success in meeting the large-scale fleet turnover required in the coming decades and may even accelerate the process compared to pursuing a single technology, alone. Moreover, both technologies show promise for unique and exciting opportunities to contribute to increased implementation of renewable energy on the state’s electric grid. For these reasons, CARB continues to support a ZEV strategy that encourages deployment of both FCEVs and BEVs.

The report states that the state committed $20 million a year to build hydrogen stations, yet no stations have been funded since 2017. Where is the annual $20 million being spent?
It is important to separate funding cycles, allocations of funds, and spending of funds on hydrogen fueling station projects. Since 2017, there has certainly been spending on hydrogen fueling station development, as the stations funded by GFO 15-605 (released in 2016 and funded in 2017) have been under development and receive disbursements of funds per their contracts with the Energy Commission. Since 2017, there had not yet been another grant solicitation released until December 2019. However, the annual funding plans for the Clean Transportation Program (formerly the Alternative and Renewable Fuel and Vehicle Technology Program) had continued to indicate allocations of $20 million per year. Thus, these funds have been leveraged in this newly released solicitation. This solicitation makes $45.7 million immediately available, which is in excess of a single year’s $20 million allocation and leverages a total allocation of up to $115.7 million through 2024. This multi-year structure will make it easier to implement the $20 million annual allocations on a consistent annual schedule. Last, see the CAFCP website for new high capacity stations in development that have recently and / or are coming online at a rapid pace.

Have you seen any movement on legislation to enact Governor Brown’s Executive Order?
It is CaFCP industry members’ perception that executive orders are typically treated with the same level of respect and seriousness as statute, however the legislature CHOSE to not fund his Executive Order callout for H2 stations. So while there is nothing in state law speaking to the funding of the 200 stations specified in Governor Brown’s Executive Order, state agencies are still planning for building 200 stations to meet this target. The new GFO is anticipated to result in 40 to 50 additional stations, pushing California past AB8’s 100 station milestone and towards the 200 station goal. In addition, CARB’s LCFS capacity credit adds additional incentive for the construction of stations with or without other public support. Industry stakeholders are working in the background to identify various mechanisms to help achieve the Executive Order 200 station milestone and lay the foundation to get to the 1000 station goal identified in the CaFCP California Fuel Cell Revolution.

Furthermore, Governor Newsom’s climate change Executive Order N-19-19 confirmed the commitment to Governor Brown’s Executive Order on ZEVs.

In the future, will CARB’s annual report include medium- and heavy-duty vehicles and stations?
As described in AB 8, the Annual Evaluations published by CARB are focused on the light-duty market and this forms the basis for the analyses. In addition, CARB’s authority for surveying vehicle manufacturers only extends to the light-duty market. Having said that, each year CARB reports on a wide array of topics that are not directly related to the central requirements of the Annual Evaluations. In recent years, this has typically included advances in the medium- and heavy-duty ZEV markets.  In the 2019 Annual Evaluation, the sections Global Announcement of FCEV Commitments on pages 25-26 and Fuel Cell Market & Technology Developments across Transportation Sectors on page 57 include discussions of advancements in the medium- and heavy-duty markets.

Can CaFCP develop a plan for trucks and buses, like what the Swiss did?
CaFCP recently published A Road Map for Zero Emission, Fuel Cell Electric Buses in California that lays out a plan for fuel cell buses supporting the Innovative Clean Transit regulation aimed at a 100% zero emission transit fleet in California. In 2020, we plan to develop a more robust and detailed road map for fuel cell trucks based on the results of the current pilot projects and ongoing stakeholder discussions.