## California ARB posts final modifications for ZEV rule on fast refueling/battery exchange for public comment

##### 05 April 2014

The staff of the California Air Resources Board (ARB) has posted for public comment current final modifications for the Zero Emission Vehicle Regulation for 15 days. (Earlier post.) Statutorily, depending upon the comments received, ARB staff may either make further modifications and resubmit to Board for further consideration; failing that, the Board will adopt the new regulatory language.

These final tweaks to the ZEV rule involve the allocation of ZEV credits for different types of ZEV vehicles and the handling of the associated fast-refueling accreditation, which includes the possible use of battery-swapping.

Background. At the 24 October 2013 public hearing, ARB approved for adoption proposed amendments to the ZEV rule, which requires auto manufacturers to develop and commercialize ZEV (e.g., plug-in hybrid, battery-electric and hydrogen fuel cell technologies).

The modification addressed three minor problems: changes to effectuate an agreement between other states adopting California motor vehicle emission standards including the ZEV regulation (Section 177 states) and regulated manufacturers; provisions to ensure ZEVs are delivered for sale in California every year; and modifying the fast refueling definition;

The Board also directed staff to incorporate further modifications to the regulation’s fast refueling credit provisions to ensure that such credit for Type IV and V ZEVs through 2017 model year only be awarded based on actual use and be fuel neutral.

California categorizes ZEVs by Type (I to V), based on the zero-emissions range. The longer the range, the higher the Type and the more credits generated for the automaker. Automakers can use ZEV credits to meet their statutory requirements for ZEV sales in California, or, as is the case, for example, with Tesla, sell the credits to other automakers as a non-insignificant revenue stream.

Under provisions adopted in 2001, ZEVs with the ability to refuel to 95% of full capacity within 15 minutes are allowed to earn more credit under the Type IV and Type V ZEV definitions. The Board directed staff to retain the fast refueling accreditation, so long as it is based on real-world use of the fast refueling and maintains fuel neutrality.

Modifications. In these latest modifications, staff alters existing language to require manufacturers to submit fast refueling usage data in order to qualify for fast refueling credits. Manufacturers seeking to earn fast refueling credits will be required to submit the miles attributed to fast refueling during 12 consecutive months and the total miles driven for all vehicles of that vehicle model during the same 12 months.

This requirement would not apply to manufacturers of fuel cell electric vehicles.

The original modifications had removed the ability to qualify for fast refueling by battery swapping; that provision is now stricken, but is replaced with the need to demonstrate the utility of the system.

For Model Year 2009 through 2017, a vehicle will be considered a Type III, Type IV or Type V ZEV if it has the capability to accumulate at least 95 miles of UDDS range in 10 minutes or less; at least 190 miles of UDDS range in 15 minutes or less; or 285 miles of UDDS range in 15 minutes or less, respectively.

For Model Years 2015 through 2017, inclusive, “capability to accumulate” means the ZEV’s refueling system has been demonstrated to the satisfaction of ARB’s Executive Officer as actually accumulating the miles required under this subdivision within the given time period for the claimed ZEV type, based on refueling events. To receive fast refueling credits manufacturers must apply to ARB with the information and documentation.

Modifications to ZEV rule

The required information and documentation includes total fleet miles attributed to fast refueling use in a 12 consecutive month period and total fleet miles in the same 12 month period; and documentation of each fast refueling event.

Fast refueling credits are to be calculated as follows:

• Fast refueling miles / total miles = M
• 4 credits = ZEV credit per each Type III ZEV
• 4 + (M) x (1 credit) = ZEV credit per each Type IV
• ZEV 4 + (M) x (5 credits) = ZEV credit per each Type V ZEV
ZEV Credit table
Tier Calendar Year in Which ZEV enters service
2009-2011 2012-2017
NEV 0.30 0.30
Type 0 1 1
Type I 2 2
Type I.5 2.5 2.5
Type I.5x n/a 2.5
Type II 3 3
Type IIx n/a 3
Type III 4 4
Type IV 5 4 to 5
Type V 7 2012-2014: 7
2015-2017: 4 to 9
Underline indicates modification

So, where is the extra credits for BEVs as they can be recharged at home so they start each day fully charged? Oh, that's right...CARB is a shill for the hydrogen lobby that ignores these REAL WORLD uses and focuses on some randomly made up bullsh*t about 95% recharge in 15 minutes. EXACTLY enough to exclude BEVs.

