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Severe Issues with Fuel Cell Vehicle GHG Emissions Claims and Hydrogen Refueling Infrastructure Grants

Editor’s Note: one of our readers sent the following letter on May 19, 2014 to the person and office noted below. However, we thought it deserved as much attention as possible and are thus publishing here on CleanTechnica as well. We advise you to share widely.

Severe Issues with Fuel Cell Vehicle GHG Emissions Claims, Detailed Analysis in Open Letter to California Energy Commission Proposing Urgent De-Funding of Hydrogen Refueling Infrastructure Grants to FirstElement Fuel Inc. and Others

F.A.O. And for circulation.

Rachel Grant Kiley

Grants and Loans Officer, California Energy Commission, 1516 Ninth Street, MS-1 Sacramento, CA 95814

Re: PON-13-607 Hydrogen Refueling Infrastructure / Severe Issues with Fuel Cell Vehicle GHG Emissions Claims.

Dear Rachel,

This is Julian Cox, thank you for taking a moment by telephone and, crucially, for your assurances that funds have not as yet been awarded to Hydrogen Refueling contractors per PON-13-607.

Thank you also for your kind attention and assistance in escalating the matters summarized hereunder to parties responsible for determining on PON-13-607.

Contrary to the impression given in numerous reports in the media, I understand that it remains the case that ‘Funding of proposed projects resulting from this solicitation [including the $27.6 million funding proposed for FirstElement Fuel Inc.] is contingent upon the approval of these projects at a publicly noticed Energy Commission Business Meeting and execution of a grant agreement.’ – and that this meeting has not yet occurred.

I would like to remark that this is out of the ordinary — that an applicant hopeful of receiving significant grant funding should declare the foregone conclusion of a publicly noticed Energy Commission Business Meeting bypress release in advance of receiving approval. This looks like a cross between deeply questionable overconfidence and a worrying attempt to de-advertise the availability of due process.

I would like to make a contribution to that process herewith.

I am writing to you as a result of what I am confident the Commission will agree are material and severe discrepancies between the rationale for awarding any funds to Hydrogen Refueling Infrastructure and the independently verifiable facts that are brought to light in this document.

Background and Introduction.

Consistent with a career-long vocation focussed on the positive convergence of economics, energy, transportation and care for the environment I have taken a keen interest in developments and challenges of all kinds facing the electrification of transport in California.

More recently I have observed some troubling conduct surrounding the auto and fossil fuel industry promotion of Fuel Cell Vehicles. Primarily that of a singular preoccupation with targeting aggressive comparative marketing statements at the initially tiny market opportunity to displace other ZEVs (Electric Vehicles) posing the least of the problems that ZEVs could reasonably be expected to solve for consumers in terms of contributions to vehicle emissions. This aggressive stance against Electric Vehicles seemed to be accompanied by evasion of public transparency with respect to the intrinsic link between hydrogen and its almost invariably natural gas feedstock and the GHG emissions resulting from its conversion to hydrogen. Accordingly I was moved to produce some basic research into like-for-like energy and emissions equivalences to look into the issue more closely and the closer I looked the more the facade unravelled.

One thing that was swiftly discovered besides very evidently bad science gives probable cause as to why. That is to say that by far the most influential scientific advisor in seemingly all matters leading to the appearance of PON-13-607 would appear to have worn a variety of hats and filled a chain of key roles surrounding this process. These roles include academic advisor to the CEC on Hydrogen policy, the role of lead author of the California Fuel Cell Partnership’s Hydrogen Roadmap and culminating in the role of Co-President of the principal awardee. I refer of course to Dr Tim Brown currently Co-President of FirstElement Fuel Inc.

Simply put, while the fact is incontrovertible that FirstElement Fuel Inc., stands to gain $27.6 million from public funds, under the most basic forensic examination the academic advice received by the CEC to support that outcome does not hold up.

Real-world well to wheel emissions calculations for Fuel Cell Vehicles produce figures that are so entirely at odds with assumptions at the heart of both public policy and broad consumer awareness that I am compelled to bring this matter to attention.

This is a long document. Thank you sincerely in advance for your most valuable time and attention, and for those who can, your decisive action in defense of the public interest as good judgement and conscience dictates.


The following bedrock statement at the heart of public policy concerning Fuel Cell Vehicles as published here by the California Fuel Cell Partnership, is a pivotal mischaracterization of core research conducted by NREL. If taken on its face value, this statement of comparison on behalf of Fuel Cell technology vehicle versus Gasoline technology vehicle is categorically and unequivocally false:

‘When making the hydrogen from natural gas, as most hydrogen is made today, the GHG emissions are cut in half compared to a conventional vehicle using gasoline’.

