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SR 04-24-2018 4A City Council Report City Council Meeting: April 24, 2018 Agenda Item: 4.A 1 of 16 To: Mayor and City Council From: Edward King, Director, Big Blue Bus, Finance & Administrative Services Subject: Fleet Composition Study Recommended Action Staff recommends that the City Council: 1) Review, and provide guidance to staff on the future implementation of a BBB vehicle propulsion technology for the BBB fleet to achieve a goal of Zero Emissions; 2) Provide feedback regarding a proof of concept program for evaluating the operational effectiveness and efficiency of a sub -fleet of electric buses which shall consist of up to 10 battery electric buses and requisite infrastructure at the BBB yard; and 3) Authorize staff to work with the Federal Transit Administration (FTA) Office of Innovation, FTA Region 9 Office, and Gillig, LLC for the procurement of one 40- foot electric propelled bus from Gillig, LLC under the FTA’s Prototype Waiver Program that would be produced in December 2018, and placed into revenue service in January 2019. Executive Summary Big Blue Bus provides regional transit service for 13.6 million passengers a year, serving an area covering 58 square miles. Since the 1990’s, Big Blue Bus (BBB) has been a leader in using cost efficient environmentally-friendly vehicle propulsion technology for its fixed route bus fleet. With the advent of ne w propulsion technology being tested and evaluated at many California transit agencies and the potential that the California Air Resources Board (ARB) proposed Innovative Clean Transit (ICT) regulation being finalized later this year, staff initiated an an alysis to compare the economic and environmental benefits for future ve hicle procurements under two propulsion scenarios: 1) transitioning BBB’s existing fleet to near-zero NOx emission (NZE) natural gas engines that would continue to be fueled by renewable natural gas (RNG); and, 2) transitioning BBB’s existing fleet to battery electric buses (BEB). 2 of 16 Staff is committed to providing an objective and unbiased approach to help guide Council, and while the GNA report summary and cost implications for each fuel path are provided in the staff report, there are inherent tradeoffs with each fuel path scenario, upsides to each, and unknowns with Scenario Number 2, (transition the fleet to BEBs) due to how new this technology is in the transit industry. At the end of the day, BBB is committed to consistently provide financially sustainable, efficient, effective and safe mobility services to our customers and the community on a daily basi s. Understanding that this technology is new in the transit industry, staff recommends a responsible approach to first prototyping the application of electric bus operation on the BBB system, and moving forward with the implementation of a proof of concept program with measurable outcomes for success with a small fleet of electric buses over the next 2 years to lay the groundwork for a transition to a 100% zero-emissions fleet. Background BBB operates twenty fixed routes that include traditional local transit service, commuter transit, express service, and community-based circulators. The urban area serviced by BBB’s transit fleet includes the entire Westside region of Los Angeles. The BBB fleet provides service to approximately 13.6 million passengers annually in an urban service area of 58 square miles. The fleet’s service area is vastly larger than the City’s municipal service boundary of 8.4 square miles. To provide these services, BBB operates a fleet of 200 natural gas urban transit buses which include nineteen (19) 30-35 foot buses, (153) 40-foot buses, and twenty-eight (28) 60-foot articulated buses. Approximately 60% of the fleet is model year 2011 or newer buses. The entire fleet is powered by natural gas engines fueled with renewable natural gas. Today, 62 ½ percent of the fleet operates on compressed natural gas (CNG) and 37.5% operates on liquefied natural gas (LNG). However, all LNG buses within the fleet would be retired by 2019. 3 of 16 Make Year Qty # of Buses Fuel Type Engine lbs. NOx per yr per bus Total lbs. NOx per year Gillig 2018 20 Near Zero 32.44 649 Gillig 2017 25 Near Zero 32.44 811 Gillig 2016 4 ISLG 324.41 1,298 Gillig 2015 11 ISLG 324.41 3,568 Gillig 2013 58 ISLG 324.41 18,816 NABI 2011 6 Near Zero 32.44 195 NABI 2011 3 ISLG 324.41 973 New Flyer 2006 10 C-Gas Plus 3,568.50 35,685 New Flyer 2004 13 C-Gas Plus 3,568.50 46,391 New Flyer 2015 7 ISLG 324.41 2,271 NABI 2011 7 ISLG 324.41 2,271 NABI 2011 14 Near Zero 32.44 454 Gillig 2018 7 Near Zero 32.44 227 El Dorado 2011 10 ISLG 324.41 3,244 El Dorado 2010 5 ISLG 324.41 1,622 200 72 Near Zero 32.44 2,336 105 ISLG 324.41 34,063 23 23 RLNG C-Gas Plus 3,568.50 82,076 RCNG VEHICLE MAKEUP 177 RCNGFUEL MAKEUP RLNG RCNG RCNG 23 28 22 40 ' B u s 60 ' B u s 30 ' B u s 127 Figure 1 - BBB's Current Revenue Vehicles (Note: ISLG refers to a Cummins Engine model) The transit facility consists of a maintenance facility, administrative buildings, fueling infrastructure, wash bays, bus yard, and a maintenance parking lot for staff vehicles. The maintenance facility was remodeled in 2009 and there are currently no plans to expand the facility. 4 of 16 Two fueling stations are physically located on BBB’s property. A private on -site station is located within the fenced boundary of the transit facility, while a public access station is located outside of the fenced boundary but still on BBB’s property. BBB’s transit fleet is supplied with CNG (via the LCNG station) and LNG from renewable liquefied natural gas (RLNG) that is procured from Clean Energy. On average, Clean Energy delivers one load of RLNG each day which is transported via tanker truck from C lean Energy’s Boron LNG plant. An onsite storage tank supplies the RLNG to the LCNG and LNG dispensers that are co-located within the drive-through wash bays. Southern California Edison (SCE) provides electricity to the transit facility. On average, BBB’s electricity cost is higher than that of surrounding utility customers because the City procures a higher fraction of renewable electricity in its electricity mix than SCE’s average delivered electricity mix. The low carbon electricity is purchased via a t hird party energy service provider (ESP) but is delivered through SCE’s distribution system. During peak service days, which occur Monday through Friday, BBB’s fleet operates 240 daily weekday assignments which require 162 transit buses during peak weekd ay service. The average distance of an assignment is 71 miles; however, individual assignments range from 13 miles up to 181 miles. Some transit buses receive more than one assignment during a peak day. The majority of route operations occur on primarily flat surfaces, however, there