A crash course in self-defence for the environmentally conscious. If you have not yet been exposed to authoritative-looking green marketing for hydrogen and fuel cell vehicles, you will be. Here is a heads-up on some representative samples: California Fuel Cell Partnership. “The well-to-wheels reports show that hydrogen made from natural gas and used in a fuel cell vehicle reduces greenhouse gases (GHGs) by 55%-65% compared to gasoline used in a conventional vehicle, and by about 40% compared to gasoline in a hybrid engine.” California Air Resources Board “As zero emission vehicles (ZEVs), hydrogen fuel cells play a significant role in reducing California's greenhouse gas and smog emissions. The California Air Resources Board's most recent Advanced Clean Cars Program builds upon the ZEV Regulation in place since 1990, and rapidly increases numbers of ZEV technologies, such as hydrogen fuel cell and battery electric vehicles. By mid-century, 87% of cars on the road will need to be full ZEVs. This will place California on a path to reducing greenhouse gas emissions by 80% by 2050, a goal adopted by many nations and believed necessary to stabilize climate temperature.” US Environmental Protection Agency “Producing the hydrogen to power FCVs can generate GHGs, depending on the production method, but much less than that emitted by conventional gasoline and diesel vehicles.” Toyota Motor Sales U.S.A, Inc. “Be a part of the next revolution in sustainable mobility: The Toyota Fuel Cell Vehicle (FCV). A driving experience that’s on par with a gasoline engine, but without any CO2 emissions.” Hyundai Motor America, marketers of the Tucson Fuel Cell “Well-to-wheel emissions for hydrogen vehicles sourced from natural gas are lower than battery electric vehicles, and less than half of equivalent gasoline vehicle emissions.” Mercedes Benz, marketers of the B-Class F-Cell “Mercedes-Benz is working hard to harness the power of the most abundant element in the known universe. In other words, zero-emission hydrogen power.” “0.0 emissions that means it is invisible to the environment.” American Honda Motor Co., Inc. “And make no mistake—the FCX Clarity FCEV is an electric car. The fuel cell combines hydrogen with oxygen to make electricity. The electricity then powers the electric motor, which in turn propels the vehicle. Water is the only byproduct the FCX Clarity FCEV leaves behind.” Any problem with these statements? Yes. They are categorically and unequivocally false. There are no such environmental benefits attributable to hydrogen either now or in any foreseeable future economic reality. On the contrary, hydrogen is a gross threat to efforts to tackle emissions as a result of public policies based on a false environmental premise and by grossly misleading advertising combined with incentives targeting consumers most at risk of deception by messaging citing the alleviation of environmental concerns as a value proposition. It would be wrong to proceed without acknowledging the following exceptions to the rule: The Ford Motor Company Inc. “Currently, the most state-of-the-art procedure is a distributed [on-site] natural gas steam reforming process. However, when FCVs are run on hydrogen reformed from natural gas using this process, they do not provide significant environmental benefits on a well-to-wheels basis (due to GHG emissions from the natural gas reformation process).” Tesla Motors Inc, Elon Musk. Transcript from minute 29:20: “Fuel Cell is so bullshit, it’s a load of rubbish. The only reason they do fuel cell is because..., they don’t really believe it, it’s something that they can..., it is like a marketing thing - but the reality is that if you took a fuel cell vehicle and you take the best case for a fuel cell vehicle in terms of the mass and volume required to go a particular range as well as the cost of the fuel cell system, and then you know, if you took the best case of that, it does not even equal the current state of the art of lithium ion batteries and so there is no way for it to become a workable technology.” Technically and despite the unguarded language, Musk is correct, it is unlikely that FCVs will persist beyond their