This statement is false by omission of the contextually absurd specification given by NREL to the term ‘conventional vehicle using gasoline’. This is a 23 mpg gasoline vehicle that in the modern era generates typically twice the power output of any 122hp to a maximum of 134hp FCV either tested by NREL, presently available or proposed for market introduction. To give an example, a 350hp 2014 Porsche 911 Carrera 4 is a 23mpg EPA vehicle. It should come therefore as no surprise that any modern 122-134hp fossil fuel powered vehicle of any kind is bound to produce at least approximately half of the emissions per mile no matter if those emissions come out of the tailpipe or elsewhere. Far more surprising is that such a revelation of the ordinary could reach the verge of triggering a rethink of public energy policy costing $100s millions if not many $billions before someone eventually points to this most obvious fact.

In plain English and for the avoidance of any doubt. In accordance with the facts and figures brought to light in this document, Fuel Cell Vehicles currently on the roads of California cannot be relied upon to require the production of any less GHG emissions per standard EPA combined mile in the making of hydrogen from natural gas than would be produced from a directly equivalent gasoline vehicle. There can be no ambiguity when the direct equivalence in question is the same make and model of vehicle substituting only a Fuel Cell system with a Gasoline or Diesel Internal Combustion Engine of the same or similar power output.


One of the key figures missing from public debate on this topic, and the one that must be well understood for transparency is the CO2 per Kg figure for Hydrogen production from natural gas.

For those unfamiliar with hydrogen production, here is a highly recommended brief and accessible click-through animation presented (in English) by French-held Air Liquide, a member of H2USA and the lead hydrogen contractor for Saudi Aramco, the world’s largest global-scale exporter of hydrogen. For those concerned about foreign fuel dependency, yes, Saudi Arabia has figured out how to export Hydrogen aboard oil tankers in a liquid petroleum-based H2 carrier called Methylcyclohexane. A perfect illustration of the fact that energy independence and measures to maintain fossil fuel dependency are competing objectives. Air Liquide is also a proposed awardee under PON-13-607.

These are the step by step well to tank calculations for steam methane reforming: Wellhead emissions: (2.450Kg) SMR furnace: (3.704Kg) SMR process: (5.072) Grid emission for compression: (1.175Kg). Subtotal 12.401 Kg CO2 per Kg of Hydrogen, prior to transportation.

This is cross checked with total Natural Gas inputs of 3.629 Kg CH4 per Kg Hydrogen representing a 66% rate of well to product energy efficiency (using a standard 50MJ/Kg figure for NG and a standard 120 MJ/Kg figure for H2, both LHV numbers). To complete the picture requires an acceptable estimated figure for transport. Figures originating at Argonne National Laboratory and republished in graphical form by hydrogen fuel cell lobby group Californian Fuel Cell Partnership arrive at 62% efficiency inclusive of transportation. Hence a final tally of 0.66/0.62 * 12.4 = 13.20Kg CO2 / Kg Hydrogen.

Key number:  Hydrogen consumed well-to-wheel produces 13.201 Kg CO2 per Kg.

Note, this is a best case figure from industrial-scale centralized production.

With reference to distributed and mobile steam reforming contemplated by some of the PON-13-607  proposed awardees, the NREL long term fuel cell study indicates an emissions intensity factor of 356:237 or 150% when producing hydrogen on-site from natural gas at refueling stations. That raises real-world CO2 emissions per Kg of Hydrogen from 13.20Kg CO2 to 19.8 Kg CO2. In order to highlight difficulties with the claims made for Fuel Cell Vehicles, I will proceed with the most generous case at 13.20Kg CO2/Kg H2, not the worst case or even the average case suggested by NREL.

This 13.201 Kg CO2 / for 1Kg Hydrogen lends public transparency to gasoline equivalent emissions simply by putting this figure alongside Well To Wheel numbers for Gasoline. 

The EPA standard figure for CO2 tailpipe emissions per gallon of gasoline is 8.887Kg CO2.

For total well to wheel CO2 emissions we need to accommodate all of the processes prior to the gas station as well as the tailpipe emissions.

NREL gives as figure of 484g CO2 /mile for a 23 mpg vehicle. 23*484 = 11,132g

We can cross check this figure with a DOE study which shows 450g CO2 per mile for a 25mpg vehicle. 25/23 * 450 = 489g. The figures are in excellent agreement.

Well To Wheel Gasoline emissions are 11.132 Kg CO2 for the production and burning of 1 Gallon of Gasoline.

To set 11.132 Kg CO2 / Gal for Gasoline against the 13.201 Kg CO2 / Kg for Hydrogen is a like for like comparison.

The LHV energy equivalence of 1gal to 1Kg is close enough 1:1.

(LHV = Lower Heating Value, just means useful energy not counting exhaust heat, fuel cells have exhaust heat in the form of steam or water vapor).

Now at last we can understand what we are looking at. 