are a small number of route assignments, such as those travelling to and from the Pacific Palisades area, that entail a significant amount of elevation change. Discussion Fuel Path Analysis To help staff better understand the issues surrounding vehicle propulsion systems, the consulting firm of Gladstein, Neandross & Associates/Ramboll prepared a detailed analysis looking at the different fuel paths. For each of the vehicle deployment scenarios, cost and emissions profiles were developed on a per-mile, annual, and lifecycle basis using fleet composition, operational, and procedural data provided by BBB, as well as assumptions where necessary in order to characterize the recently 5 of 16 commercialized alternative technologies. The operational cost for each transit bus technology is an aggregate of individual cost factors that include bus capital, fuel, operations and maintenance (O&M), midlife overhaul, fuelling infrastructure, and facility modification costs. Data provided by BBB and assumptions were evaluated to quantify the individual cost factors as a component of the overall cost. The emissions evaluated as part of the analysis include greenhouse gases (GHGs), oxides of nitrogen (NO x), and particulate matter (PM10). The analysis found the total per-mile operational cost for BBB’s existing transit buses to be $2.789/mi compared to $2.829/mi for near-zero NOx emission natural gas transit buses and $4.054/mi for battery electric transit buses if purchased in 2017. While significant operating cost reductions are not expected for BBB’s existing buses or for NZE natural gas buses over the next 20 years, it is widely projected that operating costs for battery electric buses will fall over time. The analysis projects that battery electric buses purchased in 2030 would have an average operating cost of $3.382/mi. Over a 12 -year lifecycle, the operational cost of BBB’s existing transit bus is approximately $1,079,343/bus compared to $1,094,823/bus for near-zero NOx emission transit buses, $1,568,898/bus for battery electric transit buses purchased in 2017, and $1,308,834/bus for battery electric buses purchased in 2030. This represents an incremental cost of $15,480/bus for near-zero NOx emission transit buses, $489,555/bus for battery electric transit buses purchased in 2017, and $229,491/bus for battery electric transit buses purchased in 2030. Estimated costs for battery electric transit buses take into account significant reductions in battery costs over time and are net of projected credits that BBB could generate under California’s Low Carbon Fuel Standard (LCFS). 6 of 16 The emissions analysis found well-to-wheel (WTW) GHG emissions of BBB’s existing transit bus to be 1,475 grams per mile (g/mi) compared to 1,213 g/mi emitted from near - zero NOx transit buses, and 8.88 g/mi for battery electric transit buses purchased in 2017 and in 2030. Well-to-tank (WTT) NOx emissions were found to be 4.53 g/mi for BBB’s existing transit buses, 4.55 g/mi for near-zero NOx transit buses, and 0.0653 g/mi for battery electric transit buses purchased in 2017 and in 2030. Tank -to-wheel (TTW) NOx emissions were found to be 0.581 g/mi emitted by BBB’s existing transit buses compared to 0.045 g/mi emitted from near-zero NOx transit buses and 0.00 g/mi emitted from battery electric transit buses purchased in 2017 and in 2030. 7 of 16 Transit Bus Emissions Profiles BBB Existing Transit Bus NZE NOx CNG Transit Bus 2017 Battery Electric Transit Bus 2030 Battery Electric Transit Bus WTW GHG Emissions 1,475 g/mi 1,213 g/mi 8.88 g/mi 8.88 g/mi WTT NOx Emissions 4.53 g/mi 4.55 g/mi 0.0653 g/mi 0.0653 g/mi TTW NOx Emissions 0.581 g/mi 0.045 g/mi 0.000 g/mi 0.000 g/mi WTW NOx Emissions 5.111 g/mi 4.600 g/mi 0.065 g/mi 0.065 g/mi In addition to evaluating the cost and emissions performance of the individual transit bus technologies, BBB’s fleet-wide costs and emissions were evaluated over the proposed ICT regulatory timeframe that is currently under development by the ARB. The figure below displays BBB’s existing fleet transitioning to near-zero NOx emission natural gas transit buses according BBB’s planned replacement schedule. During the 23-year implementation timeframe of the ICT regulation, BBB would incur a cost of approximately $414 million as a result of continuing to procure and operate their existing transit bus technology. The analysis found that BBB would incur a cost of approximately $418 million as a result of transitioning the existing fleet to a near -zero NOx emission natural gas fleet, representing an incremental cost of approximately $4 million. The analysis also found that BBB would incur a cost of approximately $492 million (an incremental cost of $78 million) as a result of transitioning to a battery 8 of 16 electric fleet assuming expected reductions in ba ttery costs and net of projected LCFS credits generated across the timeframe. BBB Fleet Costs – 2018-2040 BBB Existing Transit Fleet NZE NOx CNG Transit Fleet Battery Electric Transit Fleet Fleet Operational Costs $ 413,748,150 $ 417,803,910 $ 492,001,711 Incremental Cost Relative to Baseline Scenario $ - ↑ $ 4,055,760 ↑ $ 78,253,561 Transitioning BBB’s fleet to near-zero NOx emission natural gas transit buses would reduce the fleet’s WTW GHG emissions by 26,724 MT (metric tons) during the timeframe. Transitioning BBB’s existing fleet to a battery electric fleet would significantly reduce fleet-wide GHG emissions by approximately 150,000 MT during the timeframe. However, the reductions provided by the transition to battery electric transit buses come at a cost of approximately $78 million or approximately $526/MT. The majority (approximately 99%) of WTW GHGs emitted during the transition to a battery electric fleet are the emissions from BBB’s existing transit buses as they operate for the remainder of their useful lives. The analysis found that transitioning to either of the alternative scenarios technologies would yield significant TTW NOx reductions. During the timeframe, transitioning to a near zero NOx emission natural gas transit fleet yields a 63% reduction from the baseline scenario while the transition to a battery electric transit fleet buses yields a 68% reduction from the baseline scenario. Though the reductions achieved by each scenario are comparable, there is a significant difference in the costs that would be incurred. At an incremental cost of approximately $4 million, the 60.1 tons of NOx reduced as a result of transitioning to a near-zero NOx natural gas fleet would cost approximately $67,484/ton. In contrast, the 65.1 tons of NOx reduced as a result of transitioning to a battery electric transit fleet would cost approximately $1,202,052/ton (approximately 1800% more than the cost of the reductions that would result from transitioning to an NZE NOx fleet) because the 9 of 