purpose in market destabilisation and harassment. Nevertheless Hydrogen Fuel Cell Vehicles are without equal when it comes to misdirection and as a tool for extracting public funds from officials only too ready to be blind-sided by pseudo-science and the lobbying of vested interests in a nation struggling to triage the cost of foreign oil and consumer environmental concerns while newly awash with abundant cheap Natural Gas from hydraulic fracturing of shales. It is just that the false promise of hydrogen is such a dangerous deception in environmental terms that it cannot be allowed to go undetected at the eleventh hour for the environment and on the eve of genuine progress with simultaneous break throughs in solar energy costs and EVs capable of addressing the mid market. An Environmental, Media and Public Policy Wake Up Call. If it were not for the considerable efforts of marketers to point to a water vapour exhaust instead of the data, the following would be common knowledge already: Hydrogen Fuel Cell Vehicles are marketed as green to environmentalists and policy makers by comparison to a 23 mpg gasoline vehicle. A 23 mpg gasoline vehicle is the 2014 EPA average gas milage across all new vehicles. A 23 mpg is also a ‘GREET 1b’ definition of a ‘mid sized family car [of average age of fleet]’. What a 23 mpg vehicle is assuredly not is a reasonable benchmark to compare with a 2014 / 2015 Hydrogen Fuel Cell Vehicle. Toyota for example produces a 23 mpg 2014 mid sized family vehicle: The Lexus GS 350 a 3.5 liter V6 at 306 bhp . There is no example of a 23 mpg Totota-branded sedan, for example the 3.5 liter Toyota Camry only gets 268 hp and as a result has an EPA combined gas milage figure of 25 mpg. The following chart therefore references the 23 mpg EPA Lexus and compares it to variety of modern technology choices from Fuel Cell Vehicles, Diesel, Gasoline and Gasoline-Hybrids to Plug-in Hybrids and pure Battery Electric Vehicles. Horsepower is shown in red and WTW mpg equivalent emissions is shown in blue. The green bars are emissions reduction and purple is performance reduction vs the 23 mpg gasoline vehicle. Negative performance reduction denotes performance increase compared to the 23 mpg vehicle. The Y axis gives the correct number for all bars be it a percentage or a number in MPGp (miles per gasoline gallon equivalent well to wheel pollution) or vehicle power in bhp. A Closer Look at Directly Comparable Vehicle Technologies without the reference to either the arbitrary US fleet average or very old or very high power vehicle technologies. This graph references the Toyota Prius as an example of a current low-emissions technology vehicle of similar fossil fuel / hybrid architecture to every FCV and the same power output except for the Toyota 2015 FCV which at 90KW (120.6hp) is ten percent less powerful. Fact: The EPA tested 2014 134hp Toyota Prius Gasoline Hybrid offers a 60% GHG WTW emissions reduction verses the Average Fuel Cell Vehicle tested by the definitive DOE NREL long term study. Clearly the 'about 40% WTW emissions reduction apparently claimed for Hydrogen FCV technology' vs Gasoline Hybrid Vehicle technology statement made by the California Fuel Cell Partnership (and mirrored in marketing materials) is unequivocally at odds with official real-world data. One of the sleights of hand used in generating false comparisons is to include an exaggerated figure for carbon footprint of making propulsion batteries derived from an out-dated (2006) Argonne National Labs report. EV batteries on any significant scale are now known to be produced and planned for production without a significant carbon footprint and with very considerable cycle life, second use in storage and end of life recyclability. Will hydrogen also become cleaner over time? No. EVs and FCVs are a fork in the road. One leads to renewables owing to direct compatibility and the other leads to natural gas. Natural gas is a cheap and abundant resource that comes out of the ground with energy potential for self-disassembly into hydrogen and CO2. Steam methane reforming is economically unassailable as a method of hydrogen production by clean but more complex