ChatGPT & DALL-E generated panoramic image of a major highway truck stop exclusively servicing hydrogen fuel cell vehicles, including trucks, cars, and motorcycles.

ICCT Hydrogen Trucking Scenario Would Require Europe To Ban All Electric Vehicles

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Improbable and unrealistic scenarios are excellent tools to explore the odder aspects of our universe. Schrödinger’s cat being both alive and dead is a case in point. The trolley problem which had a massive resurgence in popularity and cultural awareness with the rise of autonomous cars is another.

The thing about these scenarios is that no one pretends that they are remotely realistic or proposes seriously a world in which they happen. Quantum physicists do not create experiments with cats, boxes and radioactive material in order to test them, and would be horrified if anyone suggested it. Similarly, traffic planners and ethicists don’t strap people to tracks and give some about-to-be-scarred-for-life experimental subject the task of picking between killing one or many people. They are simply useful thought experiments.

Enter the International Council on Clean Transportation’s (ICCT) new total cost of ownership report on decarbonizing trucking in Europe, specifically their hydrogen trucking scenario. It’s not a useful thought experiment on quantum indeterminacy or ethics. It purports to be a realistic scenario worth seriously considering for policy makers in Europe and probably globally. It fails miserably.

The big problem with the hydrogen vs battery electric truck scenarios is that the energy costs per kilometer for hydrogen trucks are merely 50% higher in 2030 and only 10% higher in 2050 than for battery electric trucks. The hydrogen scenario assumes that green hydrogen is manufactured at the truck stop using electricity delivered through local utility’s wires. Making hydrogen and using it in a fuel cell vehicle requires three times as much electricity as using electricity in a battery electric truck. The costs in any real world scenario should be three times higher just based on that.

A Nikola or Hyundai N3 truck — N3 is the European equivalent of a North American class 8 truck — pulling into a truck stop for a load of green hydrogen manufactured at the truck stop is clearly getting deeply preferential electricity rates if their energy cost per kilometer is only 10% higher instead of three times higher.

Let’s explore what would have to be true for that scenario to make any sense.

Think back to your road trips. I’ve taken many in Europe, North America and even a few in Australia, New Zealand and Brasil. A feature of road trips are truck stops. I’ve been in a lot of truck stops on my road trips, and passed vastly more of them without slowing down. They are a staple in movies and tv shows too, and the depiction of them is usually fairly realistic. Think about the last few truck stops you were in or passed by. What did you see?

Most likely the truck stop had most of the following. Big trucks, of course, refueling at pumps set aside for them or parked in a portion of the lot where they fit. But also mid-sized trucks and panel vans, the local utility vehicles or trades’ vehicles that keep a lot of things working. And a lot of cars, pickups and SUVs. If it’s the summer time, probably a motorcycle or two. Quite possibly a lumbering recreational vehicle. Maybe one of the pickups or SUVs is towing a boat. Police cars. Postal vans. A high likelihood of Amazon vans these days of course.

There’s a restaurant of varying quality, usually a big chain these days. There are truckers, delivery drivers, families, motorcyclists and cops drinking coffee or soft drinks or water and eating food of varying degrees of healthiness. There might be a gift shop, but there’s certainly a place to buy road food, soft drinks and eye-catching gizmos.

This is our setting. When we talk about decarbonizing trucking, a lot of it comes down to putting electric chargers or hydrogen fuel pumps into this truck stop. There are innumerable additional options for electric chargers, of course, but when it comes to putting molecules into tanks in trucks, then truck stops dominate the scenarios.

The ICCT’s battery electric trucking scenario is defensibly realistic. In this scenario, the trucks are electric, the SUVs and pickups are electric, the cop cars are electric, the motorcycles are electric and the like. Nothing is unusual about this. This is just what the future will look like. It already exists in fact. Teslas and Rivians pull into truck stops to recharge and for the drivers’ and passengers’ biological imperatives. Riders on Zero and Energica electric motorcycles pull in to recharge and have a coffee. Ford F150 Lightnings are pulling into truck stops in North America. The truck stops are still pumping a lot of diesel and gasoline, but increasingly they are pumping electrons.