16 incremental cost of transitioning to a battery electric transit fleet is approximately $78 million. BBB Fleet Emissions – 2018- 2040 BBB Existing Transit Fleet NZE NOx CNG Transit Fleet Battery Electric Transit Fleet TTW NOx Emissions 95.2 tons 35.1 tons 30.1 tons Reductions Relative to Baseline Scenario 0.0 ↓ 60.1 tons ↓ 65.1 tons Cost of TTW NOx Emissions Reductions 0.0 $67,484/ton $1,202,052/ton The analysis also found that transitioning to a near -zero NOx emission natural gas transit fleet would not yield any significant PM10 (particulate matter) reductions. The reason is the Cummins ISL G Near-Zero (NZ) and the Cummins ISL G (equipped in BBB’s existing transit buses) have the same certified PM10 emissions values. In contrast, transitioning to a battery electric transit fleet yields a 68% reduction from the baseline scenario. While this is a significant percent reduction, the PM emissions from each of the scenarios is very small because natural gas engines have extremely low PM10 emissions. In summary, the analysis found that, at an incremental cost of approximately $4 million, the transition of BBB’s existing fleet to a fleet of near -zero NOx emission natural gas transit buses would result in a small decrease in GHG emissions and a significant reduction in TTW NOx emissions. At an incremental cost of approximately $78 million, the transition of BBB’s existing fleet to battery electric transit buses would result in GHG and TTW NOx emissions reductions that are more costly compared to those achieved from the deployment of near-zero NOx emission natural gas transit buses. The results of the analysis are based on projections of significant operating cost reductions for battery electric buses over time. These reductions are based on large reductions in battery storage costs and projections of revenue from the LCFS program. Changes in these assumptions would have a dramatic impact on the total estimated project costs. Were battery storage costs to remain constant (and not fall over time as they almost certainly will based on history), the incremental cost of converting the entire 10 of 16 fleet to battery electric buses would increase to approximately $130 million as opposed to approximately $78 million. The LCFS program works with other programs in California, such as the Cap -and-Trade Program, to reduce transportation-related GHG emissions. Credits are generated from the use of low carbon fuels in the transportation sector. Regulated entities, such as petroleum refiners, are required to purchase credits to offset the GHG emissions associated with the higher carbon fuels that they produce. It is the demand for these credits by regulated entities that sets the credit price. Though the credit price has remained stable in recent years, future credit prices would be established in an open market environment and any fluctuations in the price of the credit would directly impact BBB’s cost of operating battery electric buses. Funding Opportunities With the proposed 23-year length of a transition to a zero emission fleet, it is impossible to accurately predict what the funding landscape would look like. However, this section describes existing federal, state, and county programs and incentives outside of BBB’s ongoing funding streams that could help pay for alternatively-fuelled buses. The Federal Transit Administration (FTA) offers two relatively small funding pots for the purchase of zero-emission transit buses. The Low or No Emission Competitive Program (LoNo) provides funding to state and local governmental authorities for the purchase or lease of zero-emission and low-emission transit buses as well as acquisition, construction, and leasing of required supporting facilities. The LoNo Program distributes $55 million nationwide. Big Blue Bus applied for funding for battery electric buses i n the FTA’s last funding cycle but was not selected. The FTA also offers the Bus & Bus Facilities Infrastructure Investment Program which allows agencies to replace, rehabilitate and purchase buses and related equipment and to construct bus-related facilities including technological changes or innovations to modify low or no emission vehicles or facilities. The Bus and Bus Facilities Program 11 of 16 distributes $226 million nationally. BBB currently submitted an application for the purchase of seven battery electric vehicles through this program but was not selected. The state’s funding opportunities for zero and near zero engines have been increasing in recent years. For example, the Hybrid and Zero -Emission Truck and Bus Voucher Incentive Project (HVIP) provides vouchers to help California fleets purchase advanced technology trucks and buses. HVIP provides vouchers for California purchasers and lessees of hybrid and zero-emission trucks and buses on a first-come, first-served basis. Purchasers of fixed route zero emission buses receive $110,000 per vehicle while using near zero engines receive $10,000 to offset costs. BBB would utilize these vouchers regardless of the fuel path chosen. To help with the implementation costs of the ICT regulation, the ARB has rec ently proposed to invest one-third of the VW Mitigation Trust in zero-emission buses. The program would create a maximum incentive of up to $180,000 for a new battery electric transit bus, up to $400,000 for a new fuel cell electric transit bus, and up to $100,000 for a new battery electric shuttle bus. These maximum funding amounts exceed the maximum funding amounts allowed under HVIP. Unfortunately, no funding is proposed for charging infrastructure. In January, the California Public Utility Commission (CPUC) approved the first transportation electrification applications under SB 350 from the three large investor - owned utilities. The decision approves 15 projects with combined budgets of $42 million statewide. One approved project in Southern California E dison’s (SCE) area is $3.9 million for “Electric Transit Bus Make-Ready.” SCE would deploy make-ready infrastructure at bus depots and along bus routes to serve electric commuter buses operating in SCE’s service territory. SCE would also provide a rebate to participating customers to cover the cost of the charging equipment and installation. SCE would maximize the electric transit bus routes it supports in disadvantaged communities. The California State Transportation Agency has recently finished accepting applications for the next round of Transit and Intercity Rail Capital Program (TIRCP). The TIRCP 12 of 16 aims to increase ridership on the state-wide transit and rail network and reduce greenhouse gas emissions. The five-year program is anticipated to distribute $2.4 billion. Big Blue Bus recently submitted a grant application to CALSTA asking for $3.05 million to pay for the incremental cost of ten 40-foot battery electric buses. The