methods. Hydrogen is a fossil fuel. 95% of US production is from natural gas, most of the remainder from the gasification of coal and it will not change for the better. Toyota Motor Sales U.S.A, Inc. Quote: “A cleaner, Renewable Fuel Source. It’s simple science. Our fuel cells generate electricity from hydrogen, a fuel that can be produced from a variety of renewable sources like solar and wind power.” Technically so can gasoline. However as a society we do not use renewable energy to chemically re-assemble gasoline from the exhaust fumes from gasoline vehicles. It is for exactly the same reason that we will not as a society electrolyse H2o (the exhaust of fuel cells). The energy efficiency barrier is too high and electricity is too valuable, hence on any meaningful scale the process cannot compete in the open market with drilling for additional fossil fuels. The larger the scale, the greater the percentage of fossil fuel use in the production of hydrogen. It is simple economics as illustrated in the following chart. The heavy conversion loss from electricity to chemical fuels drastically impacts the distance that can be travelled per unit of energy. The least cost pathway per mile for FCVs is so pronounced in favour of natural gas as to guarantee steam reforming, without CO2 sequestering and with no reason for the natural gas industry to fear cost per mile competition from renewables will prevail economically long into the future, and long after the date by which EVs will be operated on renewables to the exclusion of fossil fuels. This is everything the reader needs to know about why long established fossil fuel and auto industries are pushing so hard for hydrogen despite, no in fact because it makes no environmental sense. Hydrogen represents an economic moat for the fossil fuel status quo versus renewables: To conclude and to summarise It is important for any person concerned with environmental protection or simply wishing to avoid being mislead as a consumer, an investor, an editor or a public servant, to be mindful of well funded and extremely widespread misuse of publicly available data regarding Hydrogen production and Hydrogen Fuel Cell Vehicles. Misrepresentation exists across vested interests and government agencies to paint a picture of this technology as an asset to global efforts to reduce green house gas emissions. Nothing could be further from the truth. Hydrogen is locked by the force of economics to natural gas and natural gas is increasingly locked by the same force to the practice of on-shore hydraulic fracturing of shales. Hydrogen is the Hydro in fossil HydroCarbons and hence hydrogen cannot be extracted from the ground without simultaneously extracting and disposing of carbon as CO2. Re-Capturing the carbon (sequestering CO2) costs about the same as the resulting hydrogen fuel and hence it is simply released to the atmosphere. Hydrogen represents the limit of fossil fuel refining which results in the maximum hidden well to tank emissions of any fossil fuel and the maximum overall GHG emissions per unit of useful energy. The process is significantly more carbon intensive per unit of energy than coal. Mistaking fossil hydrogen from the hydraulic fracturing of shales for an environmentally sustainable energy pathway threatens to encourage energy policies that will dilute and potentially derail global efforts to head-off climate change due to the risk of diverting investment and focus from vehicle technologies that are economically compatible with renewable energy. Toyota for example, currently the world's largest auto maker is the most active supporter of lobby groups in the US and world-wide in pushing for hydrogen while it has tragically sidelined its own efforts to produce EVs. In California, the CARB ZEV mandate permits fossil fuel vehicles (if the fossil fuel is hydrogen) to qualify instead of EVs while the copious green house gas emissions to produce hydrogen for them are released in California just down the road at Air Products Inc., or at the gas station instead of on the street. It is therefore urgent from an environmental perspective that confusion on this topic is brought rapidly to a full stop. There is no