Go F yourselves CARB and all the disgusting bastards who *own* you.

Video below of what is happening in California at municipal wastewater treatment plants using fuel cell technology to produce 3 value streams of electricity, hydrogen and heat all from a human waste! This is pretty impressive in my opinion for hydro-refueling infrastructure.

"New fuel cell sewage gas station in Orange County, CA may be world's first"

http://abclocal.go.com/kabc/story?section=news/local/orange_county&id=8310315

"It is here today and it is deployable today," said Tom Mutchler of Air Products and Chemicals Inc., a sponsor and developer of the project.

2.8MW fuel cell using biogas now operating; Largest PPA of its kind in North America

http://www.fuelcelltoday.com/news-events/news-archive/2012/october/28-mw-fuel-cell-using-biogas-now-operating-largest-ppa-of-its-kind-in-north-america

Video:
DFC ERG Nat Gas / Fuel Cell Hybrid / Enbridge - Fuel Cell Energy
http://enbridge.rawintegrated.com/hybrid/hybrid_complete.html

Germans are in favour of fuel cell cars
http://www.platinum.matthey.com/news-and-events/news-articles/2013/march/21st/germans-are-in-favour-of-fuel-cell-cars

effectuate

Is that a word?

Merriam-Webster says yes.

Yes it is, but not widely used. I wonder if people use big words to sound important,

DaveD, I am forced to agree with you.  PHEVs were quite feasible with 1970's technology and would have been a major asset for pollution control and petroleum conservation, but CARB's rules demanded BEVs with performance standards set well above the state of the art.  The escalation of standards had the effect of making it appear that progress was being made while making certain that it would get to market much later if at all.  If I had the ability to probe into the backgrounds and connections of the members of CARB, I'm pretty sure I'd be able to make a good case that such was their deliberate intent.

Sooo... when CARB morphed the Tesla Model S from a Type III to a Type V, did this reflect a bias against BEVs? Let's be clear: the Type V rating requires a 300+ mi range and fast refueling (less than 15 minutes). The Model S has an EPA rating of 265mi, and the "battery swap" DOES NOT EXIST for Model S customers ANYWHERE. It was demonstrated for a press conference, and that's it. The result is $M more potential value in ZEV credits to TSLA for Model S's delivered from October 2013 through December 2014 for performance characteristics the car does not possess. I'm not saying you don't have a point that CARB has been magnanimous to FCVs (more than they deserve based on technical and market merit). But they are not exactly being cruel to luxury BEVs. Also, FWIW, search with the terms "Daniel Sperling" (the only CARB BoD member with serious technical credential) and "fuel cell". You'll get a lot of hits, including his previous title as co-Director of the UC Davis Fuel Cell Center. They are a life's work for him. He didn't indicate a bias in his Feb speech at SAE, but you might have seen it differently. CARB like any bureaucracy, exists only to see that it CONTINUES to exist,and provide sinecures for its non-elected, well paid aristocracy. Chartered to clear California's polluted air, it now serves only one of two states that continues to suffer from air pollution, by the continually tightening measurements of EPA Air Quality. CARB has imposed manufacturing requirements that automakers waste billions to provide as a handful of manufactured products. Monies that could much better be spent elsewhere to accomplish more cleansing. It still has mandates for FCEVs that will cost hundreds of thousands per copy, and require an infrastructure for$ billions more, and are never going to replace working alternatives.

Why do we still have two organizations, CARB and EPA, duplicating each others work? One has cleansed 48 states missing only in a couple of counties in Texas. CARB has failed in its one state.

It is long past time to pension them off, and close CARB down.

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