total cost of the ten vehicle program would be $9.7 million. Associated infrastr ucture costs were not included in the request in order to make the application more competitive. At the County level, BBB’s participation in Metro’s Bus Operations Subcommittee (BOS) allows it to apply for bus replacements and facility improvements. The B OS distributes 15% of Los Angeles County’s Federal 5307 Capital funds on an annual basis. Typically, the fund source spreads approximately $17 million among the sixteen Municipal Operators. The funds are allocated based on a competitive process. Context for All-Electric Fleet Conversion With over 200 public transit systems operating about 14,000 buses, the State of California is leading the way nationally in making the commitment to an all zero - emission fleet. Within the state, seven transit agencies have committed to making full transition to an all-electric fleet by the year 2030. LA Metro currently has 100 zero - emission vehicles on order, and has committed to the conversion if their new vehicles comply with performance benchmarks. Foothill Transit and the City of Los Angeles Department of Transportation (LADOT) have also made the same commitment to have an all zero-emission fleet by 2030. Foothill Transit has 30 zero -emission buses on the road; Long Beach Transit has 10. LADOT has four vehicles on the road and recently ordered 25 more zero emission vehicles. Antelope Valley Transit Authority (AVTA) has eight buses on the street and an order placed for all 85 of their buses to be battery electric by the end of 2019. Elsewhere in the United States, King Cou nty Metro in Seattle has committed to purchasing 120 all electric battery buses by 2020 with the goal of having a 100% zero emission fleet between 2034 and 2040. The number of manufacturers currently providing battery electric buses is limited but the number is growing as more transit systems commit to the new technology. Two battery electric only bus manufacturers - Proterra and BYD - currently sell most of the battery 13 of 16 electric buses across the United States. Other legacy bus manufacturers such as New Flyer and Gillig are also entering the battery electric marketplace. The most exhaustive study of battery electric bus performance was completed in June 2017 by the US Department of Energy's National Renewable Energy Laboratory on twelve Foothill Transit buses. The study compared the performance of Proterra battery electric buses versus Foothill's NABI CNG vehicles as a baseline. Highlights of the study include: the twelve battery electric buses accumulating more than 900,000 miles during the study period; the buses surpassed their target of 4,000 miles between road calls with more than 6,000 miles during the evaluation period; the on -route chargers operated reliably with minimal issues; and the high voltage batteries showed little to no sign of capacity degradation during the study period. Conversely, the short-range on-route charged buses are inflexible and cannot be deployed to other routes; the higher use of air conditioning lowers the effective range in hotter months; charger availability is needed for successful vehicle deployment; and the CNG buses did significantly outperform the battery electric bus in many of the evaluation areas. For comparison, BBB’s miles between road failures on the CNG and LNG fleets are more than 18,000 miles. Additionally, systems in Albuquerque, NM, and Long Beach have experienced significant delays in BEB deliveries from vendors, delaying new projects that both systems had intended to launch in early 2017. Based upon proactive discussions with Southern California Edison, and through staff evaluation of the proposed SCE medium- and heavy-duty vehicle charging infrastructure that includes transit agencies, staff has identified up to 23 potential charging unit locations within the maintenance/parking yard where BEBs could be charged overnight. 14 of 16 BBB all-Electric Fleet Challenges One of the many challenges with converting the fleet to electric is operational and maintenance continuity of operations. As buses become eligible for replacement under the FTA funding regulations that BBB follows, transitioning and operating a dual fueled fleet becomes complex. During the conversion, more space would be needed for infrastructure required to support charging the BBB electric fleet, while still maintaining RNG fueling facilities for the CNG fleet including giving consideration to back-up power and energy storage. As BBB is already constrained by the size of the yard and facilities from which it operates, a feasibility and transition analysis would need to be conducted to inform staff and stakeholders on best practices and how to ensure that service delivery to BBB’s 54,000 daily customers remains consistent. Other challenges and critical areas that need to be reviewed prior to transition to an all - electric fleet include: training of mechanic staff on new fleet propulsion technology; route specific energy analysis; impacts of a replacement analysis greater that one -to-one for electric buses; and the evaluation of electric bus technology advancements and reduced battery costs that are hard to accurately predict. While these challenges exist, there are many opportunities for growth of BBB’s understanding of electric bus technology. BBB Transition Plan Understanding the unknowns, benefits, costs, tradeoffs, and the City’s desire to move toward an all-electric fleet, staff continues to responsibly and conscientiously prepare and plan for that transition. To address the electric bus fleet and new infrastructure costs, staff continues to seek additional funding for both, applying for new federal and state programs for this technology, as well as meeting with SCE to learn about their new programs. As mentioned earlier, a TIRCP grant has been submitted to partially fund up to ten new electric vehicles. BBB anticipates announcement of successful grant applications by May 2018. Previous grant submittals for FTA LoNo funding and Bus and Bus Infrastructure Program funding were not successful. Staff has scheduled a conference 15 of 16 call with FTA staff on 4/20/18 to discuss our recent grant submittals and how to improve future grant applications. Staff continues to work with American Public Transportation Association, California Transit Association and sister agencies to maintain the pulse and knowledge of the market. Locally, staff has joined the LA Regional Electric Bus Working Group to collaboratively work with our peers to find solutions for implementation and to the increased costs of this technology. Staff is also working on the Zero Emission Bus Procurement Committee to provide input to the St ate Department of General Services (DGS) for the creation of a statewide electric bus procurement, giving us options to