reason to imagine that a future 306hp Lexus FCV will not pollute more than the current 306hp gasoline V6 Lexus when the average FCV tested by NREL already produces nearly 75% of the emissions with less than half of the power. This document contains minimal interpretation (the data is derived wherever available directly from official EPA and NREL records). It is intended to provide a clear and directly accessible view of that data to serve a public right to know it (and to understand it) unmasked from false comparisons and pseudo-science and from political or marketing spin intent on forcing natural gas into the energy economy, commencing with targeting the displacement of renewables. This is a key juncture in the environmental and energy policy direction of the United States and elsewhere. An uniformed public is too vulnerable. The data demonstrates that unless a consumer wishes to purchase a low performance vehicle to replace a very old, a very large or very a high performance vehicle, Hydrogen FCVs offer no net Green House Gas reductions versus any other low performance vehicle. In fact the worst environmental performance of any low performance vehicle under 200 hp discussed here was and is the average official Fuel Cell Vehicle NREL test subject at 356g CO2e/mile. Replacing an EV, PHEV, HEV (or even a small-engined diesel or gasoline vehicle) with this FCV would represent an environmental set-back. This is a fact that cannot have escaped either Mercedes (Daimler) and Hyundai-Kia who were both NREL test subjects alongside Ford and GM, BP, Shell and Chevron. Of this group, only Ford, to their credit, has publicly stated that there is no significant environmental benefit to Fuel Cell Vehicle Technology - all be it at the bottom of a web page discussing the merits of tackling climate change. The economically inescapable reason why hydrogen is of no benefit in tackling GHG emissions is that Hydrogen produced by the most efficient commercial route emits a minimum of 14.34Kg CO2e versus 11.13Kg CO2e for a US gallon of Gasoline (of which 13.2Kg is actual CO2 gas in the case of H2). This best case is not even the typical case owing to difficulties in transporting hydrogen in bulk. Hence the on-site (distributed) production from natural gas at fueling stations that suffers lowered efficiencies of scale. The real-world data attests to the fact that when installed in a hybrid electric vehicle the added weight of a Fuel Cell system ensures that the real-world energy conversion efficiency is insufficient to overcome the added GHG emission intensity of hydrogen production. Unlike the optimal economic synergy of plug-in EVs and Renewables, the economics of hydrogen strongly prevents renewables from competing to power an FCV fleet either now or in the future. Natural gas is no bridge to a better future. In the case of FCVs it is an economic barrier to renewables. Hydrogen from Natural Gas is currently posing a considerable threat in terms of diverting State and Federal budgets ostensibly intended for environmental improvement to fossil fuel based hydrogen infrastructure where at best very large amounts of public funds are at risk of going to tragic waste. At worst public funds will embolden the Natural Gas industry and Auto Industry to press for far-reaching delays in EV developments and even lobby for effectively the society-wide derailment of progress towards renewable energy in transportation. 90% of the Californian Energy Commission hydrogen infrastructure budget has been earmarked for fossil fuels in return for lip service of future environmental benefits that can never be forthcoming, meanwhile marketers of FCVs actively and openly target Electric Vehicles (not gasoline or diesel vehicles) with claims of convenient access to lowered green house gas emissions similar to an EV. Claims that are simply not true. Hydrogen Fuel Cell Vehicles and their infrastructure are a case in which the cost to the many should perhaps be considered to outweigh the benefit to the few. With some urgency. Naturally there is unlikely to be a market for Fuel Cell Vehicles outside the demographic of environmentally conscious consumers targeted and duped by false