The first thing that becomes obvious is that Hydrogen generates more CO2 emissions than gasoline for the same amount of energy. 13.201/11.132 = 1.186 (18.6% more). The same calculation in reverse 11.132/13.201 = 0.843. This determines that it takes 0.843 of one Kg of Hydrogen to produce the same CO2 emissions as one gallon of gasoline well to wheel. In other words a gasoline pollution equivalent mile is 0.843 of the distance of a 1Kg hydrogen mile.

Researching diesel vehicles in comparison with gasoline, it is possible to locate figures of 14.2g / MJ Well To Tank and 74.1g / MJ for combustion totaling 88.3g / MJ. Where a g/mile or g/km figure is known it is possible to multiply it by 88.3 / 74.1 or 1.1916.  19% of total diesel emissions occur before before it is burned. For gasoline 11132/8887 tells us 25.26% of total gasoline emissions occur before it is burned. For Hydrogen 13201/13201 tells us that 100% of total Hydrogen emissions occur before it is burned.

To illustrate this issue with the most accessible clarity it is proposes that we use a unit of emissions performance termed MPGp defined as miles per gasoline gallon equivalent well to wheel CO2 pollution. (Note the term pollution is used here interchangeably with emissions and is not intended to be inflammatory, simply that the ideal choice of MPGe which might have stood for MPG-emissions is occupied by MPG-energy. A term used by the EPA and others for Gasoline Gallon energy equivalence).

MPGp simply allows for a full 11.132 Kg well to wheel emissions per mile for a gasoline gallon instead of the 8.887Kg EPA tailpipe-only figure. Familiar mpg figures for gasoline-only or gasoline hybrid vehicles remain the same figure for MPGp, other fuel and energy sources such as Diesel, Hydrogen and Electricity require to be divided into quantities that also produce 11.132 Kg of CO2.

So now all we need to know in order to arrive at a Hydrogen Fuel Cell Vehicle pollution equivalence to gasoline vehicles is the number of miles any given Hydrogen vehicle can go on a Kg of Hydrogen – and multiply that number by 0.843 as follows (all diesel mpg calculated directly from CO2 emissions for best equivalence):

Hyundai ix35 Tucson FCV 134hp (265mi/5.64Kg) 47 miles per Kg H2    = 39.62 MPGp

Hyundai ix35 Tucson 1.6 135hp 35mpg   (11132g / 318.51 g/mi wtw )     = 34.95 MPGp

Cross check  158 g/km / 0.621371 mi / Km = 254.28 g/mi * 1.2526 = 318.51g  wtw

Hyundai ix35 Tucson 2.0 CRDi 148hp Diesel ww 293.41g/mi wtw         = 37.93 MPGp

Hyundai ix35 Tucson 1.7 CRDi 117hp Diesel EU 266.56 g/mi wtw        = 41.76 MPGp

Mercedes B Class 134hp F-Cell FCV 52 miles per Kg H2  EPA              = 43.84 MPGp

Mercedes B Class 120hp B180 1.6 gasoline 269.47 g/mi wtw                 = 38.44 MPGp

Mercedes B Class 136hp B-200 Diesel 64.2mpg  220.54 g/mi wtw         = 50.47 MPGp

Honda FCX Clarity 134hp FCV 60 miles per Kg H2   EPA                     = 50.58 MPGp

Honda Accord Gasoline Hybrid 196hp 47mpg  EPA                         = 47.00 MPGp

Honda Civic 1.6-litre i-DTEC Diesel 118hp  180.26 g/mi wtw               = 61.75 MPGp

Toyota 2015 90KW/122hp FCV 68.3 miles per Kg H2  (NREL)            = 57.58 MPGp

Toyota Prius gasoline Hybrid 1.8 134hp 50mpg EPA                              = 50.00 MPGp

Toyota Avensis Tourer 2.0 D-4D 124hp Diesel 230.13 g/mi wtw           = 48.37 MPGp

51% Emissions Reductions? No, not even close.

The most egregious example above is the Mercedes B Class F-Cell marketed as “invisible to the environment”. The Fuel Cell Vehicle version of the Mercedes B Class is actually 13% worse than the diesel version of the same power output with undeniable equivalence i.e. same aerodynamics, same car. The Hyundai Tucson, again same aerodynamics, the same power, same car, is 13% better than a standard gasoline ICE equivalent but far adrift from the 55%-65% claims made by CAFCP. It is also 5% worse than a 117hp diesel of similar driving performance.

According to the lobby group California Fuel Cell Partnership:  “The well-to-wheels reports show that hydrogen made from natural gas and used in a fuel cell vehicle reduces greenhouse gases (GHGs) by 55%-65% compared to gasoline used in a conventional vehicle, and by about 40% compared to gasoline in a hybrid engine.”

Statements like this are clearly at odds with reality irrespective of the credentials of the source. As demonstrated. These claims made by the CAFCP and repeated by marketers of FCVs are simply not true. They are not a bit on the hopeful side or wrong by an acceptable margin of error. These statements are categorically false and blatantly misleading.