buy our buses as funding comes in. Additionally, we are in dialogue with Southern California Edison (SCE) to layout plans and estimate costs for converting our property to support a 100% electric fleet. In those conversations, we have learned of SCE’s work with the CPUC for potential funding for infrastructure. We would continue to monitor all funding possibilities. Finally, BBB has initiated a collaborative effort with FTA, Gillig and the Honolulu Transit System to test one of Gillig’s five total prototype battery electric buses that they are building at the end of this calendar year. In June or early July 2018, staff will recommend to council procurement of one prototype electric bus. This pilot project would help BBB immediately begin to evaluate the technology and the application of operating an electric bus within our service area and how it would impact our operations as we transition to an electric fleet. Following best practices, we would perform route, charge and rate modeling to better prepare for a future implementation plan. This process would ultimately help staff understand the differences of this technology and how best t o procure, deploy and operate electric buses into the BBB fleet mix. Staff would continue efforts with our funding partners to apply for grants to fund electric bus purchases. Financial Impacts & Budget Actions 16 of 16 There is no immediate financial impact or budget action associated with conducting the study session. Depending on the direction given, costs associated with purchasing new vehicles and accompanying infrastructure may be affected. Prepared By: Eric O'Connor, Chief Administrative Officer Approved Forwarded to Council Attachments: A. Written Communication B. Powerpoint Presentation 1 Vernice Hankins From:kelly@drivecleansantamonica.com Sent:Monday, April 23, 2018 5:11 PM To:councilmtgitems Subject:add to item 4-A BBB April 24, 2018 Attachments:Item 4-A BBB.docx Mayor and Councilmembers, Drive Clean Santa Monica concurs with the analysis done by Earthjustice and Southern California Edison (SCE) that the report presented to the City Council regarding the electrification of the Santa Monica Big Blue Bus fleet (BBB) contains significant inaccuracies and leaves out important information. Therefore, we respectfully submit that since the conclusions are based on faulty data, the recommendation to slow down the adoption of electric buses should not be followed. Specifically, we feel that the points made in the letter from SCE are correct and are enough significant reasons to reject the report's conclusions. Some of the flaws in the report identified by SCE are: 1. Infrastructure Costs Ignore Cost-Sharing With SCE 2. Electric Bus Maintenance Cost Savings Are Too Low & Mid-life Overhaul Costs Are Too High 3. Over-Estimation Of Cost of Charging Electric Busses Other communities in Southern California are taking a lead in the change over to electric busses. This is not risky or unknown territory. Further, there are reports that the RNG BBB uses comes from TX not CA, so all the emissions data using RNG is flawed since no methane is actually captured in CA. In addition, by the time the NG is burned by BBB there is no "RNG" (Reclaimed Natural Gas) in the NG. It is an accounting shell game which leaves the BBB burning regular NG while the users take credit for RNG. Regardless of the source of the "natural" gas, "reclaimed" or fracked, the emissions from the tailpipes of the BBB fleet are significant pollutants and adds to global warming, climate change, illness to our residents and even death. Please move forward with an aggressive plan to convert the entire BBB fleet to zero-emission renewable electricity. It is the right thing to do for the residents of Santa Monica, the greater L.A. basin and the planet. Item 4-A 4/24/18 1 of 80 Item 4-A 4/24/18 2 Thank you, Kelly Richard Olsen Chair, Drive Clean Santa Monica Santa Monica City Councilman, ret. Item 4-A 4/24/18 2 of 80 Item 4-A 4/24/18 City of Santa Monica – Big Blue Bus Comparative Analysis of Transitioning to Near-Zero NOx Emission Natural Gas and Zero Emission Battery Electric Transit Fleets Contract No. 3201 (CCS) October 24, 2017 Prepared for: Eric O’Connor, Chief Administrative Officer City of Santa Monica – Big Blue Bus 1660 7th Street Santa Monica, CA 90401 Telephone: (310) 458-1975 ext. 5823 Email: eric.oconnor@smgov.net Prepared by: Gladstein, Neandross & Associates Jarrod Kohout, Project Director Ramboll Environ US Corporation 2525 Ocean Park Blvd., Suite 200 Los Angeles, CA Santa Monica, CA 90405 Phone: (310) 314-1934 Item 4-A 4/24/18 3 of 80 Item 4-A 4/24/18 TABLE OF CONTENTS EXECUTIVE SUMMARY ........................................................................................................... 1 1. BACKGROUND .............................................................................................................. 6 2. BIG BLUE BUS TRANSIT FLEET PROFILE .................................................................. 7 3. CALIFORNIA AIR RESOURCES BOARD INNOVATIVE CLEAN TRANSIT REGULATION ........................................................................................................................... 9 4. TRANSIT BUS COST ANALYSIS ..................................................................................11 4.1. EXISTING TRANSIT BUS COST ANALYSIS ..............................................................11 4.2. NEAR-ZERO NOx EMISSION NATURAL GAS TRANSIT BUS COST ANALYSIS .....14 4.3. BATTERY ELECTRIC TRANSIT BUS COST ANALYSIS ...........................................18 4.3.1. BATTERY ELECTRIC BUS TECHNOLOGY & OPERATIONAL ASSESSMENT .18 4.3.2. BATTERY ELECTRIC TRANSIT BUS COST ANALYSIS .....................................32 4.4. SUMMARY OF TRANSIT BUS COST ANALYSIS ......................................................38 5. TRANSIT BUS EMISSIONS ANALYSIS ........................................................................41 5.1. EXISTING TRANSIT BUS EMISSIONS ANALYSIS ....................................................41 5.2. NEAR-ZERO NOX EMISSION NATURAL GAS TRANSIT BUS EMISSIONS ANALYSIS ............................................................................................................................43 5.3. BATTERY ELECTRIC TRANSIT BUS EMISSIONS ANALYSIS .................................45 5.4. SUMMARY OF EMISSIONS ANALYSIS .....................................................................46 6. BBB FLEET TRANSITION ANALYSIS – 2018-2040 .....................................................49 6.1. BASELINE SCENARIO – ECONOMIC AND EMISSIONS ANALYSIS ........................49 6.2. NEAR-ZERO NOX EMISSION NATURAL GAS TRANSIT FLEET SCENARIO - ECONOMIC AND EMISSIONS ANALYSIS ...........................................................................50 6.3. ZERO-TAILPIPE EMISSION BATTERY ELECTRIC