The truck stop is purchasing electricity from the local utility at local commercial electricity rates, which the report puts at around €0.20 to €0.24 per kWh. This is completely realistic as well. It’s a truck stop, not a data center or an upscale outdoor adventure gear outlet. Increasingly, truck stops will have battery storage and solar panels as well as grid connections, enabling them to both generate some electricity locally but also to buffer the demand and supply both on the peak power side but also to reduce drawing electricity from the grid during peak demand periods.

That’s all ignored in the ICCT report, which is fine, up to the point where they insist that truck stops will be paying massively more during peak demand periods and won’t be buffering electricity with battery storage. That’s a quibble, and for a policy comparison of hydrogen and battery electric trucking, it’s a defensible if naive choice.

But then there’s the hydrogen scenario. In it, the truck stops have big electrolysis facilities, big hydrogen storage tanks and big hydrogen compression facilities. They make their own hydrogen with electricity that flows through the local utility’s wires into the truck stop.

Quite rightly, the ICCT realizes that €0.20 to €0.24 per kWh electricity would result in at minimum €12 per kilogram hydrogen just for the electricity costs, with a few more euros per kilogram for the millions of euros that the hydrogen manufacturing, storage, compression equipment costs. Call it €15 per kilogram costs, and then add profit for the organization that owns the truck stop. Let’s make it €16 per kilogram.

And they realize that there’s no way anyone would consider that a reasonable price to pay for energy for a truck or anything else if there were any alternative. So they create a scenario, which could exist for a handful of truck stops, but far from all, where there are wind and solar farms local enough to the truck stop that they can enter into power purchase agreements (PPA) and a contract with the local utility for preferred rates as the utility benefits from all those green electrons in their electricity supply.

After some back and forth, because they don’t actually provide the electricity rates used for their less than €6 per kilogram green hydrogen in either the total cost of ownership report or the earlier report that they depended on — yes, that’s an absurd oversight in a total cost of ownership publication —, it appears that they are using about €0.10 per kWh, half or less than half of commercial rates. They appear to think that they will get that 24/7/365 at the same rates regardless of peak demand periods because they will run their electrolyzers only when electricity is at that rate, avoiding peak demand periods. That’s not a terrible assumption, just a bit naive. They also ignore amortizing the massive capital costs of all of the hydrogen gear and profits for the truck stop firm. Also a quibble compared to the really unrealistic parts of the scenario.

For some truck stops, these electricity rates might even become a reality, but it’s a minority of them. PPAs are fairly sophisticated energy contracts that the average corporation doesn’t even know exist, and the conditions for a local utility to provide preferred rates as part of the contractual structure are limited. Imagine a huge truck stop on the edge of a major city in a densely populated part of northern Europe, for example. It’s unlikely to have the conditions for a renewables PPA contract with the local utility that reduces commercial rates. The ICCT imagines that this scenario will be applicable to every single truck stop, which is somewhat fantastic, but not the actually deeply unrealistic part of this scenario.

I know. The unrealistic things I’m waving away are mounting up rapidly, but you can kind of squint and see why people would consider them realistic if they were in the bubble of hydrogen for energy. PPAs exist. Electrolysers exist and are getting a bit cheaper. Hydrogen fuel cell N3 trucks exist, kind of. There are a deeply limited number of hydrogen refueling stations today, most of which are pumping black hydrogen but could pump green hydrogen.

No, the deeply unrealistic part is that they think that this cheap electricity would not be available to battery electric vehicles. In their comparative scenarios, none of the myriad of electric vehicles which also exist in the real world are allowed to use the cheap electricity used for making hydrogen. Somehow, the truck stop is supposed to use the electricity only for making hydrogen, not for charging electric vehicles.

In their fantasy world, Tesla Semis and Daimler EM2s that pulled into the truck stop would be forced to pay full commercial rates, while Nikola or Hyundai electric class 8 trucks would be receiving hydrogen manufactured with electricity that was half or less the price.

This, however, is the real world. What they posit is an unreal fantasy world where electric N3 trucks don’t exist, and further where none of the other myriad smaller electric vehicles exist. They posit an imaginary world where only hydrogen-powered vehicles can be allowed to exist, because it’s the only thing that could possibly make sense of their refusal to provide the same rates of electricity to the same class of trucks using the same truck stop. Yes, despite the reality that there is no market for lighter hydrogen fuel cell vehicles anywhere in the world, their scenario inevitably leads to the conclusion that only hydrogen fuel cell vehicles will exist.