As previously mentioned, the marketing of Fuel Cell Vehicles is targeted squarely at Electric Vehicles on grounds of greater convenience to access lower total green house gas emissions. With trivial actual merit versus gasoline and diesel the real world numbers for Electric Vehicles and Plug In Hybrid vehicles naturally obliterate the real world numbers for Fuel Cell Vehicles.

We can again use MPGp (miles per gasoline gallon equivalent well to wheel pollution). For this we will need some conversions to discover how many KWh is required to amount to 11.132 Kg of CO2 during production to be equivalent to one gallon of gasoline as follows:

US Average Grid (IPCC) is 0.610 Kg CO2 per KWh. 11.132/0.610 = 18.249 KWh.

PG&E in California is 0.524lb = 0.238 Kg CO2 per KWh. 11.132/0.238 = 46.773 KWh.

A 2014 primer of the kind of performance that now possible in the real world:

Norway’s National Grid (IPCC): 0.003Kg CO2/KWh. 11.132/0.003 = 3710.67 KWh.

These figures are ‘well to socket’. To be as accurate as possible we need to introduce a charging efficiency loss between the socket and the battery of an EV, typically 8% is fair.

Then all we need to know is how far an electric vehicle travels on a KWh of electricity.

Tesla Model S P85+ 416hp 330Wh/mile* (0.359 KWh/mile after charging loss).

*Some references are suggestive that this is total usage as measured at the wall inclusive of charging loss but to ensure that this exercise errs on the unimpeachable I will leave in 8% charging losses for EVs throughout.

Tesla Model S P85    US Grid Average 18.249 / 0.359                        = 50.83 MPGp

Tesla Model S P85   California PG&E 46.773 / 0.359                        = 130.27 MPGp

Tesla Model S P85   Norway Grid       3710.67 / 0.359                       = 10,336.13 MPGp

Chevrolet Spark EV 280Wh/mile (0.304 KWh/mile after charging loss), This is a 100KW (134hp) EV, which makes it a useful direct comparison with FCVs.

Chevrolet Spark EV US Grid Average   18.249 / 0.304                          = 60.03 MPGp

Chevrolet Spark EV California PG&E   46.773 / 0.304            = 153.85 MPGp

Chevrolet Spark EV Norway Grid         3710.67 / 0.304                = *12,206.15 MPGp

Comparison to equivalent FCVs

Hyundai ix35 Tucson FCV 134hp (265mi/5.64Kg) 47 miles per Kg H2    = 39.62 MPGp

Mercedes B Class 134hp F-Cell FCV 52 miles per Kg H2  EPA              = 43.84 MPGp

Honda FCX Clarity 134hp FCV 60 miles per Kg H2   EPA                     = 50.58 MPGp

Toyota 2015 90KW/122hp FCV 68.3 miles per Kg H2  (NREL)            = 57.58 MPGp

Honda Accord Plug In Hybrid EPA    = 115 MPGp

*This is what is at stake as a society upon the outcome of PON-13-607.

Note. PHEVs are complex to dismantle into MPGp in a way that readily verified without special knowledge due to unknown interactions between wall charging, engine charging and charging by regenerative braking. This is not the case for HEVs and FCVs because these are closed systems with chemical fuel as the only input. While some contribution to CO2 emissions at the rate of 138MPGp should be considered for wall charging its 290Wh/mile electric performance, suffice to say that its 115 MPGe EPA combined milage will be a very close approximation to 115 MPGp. As such the Honda Accord Plug In Hybrid is unassailably better in terms of emissions than a 57.58 MPGp Toyota 2015 FCV, at least twice as good. It is at approaching three times as good as the 39.62 MPGp Hyundai Tucson FCV. There is not one FCV that comes even close despite the fact that neither PHEVs or EVs require any public investment in infrastructure.

To conclude the subject of emissions in relation to EVs. According to Dr. Shane Stephens-Romero, the other Co-President of FirstElement Fuel Inc while representing the National Fuel Cell Research Centre / UCI (a hat according to the website that he still wears in the capacity of ‘communications and outreach’). There is 12,500 GWh of ‘Curtailed’ energy in California annually of which 40% is wind power (curtailed = going to waste). Instead of which, as Dr Romero proposed, at $7.5cts per KWh it would be sufficient to power 1.2 Million FCV’s viaelectrolysis without adding to existing emissions. Perhaps that would be interesting if natural gas ever became three times more expensive, however, it seems reasonable to suppose that night time EV charging is a zero net emissions event that is already impinging to a small degree on curtailed night time wind energy. Most importantly, if true, 12,500 GWh would support 2,321,262 Tesla Model S P85+ vehicles at 15,000 miles per year, of which 40% is 928,505 vehicles with zero net contribution to emissions and zero absolute emissions respectively. More on energy efficiency below in the discussion regarding economics.

