Comment Log Display

October 19, 2006
Clerk of the Board
Air Resources Board
1001 I Street
Sacramento, California 95814
RE: Comments on Proposed Amendments to Zero Emission Bus
Regulation
Dear Air Resources Board:
Hythane Company appreciates the Air Resources Board’s (ARB)
interest in providing bus fleets with an
opportunity to meet some of the obligations of the Zero Emission
Bus Regulation through the use of “zero
emission enabling technologies” such as Hythane® or other
hydrogen/natural gas fuel blends. We are
grateful that the ARB recognizes the important role that Hythane®
can play in easing the transition to zero
emission bus technology by transit agencies that have elected to
achieve emission compliance.
We are deeply troubled, however, by the minimal incentive that ARB
has chosen to provide transit
agencies that have already invested in the alternative fuel path
and are interested in further reducing their
emissions through the use of zero emission enabling technologies.
Although Hythane® and other
hydrogen/natural gas fuel blends can enable any transit agency to
integrate both hydrogen production and
dispensing in to their operations more cost effectively than fuel
cell technology, the approach suggested by
the revised rule will not encourage transit agencies to take this
important intermediary step.
Providing bus fleets with only a one year delay in the zero
emission bus purchase requirement in exchange
for the implementation of a demonstration project that
incorporates the use of zero emission enabling
technology is insufficient. This minimal delay does not offer
fleets any incentive to implement advanced
technology demonstrations and is therefore an ineffective means of
achieving ever lower emissions in the
present. Moreover, the amendments provide little incentive for
fleets to invest in demonstrations that
would facilitate the deployment the hydrogen fueling
infrastructure that is necessary for future deployment
of zero emission buses in California.
If leveraged appropriately, Hythane® can deliver tremendous
emission reductions for a fraction of the cost
of the proposed zero emission bus technology. As we presented to
staff, conversion of 30% of the existing
natural gas bus fleet in California to Hythane® would cost only
$37 million, would lead to the construction
of 40 hydrogen production/fueling facilities, and would yield
nearly 2,000 tons of NOx emissions over the
remaining useful lives of those buses. Thus, the development of a
real incentive to incorporate zero
emission enabling technologies would yield far more desirable and
cost effective results than the current
staff proposal.
We suggest amending the rule to allow for meaningful incentive for
zero emission enabling technologies.
A mechanism which would postpone the purchase requirement by the
same number of years that a transit
agency implements a demonstration project would be a good start,
as long as that demonstration project
yields the same or greater emission reduction benefit as if the
agency began to make 15% of its purchases
zero emission buses, per the current revised proposal. Thus, if a
transit agency implemented a
demonstration project in 2007 that yielded the same or greater
emission reductions as the purchase
requirement, the transit agency would not be subject to the
purchase requirement until 2014. Such an
approach would likely provide a real encouragement to transit
agencies to accelerate emission reductions.
Hythane® and other zero emission enabling technologies can provide
a real bridge to the zero emission
transit future that ARB envisions, but only if the agency finds an
effective means of encouraging it. With
the change to the amendment that we suggest, Hythane® and other
zero emission enabling technologies can
not only provide a link to a cleaner transit bus future, but can
also deliver real verifiable surplus NOx
emission reductions almost immediately.
Please don’t hesitate to contact me if you have any questions or
would like further information on
Hythane®.
Sincerely yours,
Roger W. Marmaro
President