Comment Log Display

August 10, 2007

Clerk of the Board
Air Resources Board
1001 I Street
Sacramento, CA  95814

RE: Zero Emission Bus Regulation – Modified Text and Resolution
06-28

UTC Power greatly appreciates the efforts of the California Air
Resources Board (CARB) members and staff to address concerns
regarding the proposed revisions to California’s zero emission bus
regulations.  We also appreciate the opportunity to submit these
brief comments on the modified text and Resolution 06-28.

UTC Power has been involved in fuel cell bus applications since
1998 and our PureMotion power plant has provided propulsion for
buses deployed in Washington, DC, Spain, Italy, Belgium,
California, and Connecticut.  We have been an active participant
in the subject proceeding and testified before the Board on this
matter on October 19, 2006.  We have consistently stressed our
concerns regarding the potential chilling effect changes in this
rule could have on fuel cell supplier confidence and investment as
well as the need to sustain market demand while technology
validation efforts continue.

UTC Power would like to comment on the Board's direction to staff
to consider implementation criteria for Durability/Warranty and
Reliability.  The Durability/Warranty criterion of 20,000 hours is
a very high bar to set for an emerging bus drive train technology. 
Suitable validation for such a criterion would require several
years of fielded bus operation with a statistically significant
number of buses fielded (validation fleet).  

The delay in the California zero emission bus purchase requirement
will postpone the introduction of a meaningful validation fleet,
hence slowing the validation that would support a 20,000 hour
warranty or life prediction.  A 20,000 hour power train warranty
rivals the extended warranty offered for internal combustion
engine bus drive trains that have been in development and
production for over 100 years.  UTC Power requests that the
revised Zero Emission Bus regulation emphasize that the 20,000
hour criterion is a commercial product requirement and that fuel
cell technology that is demonstrated to be improving at a rate
that would allow full commercial life in the future would be a
candidate for a minimum purchase requirement in California.

UTC Power would also apply this same logic to the 10,000 miles
between propulsion related road calls (MBPRC) reliability metric. 
That figure is representative of today's commercial products and
will only be properly field validated after several years of
operation with a statistically significant population of fuel cell
buses in operation.  It is very unlikely that field validation to
support a 10,000 MBPRC metric will be complete when the board
considers the staff recommendations in mid-2009.  

In summary, UTC Power would like the Durability/Warranty and
Reliability implementation criteria to be considered in the spirit
of a developing technology where the trajectory of these criteria
is given as much consideration as the absolute value during the
2009 staff evaluation.  Additionally, we ask that the criteria be
lowered in accordance with the practical limits of field
validation between now and the staff evaluation.  Specifically, we
ask that the Durability and Reliability criteria be lowered to
>10,000 hours and >5,000 MBPRC (the lower threshold for today's
diesel fleets), respectively.

Thank you for the opportunity to comment.  Please feel free to
contact me if you have questions regarding this issue.

Sincerely, 

Michael Tosca 
Senior Product Marketing & Sales Manager 
UTC Power 
195 Governor's Highway 
South Windsor, CT 06074 
860-727-7324 
michael.tosca@utcpower.com 
www.utcpower.com