Drilling down to the sources of the enormous disparity between what we are being told, and what is.

This (dangerously false and misleading) marketing quote from Hyundai is the beginning of an illuminating quest for answers:

“According to UCI’s Advanced Power and Energy Program’s 2013 study, the hydrogen fuel cell provides lower total well-to-wheel emissions than a battery electric vehicle. For the Tucson Fuel Cell driver, this social benefit is achieved with greater utility, versatility and without compromises.”

Firstly excepting that it is a statement of fact (that the study implies what is claimed), the intended message of this statement is 100% false. As demonstrated, FCVs have far higher total well-to-wheel emissions, especially in California. On average similar to gasoline, terrible compared with diesel, and abysmal compared with PHEVs and EVs – despite being identical in concept to any other Fossil Fuel / EV hybrid.

What is more remarkable is the UCI Study itself. Aside from the academically irresponsible comparison with very dissimilar gasoline vehicles, the study is one of a number of similar pieces that illustrate a variety of theoretical but uneconomical methods of Hydrogen production depicted alongside elevated numbers for Grid-powered BEVs and no mention or depiction at all of BEV’s (Battery Electric Vehicles) powered directly from mature and rapidly maturing technologies of solar, wind and hydro electricity in current use on the grid. For a supposedly academic document the level of bias is astounding. This is a sales-support document and it precisely mirrors the same bias seen in materials from the California Fuel Cell Partnership. No mention at all of renewable powered EVs and specious comparisons to modern gasoline vehicles of more than twice the performance of FCVs.

The dots appear to connect in one Dr Tim Brown. Former employee of General Motors Inc.Consultant to the CEC on Hydrogen Policylead author of the California Fuel Cell Partnerships’ Roadmap documentSenior Scientist at UCI’s Advanced Power and Energy Program and finally co-President of FirstElement Fuels Inc, primary proposed awardee of $27.6 million in hydrogen infrastructure grants – and sure enough of it to claim a victory over due public due process by press release prior to those funds being approved.

Drilling still further down towards the original source of false policy advice publicity surrounding Fuel Cell Vehicles.

The original source of the disparity between real world numbers, and the policy-defining key assumption of 51% emissions reduction versus gasoline for Fuel Cell Vehicles appears to be this highly authoritative DOE NREL Study (note though that its participants are auto makers and big oil, a most improbable duet of inspiration for fossil fuel replacement).

In section ‘2.2.2 Greenhouse Gas Emissions’  there are two numbers as follows:

“Conventional gasoline mid-sized passenger vehicles emit 484 g CO2-eq/mile (grams CO2 equivalent per mile) on a well-to-wheels (WTW) basis”.

Note the similar language to ‘mid-sized vehicles’ picked up upon by UCI.


“The average WTW greenhouse gas emissions estimate for the Learning Demonstration fleet operating on hydrogen produced from on-site natural gas reformation was 356 g CO2-eq/mile, and the lowest WTW GHG emissions estimate for [off]-site natural gas reformation was 237 g CO2-eq/mile.”

51% is arrived as as follows:  237/484 = 49%  hence 51% less emissions than 100%.

100% of what exactly?

A 23 mpg gasoline vehicle.   (11132g / 484 = 23 MPGp )

Applying MPGp to the other two numbers is illuminating also:

237g = 46.97 MPGp   not exactly stunning for any 134hp HEV vehicle in 2014 or beyond.

356g = 31.27 MPGp  this ought to have been the reason to halt FCVs there and then:

Toyota 2015 FCV is 38.39 MPGp by this measure.

Hyundai Tucson FCV lags at 26.41 MPGp.

This is the result of producing hydrogen at the refueling station thereby losing efficiencies of industrial scale production.

As previously mentioned, an example of a modern 23 mpg EPA-rated vehicle is a 350hp 2014 2014 Porsche 911 Carrera 4.  It is necessary to go back 20 years in gasoline ICE technology to find 23 mpg vehicles of similar 122-134hp performance currently on offer from FCVs. For example a 23mpg 1994 Honda Accord is was a 130hp vehicle.

To state that an FCV has 51% better emissions than a 350hp Porsche 911 or a 1994 Honda Accord is evidently not a like for like comparison facing consumers, neither is it a fair comparison of technologies. A 350hp FCV would clearly require more emissions than a 122hp or 134hp FCV.

As a reminder: EPA figures for the current model Honda Accord PHEV out performs the 122hp 2015 Toyota FCV 2:1 in terms of emissions, while at 195hp offering considerably higher driving performance.

Energy Economics 101. Where does the hydrogen highway lead?

It is perhaps fair at this juncture to conclude that the California Energy Commission, and the public interest is at gross risk of being taken for fools.