TRANSIT FLEET SCENARIO – ECONOMIC AND EMISSIONS ANALYSIS ...........................................................................51 6.4. SUMMARY AND CONCLUSIONS ...............................................................................53 APPENDIX A – Big Blue Bus Existing Fleet Characteristics and Assumptions ............... A-1 APPENDIX B – Transit Bus Costs and Assumptions ......................................................... B-1 APPENDIX C – Fuel and Fuelling Infrastructure Cost Assumptions ................................. C-1 APPENDIX D – Fuel Properties and Emissions Factors ..................................................... D-1 Item 4-A 4/24/18 4 of 80 Item 4-A 4/24/18 EXECUTIVE SUMMARY The City of Santa Monica’s (City’s) Big Blue Bus (BBB) transit agency currently operates a fleet of 200 natural gas urban transit buses. The fleet provides service to approximately 13.3 million passengers annually in an urban service area of 51 square miles. During peak service days which occur Monday through Friday, BBB’s fleet operates 240 daily assignments that require 162 transit buses to be in service during peak morning and afternoon service periods. BBB’s fleet consists of nineteen (19) 30-35 foot buses, 153 40-foot buses, and 28 60-foot articulated buses. Approximately 60% are model year 2011 or newer. Transit operations and supporting administrative functions occur at BBB’s facility located at 1660 7th Street, Santa Monica, CA 90401. As the only site under BBB’s direct ownership and control, the maintenance facility, administrative buildings, fuelling infrastructure, wash bays, bus yard, and a maintenance parking lot for staff vehicles are all located within the site’s fenced boundary. The following report is a comparative analysis to assess the economic and environmental benefits of transitioning BBB’s existing fleet under two alternative deployment scenarios. The alternative deployment scenarios that were evaluated include 1) transitioning BBB’s existing fleet to near- zero NOx emission (NZE) natural gas engines that will continue to be fuelled by renewable natural gas (RNG), and 2) transitioning BBB’s existing fleet to battery electric buses (BEB). The evaluation assessed economic and environmental benefits over the regulatory timeframe of the California Air Resources Board’s (ARB’s) proposed Innovative Clean Transit (ICT) regulation. According to the most recent implementation timeframe stated by the ARB, the ICT regulation is anticipated to be implemented from 2018 through 2040. For each of the scenarios, cost and emissions profiles were developed on a per-mile, annual, and lifecycle basis using fleet composition, operational, and procedural data provided by BBB, as well as assumptions where necessary in order to characterize the recently commercialized alternative technologies. The operational cost for each transit bus technology is an aggregate of individual cost factors that include: bus capital, fuel, operations and maintenance (O&M), midlife overhaul, fuelling infrastructure, and facility modification costs. Data provided by BBB and assumptions were evaluated to quantify the individual cost factors as a component of the overall cost. The emissions evaluated as part of the analysis include greenhouse gases (GHGs), oxides of nitrogen (NOx), and particulate matter (PM10). The analysis found the total per-mile operational cost for BBB’s existing transit buses to be $2.789/mi compared to $2.829/mi for near-zero NOx emission natural gas transit buses and $4.054/mi for battery electric transit buses purchased in 2017. While significant operating cost reductions are not expected for BBB’s existing buses or for NZE natural gas buses over the next 20 years, it is expected that operating costs for battery electric buses will fall over time. This is based primarily on expected, significant reductions in battery costs, which will affect both purchase and midlife overhaul costs for battery electric buses. The analysis projects that battery electric buses purchased in 2030 will have an average operating cost of $3.382/mi. Over a 12- year lifecycle, the operational cost of BBB’s existing transit bus is approximately $1,079,343/bus Item 4-A 4/24/18 5 of 80 Item 4-A 4/24/18 compared to $1,094,823/bus for near-zero NOx emission transit buses, $1,568,898/bus for battery electric transit buses purchased in 2017, and $1,308,834/bus for battery electric buses purchased in 2030. This represents an incremental cost of $15,480/bus for near-zero NOx emission transit buses, $489,555/bus for battery electric transit buses purchased in 2017, and $229,491/bus for battery electric transit buses purchased in 2030. Estimated costs for battery electric transit buses take into account significant reductions in battery costs over time and are net of projected credits that BBB could generate under California’s Low Carbon Fuel Standard (LCFS). The emissions analysis found well-to-wheel (WTW) GHG emissions of BBB’s existing transit bus to be 1,475 grams per mile (g/mi) compared to 1,213 g/mi emitted from near-zero NOx transit buses, and 8.88 g/mi for battery electric transit buses purchased in 2017 and in 2030. Well-to- tank (WTT) NOx emissions were found to be 4.53 g/mi for BBB’s existing transit buses, 4.55 g/mi for near-zero NOx transit buses, and 0.0653 g/mi for battery electric transit buses purchased in 2017 and in 2030. Tank-to-wheel (TTW) NOx emissions were found to be 0.581 g/mi emitted by Item 4-A 4/24/18 6 of 80 Item 4-A 4/24/18 BBB’s existing transit buses compared to 0.045 g/mi emitted from near-zero NOx transit buses and 0.00 g/mi emitted from battery electric transit buses purchased in 2017 and in 2030. Transit Bus Emissions Profiles BBB Existing Transit Bus NZE NOx CNG Transit Bus 2017 Battery Electric Transit Bus 2030 Battery Electric Transit Bus WTW GHG Emissions 1,475 g/mi 1,213 g/mi 8.88 g/mi 8.88 g/mi WTT NOx Emissions 4.53 g/mi 4.55 g/mi 0.0653 g/mi 0.0653 g/mi TTW NOx Emissions 0.581 g/mi 0.045 g/mi 0.000 g/mi 0.000 g/mi WTW NOx Emissions 5.111 g/mi 4.600 g/mi 0.065 g/mi 0.065 g/mi In addition to evaluating the cost and emissions performance of the individual transit bus technologies, BBB’s fleet-wide costs and emissions were evaluated over the proposed Innovative Clean Transit (ICT) regulatory timeframe that is currently under development by the California Air Resources Board (ARB). The figure below displays BBB’s existing fleet transitioning to near-zero NOx emission natural gas transit buses according BBB’s planned replacement schedule. During the 23-year implementation timeframe of the ICT regulation, BBB would incur a cost of approximately $414 million as a result of continuing to procure and operate their existing transit bus technology. The analysis found that BBB would incur a cost of approximately $418 million as a result