Vehicle Technology and Aviation Bill

Written evidence submitted by UK Hydrogen and Fuel Cell Association (UK HFCA) (VTAB 10)


This Written Evidence is submitted by the UK Hydrogen and Fuel Cell Association (UK HFCA). The UK HFCA works to ensure that fuel cell and hydrogen energy can realise the many benefits offered across economic growth, energy security, carbon reduction , air quality and beyond. Through the breadth, expertise and diversity of our membership, we work to trigger the policy changes required for the UK to fully deliver the opportunities offered by these clean energy solutions and associated elements of the supply chain.

Key Points and Suggested Amendments to the Bill

· The UK HFCA supports the aims of the Bill and its intention to recognise and regulate new transport technologies.

· However, we believe that the terminology and definitions used to describe hydrogen fueled vehicles and hydrogen refueling stations is very misleading and confusing. As described in the section below, hydrogen has a key role to play in the evolving transport arena, and the current wording of the Bill fails to reflect this.

· In particular, in part 2 of the Bill 1.b notes "hydrogen refuelling point" means a device intended for refuelling a vehicle that is capable of being propelled by electrical power derived from hydrogen"; and in 1.c "a charge point or a hydrogen refuelling point is a "public charging point" if it is provided for use by members of the general public."

· We believe that 1.b should be re-worded as: "A hydrogen refueling point means a device where hydrogen is dispensed at the nozzle for use in any vehicle where hydrogen fuel is required." The additional explanation is completely unnecessary in terms of defining the technical function of the refueling point.

· In 1.c, the "public charging point" should only refer to electric charging points, whereas hydrogen refueling points for use by members of the general public should be referred to as "public refueling points". A hydrogen vehicle is filled, not charged, and is paid for in terms of £/kg in comparison to an electric charging point which is paid for based on the £/kWh.

· In addition, to help avoid confusion for consumers (and stakeholders, including policy makers), raise wider awareness, and minimize unanticipated bias across all available technologies, it would be helpful for Part 2 to be renamed "Ultra Low Emission Vehicles (ULEVs)" and to be divided into distinct sections such as  "Battery Electric Vehicles (BEVs)", "Hydrogen fueled vehicles", and / or other sub-sections, with clear headings and accurate definitions for each.

The benefits of hydrogen fueled vehicles

· Hydrogen fueled vehicles offer significant carbon reduction and air quality benefits:

o Fuel Cell Electric Vehicles (FCEVs) powered with locally generated renewable hydrogen have zero well-to wheel (WtW) emissions. Renewable hydrogen will increasingly become available from ‘stranded wind’ sources. Those powered by hydrogen produced from fossil fuels produce ~85g of CO2/km on a WtW basis. In comparison, a gasoline fuelled internal combustion engine produces approximately ~170g of CO2/km on the same basis. By 2030, increasing FCEV deployment could lead to total annual projected CO2 abatement in the UK of 3 million tonnes. In addition to CO2 reduction benefits, FCEVs offer significantly improved general air quality by eliminating all oxides of nitrogen and particulate matter from vehicle exhausts, thus addressing a growing area of societal concern.

o As well as FCEVs fueled by hydrogen, adapted conventional engines can also run on hydrogen (100% or dual fuel with diesel). In air, particulates and many other by-products of combustion with hydrocarbon fuels are reduced significantly. When emission control strategies are implemented and the combustion is carefully optimized, it is possible to gain the benefits of very low carbon and improved air quality from hydrogen within conventional engines.

o For simplicity, every kilogram of hydrogen used to displace diesel will save a gallon’s worth of CO2 emissions, whatever the vehicle or the technology the hydrogen is used in.

· The essential point is that as far as consumers are concerned, unlike electric vehicles where the vehicle needs "recharging" hydrogen vehicles fill up with hydrogen in the same way as conventionally fueled vehicles. Hydrogen fueled vehicles therefore do not lead to range anxiety (once sufficient refuelling stations are available) and their short refilling time (less than 5 mins) means that cons umers can be "ready to go" promptly. These are two of biggest factors deterring consumers from currently investing in buying an electric car or van, and are addressed by hydrogen fueled vehicles. Equally, the hydrogen refueling point can be integrated into normal fuel dispensing points, requiring very little change of behavior from the consumer’s perspective.

· The short refuelling time also works with the current design and function of forecourts, and current business models for the use of space, and facilities at fuel retail outlets.

· The process to make hydrogen for hydrogen fueled vehicles, contributes to the flexibility of the wider energy system by offering grid balancing services, a seasonal energy storage solution and an added value energy vector which has the opportunity to provide a positive value proposition for overall energy system. The time when hydrogen is generated can be set to suit the grid, rather than on demand and disconnects the demand for power from the vehicle use.

· On the contrary, BEVs constitute a very large electrical load I (in many cases the entire electrical load requirement of a typical domestic dwelling). Additionally, the timing of each recharge event is under the control of consumers. At the maximum level of uptake in the city battery electric vehicles would demand between seven and eight gigawatt-hours per year. Thus, if a significant number of BEV users choose to recharge their vehicles on the basis of lifestyle schedules or range anxiety concerns, rather than upon time-of-use electricity tariffs, then very substantial increases in power flows will occur in distribution networks at peak times and often at locations that do not currently have adequate electrical supply (such as car parks etc.). This will lead to increased use of high-carbon power plant, and will soon require significant investment in distribution network reinforcement. As highlighted, conversely, in the case of hydrogen fueled vehicles, the hydrogen storage tanks of a hydrogen refueling station (HRS) enable production and demand to be decoupled in time phasing, with electrolytic hydrogen production occurring during off-peak hours by design.

· Car manufacturers are not simply building prototypes, three leading manufacturers already offer production line FCEVs (Toyota, Honda and Hyundai), and many others have announced their intention to launch FCEVs, including Daimler, Lexus, BMW and Kia. Meanwhile, the next generation FCEVs in 2019-20 will be lower in price and require less support from the manufacturer, policy support or subsidies. Other hydrogen vehicles such as dual fuel with diesel are available today based on conversion and retrofits that address the challenging decarbonisation area of commercial vehicles. A l l these vehicles are here and now; their current limited penetration is only due to an immediate shortage of refueling infrastructure, which would encourage more models , and therefore , address the current lack of scale to bring costs down.

· Continued consumer incentives, G overnment support and integration of hydrogen fueled vehicles in fleet, freight and public trans port will ensure the rollout of hydrogen fueled vehicles and will bring forward the tipping point for mass market appeal.

March 2017


Prepared 21st March 2017