Essentially unless environmental policy calls for public investment from the State of California to hasten to the aid of principally Japanese, Korean and German controlled auto makers to eliminate the competitive threat posed byCalifornian industry to the unchained proliferation of hydraulic fracturing, there can be no rational justification for public funds to be applied to un-sequestered steam reforming. Neither to relieving the fossil fuel industry of the capital cost associated with releasing CO2 emissions from natural gas in California in the name of green energy. Unfortunately that is exactly what the hydrogen lobby stands for.

It is impossible to concur with the advice on record to the California Energy Commission from First Element Fuel Inc, that essentially 90% of the commission’s funding for hydrogen should be applied to steam reforming of natural gas on the promise of jam tomorrow in terms of emissions. From the same letter:

‘100% renewable fuel is a goal that the industry must strive for. But, the realities of the developing hydrogen refueling industry necessitate pragmatic near-term solutions.’

On the contrary as demonstrated below, the entirely inevitable economic outcome of funding natural gas based hydrogen infrastructure will be to create a Trojan Horse. That is to invite freely-polluting and super-funded competition to fossil fuel replacement at the heart of the renewable energy and sustainable transportation sectors from where it may best defend shareholder value from the risk of being replaced. Fossil fuel derivatives publicly endorsed as “green energy” is already precipitating a travesty of both public and private sector resource-misdirection as well as media confusion resulting from the blurring of boundaries between investing for emissions and for emissions-reduction simultaneously under the banner of “green”.

Why it is inevitable that the ‘hydrogen highway’ is a one-way street to a heavily polluting fossil fuel future.

Direct compatibility with renewable electricity strongly favors a continuing trend towards an emissions-free transportation future (i.e. real well to wheel) in the case of Electric Vehicles owing in particular to the cascading price of solar electricity.

Despite much misleading references in marketing materials (and sadly a rash of economically-disconnected idealism in well-meaning scientific circles that is readily seized upon by lobbyists to divert attention from natural gas), there are no such parallels to an economically realistic pathway towards primarily emissions free transportation based on Hydrogen Fuel Cell Vehicles. The price of hydrogen feedstock in the form of natural gas is extremely low averaging around $5 per mmBtu = (293KWh or 1055MJ heating energy). That translates to about 3.4 US Cents as electricity or about 91 US Cents per Kg Hydrogen in energy costs alone (not counting operational expenses, return on capital to bring it to market).

Thanks to prolific hydraulic fracturing the universal abundance not of hydrogen but of natural gas is overwhelming. If it were not for the unwanted emissions of CO2 and CH4 (as well as mercury vapor, hydrogen sulfide, radon etc) and groundwater pollution with anything from barium to benzine primarily related to associated gas drilling and ablight on the natural landscape, natural gas could be an energy panacea. Hence the strong incentive to deal withvoter and consumer concern for the environment as an economic nuisance.

Chemical energy for transportation, hydrogen included, inevitably favors the economics of chemical feedstocks.Abundant natural gas feedstock from the hydraulic fracturing of shales contains the energy potential for self-disassembly into Hydrogen and CO2 via the process of steam methane reforming and as a result it is the simplest, cheapest and most economically unassailable source of hydrogen, best equipped to see off meaningful competition from electrolysis, biofuels and waste-stream reformation – so long as vehicles are chemically and not electrically powered.

Some calculations to get at the specifics:

Renewable energy offers 2.57 miles for every 1 KWh of renewable energy even in a powerful (300KW) EV after grid and charging losses, and 3.03 miles for an FCV-equivalent (100KW) EV.

The same 1 KW of renewable energy (at 54.65 KWh/Kg) after 39% conversion losses via hydrogen would carry a modestly performing 100KW (134hp) FCV only 0.86 miles (47mpKg Tucson) or 1.24 miles (68mpKg Toyota).

In reverse, the disparity is significant but far less marked.

1 KWh of natural gas heating energy (1/13.1KWh/Kg LHV energy/3.629 Kg Ch4 per Kg Hydrogen) producing 0.021Kg of Hydrogen will take a hydrogen FCV between 0.987 miles (Hyundai) and 1.428 miles (Toyota).

The same 1 KWh of natural gas heating energy after a typical 50% conversion loss in natural gas electricity generation and distribution will take an EV, counting an additional 8% charging loss, between 1.39 miles (300KW Tesla Model S EV @330Wh/mile) and 1.63 miles (100KW Chevy Spark EV @280Wh/mile).

From these figures it is possible to calculate fundamental cost per mile economic break-even in either direction in three different hypothetical scenarios comparing a 100KW Chevy Spark EV to a 90KW 2015 Toyota FCV.