advertising. In that regard I trust this document comes to the defence of the widest possible audience as it contains vital consumer education. Of course the most decisive action environmentally concerned consumers can take to prevent the displacement of renewable energy in transportation by fracking and instead to force the focus of auto makers in the direction of constructive approaches to the environment is simply to refuse to lease or to buy a Fuel Cell Vehicle regardless of incentives. Julian Cox. For details of public participation and input into California Energy Commission programs including the Alternative and Renewable Fuel and Vehicle Technology Program (ARFVTP) Investment Plan, a contact is Alana Mathews, Public Advisor, at 916-654-4489. Appendix: To dig deeper or if the reader is technically minded and inclined to double check the logic, there are some open source details of the calculations and accompanying notes and references that resulted in the information above. Transparency. For those unfamiliar with hydrogen production, here is a highly recommended brief and accessible click-through animation. These are the step by step well to wheel calculations for steam methane reforming: Wellhead emissions: (2.450Kg) SMR furnace: (3.704Kg) SMR process: (5.072) Grid emission for compression: (1.175Kg). Subtotal 12.401 Kg CO2 per Kg of Hydrogen, transportation (0.8Kg). Subtotal 13.2Kg CO2. This is cross checked with total Natural Gas inputs of 3.629 Kg CH4 per Kg Hydrogen representing a 66% rate of well to product energy efficiency (using a standard 50MJ/Kg figure for NG and a standard 120 MJ/Kg figure for H2, both LHV numbers). To complete the picture requires an acceptable estimated figure for transport. Figures originating at Argonne National Laboratory and republished in graphical form by hydrogen fuel cell lobby group Californian Fuel Cell Partnership arrive at 62% efficiency inclusive of transportation. Hence 0.66/0.62 * 12.4 = 13.2Kg CO2 / Kg Hydrogen. EPA estimated CH4 emissions: 1.5% = 0.054435 Kg * GWP (21) = 1.1431Kg CO2e Key Number: Production of Hydrogen = 14.34 Kg CO2e Green House Gas Emissions. This number takes into consideration only actual CO2 gas and EPA estimated CH4 emissions and EPA estimated GHG potency of CH4. Note also, this is a best case figure from large-scale industrial SMR (steam methane reforming) which benefits from efficiencies of scale. According to the NREL long term fuel cell vehicle study on-site production (at the refueling station) is often deployed. Ford, a participant in the NREL study refers to it as distributed natural gas steam reforming. The NREL figures are included in the comparisons above. For Gasoline equivalence the same NREL study gives us a figure of 484g CO2 /mile for a 23 mpg vehicle. 23*484 = 11,132g We can cross check this figure with a DOE study which shows 450g CO2 per mile for a 25mpg gasoline vehicle. 25/23 * 450 = 489g. The figures are in excellent agreement (within 1%). 484g CO2e / mile = 23 mpg for gasoline. Well To Wheel Gasoline emissions are 11.132 Kg CO2 / Mile for 1 Gallon of Gasoline. The EPA standard figure for CO2e tailpipe emissions per gallon of gasoline is 8.887Kg CO2. 25.26% of the GHG emissions are hidden in refinery and transport processes for a total of 11.132 Kg. The 14.34 Kg CO2e for Hydrogen emissions are 100% hidden. Key numbers: For the same energy (1 gal gas : 1 Kg H2) Total Hydrogen CO2e emissions are 28.8% more polluting than gasoline fuel (in reverse the math is 77.6% as clean as gasoline fuel). Key number: Because Hydrogen pollutes more than gasoline for the same energy it is only possible to go 0.776 (77.6%) of the distance shown in Miles per Kg Hydrogen compared with miles per US gallon. To compare Diesel vehicles with gasoline, it is possible to locate figures of 14.2g well to tank : 74.1g combustion totaling 88.3g (per MJ of energy content). The hidden CO2 emissions for Diesel are an extra 19% on top of tailpipe CO2 emissions. For electric equivalence to produce the same 11.132Kg CO2 as a gallon of gasoline there are published figures available for CO2 per KWh. US Average Grid (IPCC) is 0.610 Kg CO2e per KWh. 11.132/0.610 = 18.249 