of transitioning the existing fleet to a near-zero NOx emission natural gas fleet, representing and incremental cost of approximately $4 million. The analysis also found that BBB would incur a cost of approximately $492 million (an incremental cost of $78 million) as a result of transitioning to a battery electric fleet assuming expected reductions in battery costs and net of projected LCFS credits generated across the timeframe. BBB Fleet Costs – 2018-2040 BBB Existing Transit Fleet NZE NOx CNG Transit Fleet Battery Electric Transit Fleet Fleet Operational Costs $ 413,748,150 $ 417,803,910 $ 492,001,711 Incremental Cost Relative to Baseline Scenario $ - ↑ $ 4,055,760 ↑ $ 78,253,561 Item 4-A 4/24/18 7 of 80 Item 4-A 4/24/18 Transitioning BBB’s fleet to near-zero NOx emission natural gas transit buses will reduce the fleets WTW GHG emissions by 26,724 MT during the timeframe. Transitioning BBB’s existing fleet to a battery electric fleet will significantly reduce fleet-wide GHG emissions by approximately 150,000 MT during the timeframe. However, the reductions provided by the transition to battery electric transit buses come at a cost of approximately $78 million or approximately $526/MT. The majority (approximately 99%) of WTW GHGs emitted during the transition to a battery electric fleet are the emissions from BBB’s existing transit buses as they operate for the remainder of their useful. The analysis found that transitioning to either of the alternative scenarios technologies will yield significant TTW NOx reductions. During the timeframe, transitioning to a near zero NOx emission natural gas transit fleet yields a 63% reduction from the baseline scenario while the transition to a battery electric transit fleet buses yields a 68% reduction from the baseline scenario. Though the reductions achieved by each scenario are comparable, there is a significant difference in the costs that will be incurred. At an incremental cost of approximately $4 million, the 60.1 tons of NOx reduced as a result of transitioning to a near-zero NOx natural gas fleet will cost approximately $67,484/ton. In contrast, the 65.1 tons of NOx reduced as a result of transitioning to a battery electric transit fleet will cost approximately $1,202,052/ton (approximately 1800% than the cost of the reductions that would result from transitioning to an NZE NOx fleet) because the incremental cost of transitioning to a battery electric transit fleet is approximately $78 million. BBB Fleet Emissions – 2018- 2040 BBB Existing Transit Fleet NZE NOx CNG Transit Fleet Battery Electric Transit Fleet TTW NOx Emissions 95.2 tons 35.1 tons 30.1 tons Reductions Relative to Baseline Scenario 0.0 ↓ 60.1 tons ↓ 65.1 tons Cost of TTW NOx Emissions Reductions 0.0 $67,484/ton $1,202,052/ton The analysis also found that transitioning to a near-zero NOx emission natural gas transit fleet will not yield any significant PM10 (particulate matter) reductions. The reason for this is because the Cummins ISL G Near-Zero (NZ) and the Cummins ISL G (equipped in BBB’s existing transit buses) have the same certified PM10 emissions values. In contrast, transitioning to a battery electric transit fleet yields a 68% reduction from the baseline scenario. While this is a significant percent reduction, the PM emissions from each of the scenarios is very small because natural gas engines have extremely low PM10 emissions. In summary, the analysis found that, at an incremental cost of approximately $4 million, the transition of BBB’s existing fleet to a fleet of near-zero NOx emission natural gas transit buses will result in a small decrease in GHG emissions and a significant reduction in TTW NOx emissions. At an incremental cost of approximately $78 million, the transition of BBB’s existing fleet to battery electric transit buses will result in GHG and TTW NOx emissions reductions that are very costly compared to those achieved from the deployment of near-zero NOx emission natural gas transit buses. The results of the analysis are based on projections of significant operating cost reductions for battery electric buses over time. These reductions are based on large reductions in battery storage costs and projections of revenue from the LCFS program. GNA acknowledges that changes in these assumptions will have a dramatic impact on the total estimated project costs. Should battery storage costs remain constant (and not fall over time as projected), the incremental Item 4-A 4/24/18 8 of 80 Item 4-A 4/24/18 cost of converting the entire fleet to battery electric buses would increase to approximately $130 million as opposed to approximately $78 million. The LCFS program works with other programs in California, such as the Cap-and-Trade Program, to reduce transportation-related GHG emissions. Credits are generated from the use of low carbon fuels in the transportation sector. Regulated entities, such as petroleum refiners, are required to purchase credits to offset the GHG emissions associated with the higher carbon fuels that they produce. It is the demand for these credits by regulated entities that sets the credit price. Though the credit price has remained stable in recent years, future credit prices will be established in an open market environment and any fluctuations in the price of the credit will directly impact BBB’s cost of operating battery electric buses. In the event that battery storage costs remain constant and the market value of LCFS credits declines by 50%, the incremental cost of converting the entire fleet to battery electric buses would rise to approximately $141 million. If the market for LCFS credits is eliminated entirely and battery prices remain constant, the incremental cost for converting BBB’s fleet to battery electric buses would rise further to approximately $152 million. Taking into account the uncertainty that exists when making projections about the future, the analysis estimates that the incremental cost of converting BBB’s existing fleet to battery electric buses ranges from approximately $78 million to $152 million during the timeframe (2018-2040). Item 4-A 4/24/18 9 of 80 Item 4-A 4/24/18 1. BACKGROUND An analysis of the City of Santa Monica’s (City’s) Big Blue Bus (BBB) transit fleet was performed to assess the economic and environmental benefits of transitioning BBB’s fleet to alternative technologies. The alternative technologies evaluated include transitioning BBB’s existing fleet to near-zero NOx emission (NZE) natural gas buses that will continue to be fuelled by RNG, and transitioning BBB’s existing fleet to battery electric transit buses (BEB). The evaluation assessed the economic and environmental benefits of the existing fleet (baseline) and alternative technology scenarios over the regulatory timeframe of the California Air Resources Board’s (ARB’s) proposed Innovative