  1. If EVs entirely dominate FCVs.  Renewable energy hits break even per mile vs Natural Gas electricity generation at 3.03/1.24 = 244%  of the cost of natural gas. For example if natural gas costs $5 per 293 KWh (true on average) Solar can compete in terms of cost per mile at $12.20 per 293KWh or 4.16 US Cents / KWh.
  2. If EVs and FCVs co-exist. Renewable energy hits break even vs fossil fuel powered FCVs at 3.03/1.428 = 212% of the cost of natural gas. (3.61 US Cents / KWh).
  1. If FCVs entirely dominate EVs as a result of publicly funded anti-competitive practices. Renewable energy converted to hydrogen hits break even with fossil fuel powered FCVs at  1.24/1.428 = 86% of the cost of natural gas. This is the disaster for renewable energy for transportation and the environment that PON-13-607 and initiatives like it will bring about at the public expense assuming consumers cooperate in the purchase of FCVs. The answer is 1.47 US Cents per KWh to be competitive with natural gas.

These numbers represent the economic life and death of our generation’s bid for emissions free and renewable powered transportation. 

We are within three to six years of it being cheaper to run an EV fleet on utility scale solar than it is to power an EV fleet via natural gas. But with an artificially imposed societal choice of FCVs based upon false promises of emissions reduction that very goal is pushed out by approximately 12 years of additional entrenchment in a fossil fuel transportation economy with corresponding emissions and loss of investment in useful progress on the subject of emissions reduction.

There are two economic conditions for these cost comparison scenarios to remain true and these are as of this moment both in the hands of the California Energy Commission to determine the outcome and to set the precedent:

  1. The cost of hydrogen infrastructure must be free of charge to the fossil fuel industry (paid for by public funds). Amortizing that cost and risk of consumer rejection of FCV technology is never accounted for in the cost of Hydrogen.
  2. There must be no accounting for the cost of CO2 sequestration during the production of hydrogen – instead there must be a carte blanche license to pollute. At an incremental $3.50 per Kg H2, 90% clean hydrogen as a result of sequestering the CO2 outputs of SMR cost between 50% and 100% more than the $7.00 to $3.50 figures typically cited.

While it may well be the case that neither the national energy budget nor the US economic budget in the broader appears possible to balance without efforts to displace foreign oil imports with domestic natural gas, it clearly does not follow that a massive public private partnership convened to starve out innovation in US generated renewable energy and tremendous advances made in California in the Electric Vehicle business serves any purpose that is supportable in the broad light of day

It is not as though there is no easier solution for the Auto and Natural Gas industries either:

While it is true that renewable electricity cannot compete to fuel FCVs, natural gas is currently highly competitive 14 – 65% better off supplying electricity to EVs than Hydrogen to FCVs. Meanwhile:

Turbocharged CNG vehicles are a far superior technological answer to the use of natural gas in transportation and far closer to the native skills of the auto industry to produce at an attractive product at an attractive price. This(Hyboost) technology is the perfect technological solution for a mild-hybrid, low emissions, high performance CNG vehicle with regenerative breaking that will certainly exceed the performance of Fuel Cell Vehicles in every regard, including emissions, without having to lie to consumers about emissions credentials. It is beyond reprehensible that this technology has been overlooked. Even without Hyboost:

“With a dedicated solution, you get much better performance and efficiency,” says Wach. He points to the attributes of a Volkswagen Passat with a 1.4L engine using both a supercharger and turbocharger, rated at 150 hp and emitting [190.4] g/[mile] of CO2, the equivalent of 51 mpg”

Best case NREL performance? 237g/mile for a 134hp (probably the 122hp) FCV.

Fact, natural gas is an economically important fossil fuel (we know) that includes the equally fossil hydrogen ions. How does that excuse missing a trick like this?

A very straight forward example of an approach to natural gas emissions reduction with public funds:

It is very hard to ignore the fact that $200 Million of emissions reduction budget could provide the taxpayer with the guarantee of millions of tones of CO2 reduction at precisely $193Kg CO2 per tax payer dollar just by going to where the pollution can best be found. Were that budget to be applied to sequestering the emissions of a single 500 MW combined cycle gas generator running at 85% max load, this would be enough to power 640,055 high performance 300KW EVs or 754,350 100KW EVs on natural gas 90% emissions free with nothing to spend on refueling infrastructure. Alternatively the same natural gas would deliver hydrogen power for 698,301 modest performance Toyota 90KW FCVs while releasing  38,846,462 Metric tones of CO2 into the air over California during a 20 year period with no budget to spare after paying for 100 hydrogen refueling stations as an enabler – if $200 million is enough (average 1995 refueling per station per day). All vehicles 15,000 miles per year.

These choices are of course within the remit of the California Energy Commission at this moment. Whether or not to defray the cost of entry for a polluting cuckoo in the nest in green energy sector, and whether or not to impose or to waive the mandatory sequestration of CO2 during SMR as a gatekeeper to entry. 

Ultimately, the defining advantage for hydrogen produced by natural gas for Fuel Cell Vehicles is the ability to pollute while claiming to be green. It is not good enough that images of celebrities drinking distilled exhaust emissions sets the standard of public education on such a pivotal societal choice.