KWh. PG&E in California is 0.524lb = 0.238 Kg CO2e per KWh. 11.132/0.238 = 46.773 KWh. Norway’s National Grid (IPCC): 0.003Kg CO2e per KWh. 11.132/0.003 = 3710.67 KWh. Now we can take a hard look at a sample of similarly performing vehicles including Fuel Cell Vehicle and also look at both similar and very much more powerful PHEVs and EVs. MPGp defined as miles per gasoline gallon equivalent well to wheel CO2e pollution. Hyundai ix35 Tucson FCV 134hp (265mi/5.64Kg) 47 miles per Kg H2 = 36.48 MPGp Hyundai ix35 Tucson 1.6 135hp 35mpg (11132g / 318.51 g/mi wtw ) = 34.95 MPGp Cross check 158 g/km / 0.621371 mi / Km = 254.28 g/mi * 1.2526 = 318.51g wtw Hyundai ix35 Tucson 2.0 CRDi 148hp Diesel ww 293.41g/mi wtw = 37.93 MPGp Hyundai ix35 Tucson 1.7 CRDi 117hp Diesel EU 266.56 g/mi wtw = 41.76 MPGp Mercedes B Class 134hp F-Cell FCV 52 miles per Kg H2 EPA = 40.36 MPGp Mercedes B Class 120hp B180 1.6 gasoline 269.47 g/mi wtw = 38.44 MPGp Mercedes B Class 136hp B-200 Diesel 64.2mpg 220.54 g/mi wtw = 50.47 MPGp Honda FCX Clarity 134hp FCV 60 miles per Kg H2 EPA = 46.58 MPGp Honda Accord Gasoline Hybrid 196hp 47mpg EPA = 47.00 MPGp Honda Civic 1.6-litre i-DTEC Diesel 118hp 180.26 g/mi wtw = 61.75 MPGp Toyota 2015 90KW/122hp FCV 68.3 miles per Kg H2 (NREL) = 53.02 MPGp Toyota Prius gasoline Hybrid 1.8 134hp 50mpg EPA = 50.00 MPGp Toyota Avensis Tourer 2.0 D-4D 124hp Diesel 230.13 g/mi wtw = 48.37 MPGp Tesla Model S P85+ 416hp 38 KWh / 100 mile EPA (Note: The EPA figure of 380Wh/mile includes an aggressive estimate for charging losses based on a small relatively low-efficiency 3.3KW charger). From the fueleconomy.gov site: Battery and battery charger efficiency are assumed to total 81% (roughly 90% each) based in part on estimates from published studies (Chae et. al., 2011; Gautam et. al., 2011). Tesla Model S P85 US Grid Average 18.249 / 0.380 = 48.02 MPGp Tesla Model S P85 California PG&E 46.773 / 0.380 = 123.09 MPGp Tesla Model S P85 Norway Grid 3710.67 / 0.380 = 9,764.92 MPGp Chevrolet Spark EV 28 KWh / 100 mile EPA. (Incorporates EPA standard charging losses). This is a 100KW (134hp) EV, which provides direct comparison with typically 100KW (134hp) FCVs. Chevrolet Spark EV US Grid Average 18.249 / 0.280 = 65.18 MPGp Chevrolet Spark EV California PG&E 46.773 / 0.280 = 167.05 MPGp Chevrolet Spark EV Norway Grid 3710.67 / 0.280 = *13,252.39 MPGp Honda Accord Plug In Hybrid195hp EPA = 115 MPGp “The average WTW greenhouse gas emissions estimate for the Learning Demonstration fleet operating on hydrogen produced from on-site natural gas reformation was 356 g CO2-eq/mile, and the lowest WTW GHG emissions estimate for on-site natural gas reformation was 237 g CO2-eq/mile.” 51% is arrived as as follows: 237/484 = 49% hence 51% less emissions than 100%. 100% of what exactly? A 23 mpg gasoline vehicle. (11132g / 484 = 23 MPGp ) The Economic Determinacy of Natural Gas. Where does the hydrogen highway lead? While direct compatibility with renewable electricity strongly favors a continuing trend towards an emissions-free transportation in the case of Electric Vehicles, chemical energy for transportation, hydrogen included, inevitably favors the economics of chemical feedstocks. According to H2USA ‘Recent development of the United States’ tremendous shale gas resources [is] helping to reduce the costs of producing hydrogen and operating hydrogen fuel cells’. Methane from natural gas contains the energy potential for self-disassembly into Hydrogen and CO2 via the process of steam methane reforming and as a result it is the simplest, cheapest and most economically unassailable source of hydrogen, that is best equipped to see off meaningful competition from electrolysis, biofuels and waste-stream reformation – so long as vehicles are chemically and not electrically powered. Some calculations to illustrate the economic specifics of FCV vs EV energy costs via renewable vs fossil fuel pathways. Miles travelled on 1KWh Electricity: Using the EPA figures of 380 Wh/mile and 280 Wh/mile respectively, renewable energy offers 1/.38 or 2.63 miles for every 1 KWh of electricity in Tesla Model S P85 after an aggressive EPA estimate of charging and battery efficiency losses, and 1/.28 or 3.57 miles for an FCV-equivalent (100KW) EV. This should be reduced to 92.5% to account for a fair 7.5% estimate of grid loss in the case of electricity from a remote renewable utility-scale source. Tesla Model S P85 2.43 miles per KWh. Chevy Spark EV 3.30 miles per KWh. The same 1 KW of renewable energy (at 120 MJ = 54.65 KWh/Kg for hydrogen) after 39% conversion losses in electrolysis and compression would carry a 100KW (134hp) FCV 0.86 miles (47mpKg Hyundai Tucson FCV) or 1.25 miles (68.3 mpKg 90KW Toyota 2015 FCV). Miles travelled on 1KWh Natural gas (LHV). 