Why would I say this? Well, if there were battery-electric, N3 trucks, they would be recharging at the same truck stops. They would be using megawatt-scale chargers. They would be receiving the same energy price benefits as the hydrogen trucks. They would have fuel costs a third at minimum of the hydrogen N3 trucks that were also using the facility.

Who in this world would bother to buy a hydrogen fuel cell truck? Further, if this fictitious hydrogen truck stop was competing with the more numerous gas stations that service light vehicles, also a staple of highways, everyone would know that the truck stop’s electricity was a third the price as the gas station and everyone would be piling into the hydrogen equipped station to refuel. If battery electric vehicles existed in this scenario, the truck stock would be swarmed and the gas stations would be empty.

The only way that this scenario is remotely possible is if Europe bans all battery electric vehicles. No Tesla Model Ys. No BYD Attos. No VW ID.4s. No electric motorcycles. No electric Amazon vans. No Quantron delivery vans (which given their terrible range wouldn’t be a particular loss).

There’s another unrealistic condition where they might be able to justify this, and it’s possibly what they are thinking. Right now hydrogen refueling stations aren’t in gas stations or truck stops because there are so few of them. They are dotted around the place as completely separate entities. They are very expensive and have few customers, so gas station and truck stop firms aren’t interested in them because they make no fiscal sense. They are set up by governments and hydrogen firms like OMV, the black hydrogen supplier of choice in Austria for example.

This other scenario has completely separate truck stops set up solely for hydrogen N3 trucks. No one else is allowed to use it. The truck stop doesn’t have the steady stream of light vehicles. No Tesla or Daimler N3 trucks are allowed. Only Nikola or Hyundai fuel cell vehicles are permitted. The truck drivers will hate that. Deeply inferior amenities. No tourists or surfers or cops to pass the time of day with. Just other N3 drivers.

Highways would have two of every truck stop. One would be solely for big hydrogen trucks. The other would be for literally every vehicle that uses the highways including big electric trucks.

Do I think either of those scenarios is remotely realistic? No, I think they are phantasmagorical. I think that the hydrogen local manufacturing scenario is magic realism, where some completely unrealistic thing is allowed and the rest of the world organizes itself around it.

But the ICCT isn’t Gabriel García Márquez, author of the astounding books 100 Years of Solitude and Love in the Time of Cholera. It is supposed to be an organization of policy-guiding analysts and researchers grounded in realistic scenarios.

As I’ve noted before, the only way that serious researchers and organizations could justify massively higher electricity prices for battery electric vehicles than for hydrogen fuel cell vehicles is if they have a deep bias in favor of hydrogen vehicles. Maybe they drive Toyota Mirais and think that the deeply inferior, hidden and barely used hydrogen refueling stations are normal. The ICCT’s report does a deep disservice to actual transportation policy discussions because they’ve create a fantasy scenario and are pretending it is a real scenario. And even then, they load costs onto electric and remove costs from hydrogen, further tipping the scale.

That even this degree of unreality can’t make hydrogen fuel cell N3 trucks cheaper to own and operate than battery electric trucks should have given them pause. But it didn’t. In the two weeks since they published the deeply flawed report they’ve been defending this choice, asserting that the scenarios were deliberate and methodologically sound. Their deeply flawed conclusion that hydrogen fuel cell trucks would only cost 10% more per kilometer to operate is still their official word on the subject.

Once again, the ICCT needs to retract this report. They need to retract the earlier report that found that hydrogen at trucking stations would be under €6 per kilogram. They need to assess where else this damaging fallacy has been permitted to stand and inform their opinions. And they need to fix the organizational biases around hydrogen that permit these reports to be written and go through multiple reviewers without anyone putting up their hands and saying that they are fantastical nonsense.

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Michael Barnard

is a climate futurist, strategist and author. He spends his time projecting scenarios for decarbonization 40-80 years into the future. He assists multi-billion dollar investment funds and firms, executives, Boards and startups to pick wisely today. He is founder and Chief Strategist of TFIE Strategy Inc and a member of the Advisory Board of electric aviation startup FLIMAX. He hosts the Redefining Energy - Tech podcast ( , a part of the award-winning Redefining Energy team.

Michael Barnard has 689 posts and counting. See all posts by Michael Barnard