Naturally it does not help matters that the jurisdiction of the CARB Zero Emissions Vehicle program is simply a dividing line that defines where to pollute and not whether or not to do so.

In summary

  1. Fact. There is inherently no emissions advantage in Fuel Cell Vehicle technology when compared with equivalent gasoline HEVs or diesel ICEs and policies seeking 51% or 55% emissions reductions vs gasoline are misinformed.
  2. EVs are inherently a more efficient and economical per mile usage of natural gas than FCVs.
  3. There are far better and easier ways to make natural gas powered vehicles than FCVs.
  4. There are far more effective ways for $200M USD to deliver emissions reductions.
  5. There are deep concerns to be addressed in the area of false marketing surrounding FCVs, consumers are being systematically mislead by claims of large total GHG reductions that are not true.
  6. The economic course-correction from renewables to fossil fuels implicit in the public funding of hydrogen refueling infrastructure holds unparalleled dangers to efforts to tackle GHG emissions.
  7. Inviting fossil fuels to participate in the green energy economy without mandating full sequestration of emissions from the outset is a violation of the contract of public trust entered into by FCV marketing slogans heavily suggestive of well to wheel emissions free transportation with additional complications for ethical investing.
  8. Facilitating FCV entry to market evidently before commercial maturity appears to conflict excessively with the interests of the Californian taxpayer — Unwarranted and artificial competition to a significant employer in the Californian tax base (Tesla Motors Inc.), harassment of the same ahead of a significant ZEV launch, likely $100K per vehicle tax deductible losses in State (Hyundai & Toyota), ZEV Credits claimed with questionable merit, cannibalization of low-budget-impact ZEV market with high budget-impact ZEV infrastructure expenses, taxpayer accepting unnecessary burden of risk with no emissions reduction rewards and no visible guarantee of economic reward.

Accordingly there are two serious ethical issues beyond the pressing requirement to review whether it is in any way justifiable or appropriate to allocate public funds to fossil fuel interests in the green energy sector. Especially at the juncture of utility-scale Solar Photovoltaic Energy production rapidly approaching grid parity in California and on the eve of the anticipated 2015 unveiling of a Californian designed and built EV that is slated to achieve unsubsidized range, cost and performance parity with the average new vehicle purchased in the State. The latter reasonably likely to be the primary driver of the current auto industry fervor to rush FCVs to market long before they are commercially viable to produce. Behavior that is uncomfortably reminiscent of a similar moves to play the hydrogen card before officers of CARB in the late 1990s and early 2000s.

These concerns are as follows:

  1. Probable cause to investigate material conflict of interest between the advice given to the CEC directly from Dr Tim Brown while overtly representing UCI and also indirectly via the CAFCP prior to applying for, and subsequently securing the potential award of $27.6 million in public funds in the capacity of Co-President of FirstElement Fuel Inc. The advice given and publicised rests in particular on comparative models of well to wheel emissions data according to type and source that includes economically questionable cases of renewable sourced hydrogen, but the inexplicable exclusion of the 78-85% well to wheel efficient use of renewable power in the case of Electric Vehicles as well as likely initiating, perpetuating and allowing to be repeated when known to be false, evidently misleading generic claims of emissions benefits that are nonexistent more than to claim an ordinary feature of ICE vehicles such that any 42mpg gasoline vehicle has half of the emissions per mile produced by any 21mpg gasoline vehicle owing to its smaller engine size and more limited driving performance.
  2. Probable cause to contemplate an antitrust type scheme to starve out competition from renewable and EVs in the transport sector prior to raising the cost of hydrogen from $0.00 to market value as the most likely economic motivation and intended use to which parties including for example Hyundai Motor America, Toyota Motor North America and others expect to leverage from California’s proposed investment in hydrogen fueling infrastructure, as evidenced in the marketing materials from these entities, Hyundai in particular to be the first to declare pricing, including Hydrogen at $0.00. Materials explicitly target the displacement of Electric Vehicles, not gasoline or diesel vehicles accompanied by sales policies that appear designed to rush vehicles to the market considerably below the cost of manufacture (cited at$145,000 and at more than $100,000 respectively) serving as tax deductibles in the State at likely $100,000 per unit and including unlimited free hydrogen refueling in the case of Hyundai (Toyota pricing and consumer incentive policy as yet unknown). Policies that together with misdirection on the subject of emissions and environmental impact appear aimed at artificially distorting the market in California.

In closing.

Thank you for your time and attention. I would be gratified to learn that this work has been of service to the Commission, to the people of California and to the far broader constituency that looks to the California Energy Commission for leadership in what I am confident is a defining moment of truth regarding the challenges and responsibilities facing this generation.

Please choose wisely.

Yours truly,

Julian Cox

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has had career-long vocation focussed on the positive convergence of economics, energy, transportation, and care for the environment.


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