1 KWh of natural gas heating energy (1/13.1KWh/Kg LHV energy/3.629 Kg Ch4 per Kg Hydrogen) produces 0.021Kg of Hydrogen. This will take a hydrogen FCV between 0.987 miles (Hyundai) and 1.428 miles (Toyota). The same 1 KWh of natural gas heating energy after a typical 50% conversion loss in natural gas electricity generation and distribution will take an EV, counting EPA charging loss, 1.32 miles (Tesla Model S P85 at 380Wh/mile) and 1.79 miles (100KW Chevy Spark EV at 280Wh/mile). From these figures it is possible to calculate fundamental cost per mile economic break-even in either direction in three different hypothetical scenarios comparing a 100KW Chevy Spark EV to a 90KW 2015 Toyota FCV. EV only transport system. Renewable energy hits break even per mile vs Natural Gas electricity generation at 3.30/1.25 = 264% of the cost of natural gas. For example if natural gas costs $5 per 293 KWh (true on average) Solar can compete in terms of cost per mile at $13.20 per 293KWh or 4.50 US Cents / KWh. If EVs and FCVs co-exist in transportation allowing FCVs to take least-cost route (natural gas). Renewable energy hits break even vs fossil fuel powered FCVs at 3.30/1.428 = 231% of the cost of natural gas. (3.94 US Cents / KWh). FCV only transport system. Renewable energy must be converted to hydrogen to access transportation and hence hits break even with fossil fuel powered FCVs at 1.25/1.428 = 87.5% of the cost of natural gas. This is a potential disaster for renewable energy in transportation and for the environment that PON-13-607 and initiatives like it encourage at the public expense assuming consumers cooperate in the purchase of FCVs. The answer is 1.49 US Cents per KWh to be competitive with natural gas or more than double the cost reduction to be competitive in an EV system. These numbers represent the threat posed by hydrogen to our generation’s bid for emissions free and renewable powered transportation. We are within three to six years of it being cheaper to run an EV fleet on utility scale solar than it is to power an EV fleet via natural gas. But with an artificially imposed societal choice of FCVs, that goal is at risk of being pushed out by approximately 12 years of additional entrenchment in a fossil fuel transportation economy. There are two economic conditions for these cost comparison scenarios to remain true: The cost of hydrogen infrastructure must be free of charge to the fossil fuel industry (paid for by public funds). Amortizing that cost and risk of consumer rejection of FCV technology is never accounted for in the cost of Hydrogen. There must be no accounting for the cost of CO2 sequestration during the production of hydrogen – instead there must be a carte blanche license to pollute. At an incremental $3.50 per Kg H2, 90% clean hydrogen as a result of sequestering the CO2 outputs of SMR cost between 50% and 100% more than the $7.00 to $3.50 figures typically cited. These choices are of course within the remit of the California Energy Commission and similar bodies Nation wide and World wide at this moment. Whether or not to defray the cost of entry for natural gas to enter the green energy sector, and whether or not to impose or to waive the mandatory sequestration of CO2 during SMR as a gatekeeper to entry. Ultimately, the defining advantage for hydrogen produced by natural gas for Fuel Cell Vehicles is the ability to pollute while claiming to be green. It is not good enough that images of celebrities drinking distilled exhaust emissions sets the standard of public education on such a pivotal societal choice. There are better choices.