Clean Transit (ICT) regulation which is further described in Section 3. The environmental profile and the capital and operational costs were analysed for the baseline scenario and the two alternative transit technology deployment scenarios. The evaluation of the environmental benefits includes analysing greenhouse gas (GHG), oxides of nitrogen (NOx), and particulate matter (PM10) emissions. The emissions were evaluated on a per mile basis for each technology, as well as a fleet wide basis over the regulatory timeframe. Similarly, the evaluation of operational costs include the capital costs for the transit buses, as well as capital costs for the infrastructure required to support each of the alternative scenarios. The first element in conducting the analysis was to the development of a cost and emissions profile of BBB’s existing fleet that serves as the baseline for comparison to the two alternative transit technologies over the proposed regulatory timeframe. This final report compares the results from the baseline cost and emissions analysis to each of the two alternative scenarios. Item 4-A 4/24/18 10 of 80 Item 4-A 4/24/18 2. BIG BLUE BUS TRANSIT FLEET PROFILE The BBB transit fleet provides service to approximately 13.3 million passengers annually in an urban service area of 51 square miles. The fleet’s service area is vastly larger than the City’s municipal service boundary of 8.6 square miles. The urban area serviced by BBB’s transit fleet includes the entire Westside region of Los Angeles. BBB’s operations maintain twenty routes that include traditional local transit service, commuter transit, express service, and community-based circulators. Facility Overview Transit operations and supporting administrative functions occur at BBB’s transit facility located at 1660 7th Street, Santa Monica, CA 90401. The transit facility consists of a maintenance facility, administrative buildings, fuelling infrastructure, wash bays, bus yard, and a maintenance parking lot for staff vehicles. All buses enter and exit through a guarded gate located on 6th Street. This is also the primary gate for staff, vendors, and other visitors. The transit facility currently operates at maximum capacity and is constrained by limited parking for both buses and staff vehicles. Bus parking is limited and at capacity during off-service hours which occur between midnight and 4:00AM. Staff parking is limited and typically at capacity during peak staffing hours which occur between noon and 4:30PM. The maintenance facility was remodelled in 2009 and there are currently no plans for expanding the facility. When not required for service, transit buses are parked 3 deep in a nose-to-tail configuration. Parking of transit buses are performed based on availability, as individual buses are not assigned specific stalls within the yard. The bus maintenance facility has 21 bays for performing a variety of maintenance services and repairs. Two of the bays within the facility are dedicated to servicing BBB’s small fleet of articulated buses. Fleet Overview To provide these services, BBB operates a fleet of 200 natural gas urban transit buses which include nineteen (19) 30-35 foot buses, 153 40-foot buses, and 28 60-foot articulated buses. Approximately 60% of the fleet is model year 2011 or newer buses. The entire fleet is powered by natural gas engines fuelled with renewable natural gas. 62.5% of the fleet operates on compressed natural gas (CNG) and 37.5% operates on liquefied natural gas (LNG). However, all LNG buses within the fleet will be retired no later than 2019. Fuelling and Fuelling Infrastructure There are two fuelling stations physically located on BBB’s property. A private on-site station is located within the fenced boundary of the transit facility, while a public access station is located outside of the fenced boundary but still on BBB’s property. The on-site liquefied-compressed natural gas (LCNG) and LNG fuelling stations are integrated within the bus wash bays within the transit facility. However, the private fuelling station also has a separate dispenser which is located adjacent to the wash bays and serves as an optional fuelling location for other City-owned vehicles, such as the City’s refuse fleet. Item 4-A 4/24/18 11 of 80 Item 4-A 4/24/18 BBB’s transit fleet is currently supplied with CNG (via the LCNG station) and LNG from renewable liquefied natural gas (RLNG) that is procured from Clean Energy. On average, Clean Energy delivers one load of RLNG each day which is transported via tanker truck from Clean Energy’s Boron LNG plant. An onsite storage tank supplies the RLNG to the LCNG and LNG dispensers that are co-located within the drive-through wash bays. Utilities Electricity is provided to the transit facility by Southern California Edison (SCE). On average, BBB’s electricity cost is higher than that of surrounding utility customers because the City procures a higher fraction of renewable electricity in its electricity mix than SCE’s average delivered electricity mix. The low carbon electricity is purchased via a third party energy service provider (ESP) but is delivered through SCE’s distribution system. It should be noted that SCE is currently working with the Public Utilities Commission (PUC) to obtain approval for a tariff that will allow SCE funds to be used to pay for utility infrastructure upgrades that are required to support electric vehicle deployments. Approval of the tariff would allow SCE to fund transformers, wires, and other upgrades to bring power up to the connection with the charger. Transit Operations During peak service days which occur Monday through Friday, BBB’s fleet operates 240 daily weekday assignments which require 162 transit buses during peak weekday service. The average distance of an assignment is 71 miles; however, individual assignments range from 13 miles up to 181 miles. Some transit buses receive more than one assignment during a peak day. The majority of route operations occur on primarily flat surfaces, however, there are a small number of route assignments, such as those travelling to and from the Pacific Palisades area, that entail a significant amount of elevation change. It is important to note that the analysis does not take into account topography due to the limited number of assignments that are exposed to changes in elevation. Transit layovers are not performed on properties owned by BBB, although, all routes have at least one stop at a Metro train station. Only 1% of all BBB’s services are performed on dedicated lanes which service point-to-point locations. Morning assignments begin at 4:00AM and occur throughout the day until 12:30AM. Item 4-A 4/24/18 12 of 80 Item 4-A 4/24/18 3. CALIFORNIA AIR RESOURCES BOARD INNOVATIVE CLEAN TRANSIT REGULATION Since 2000, the California Air Resources Board has sought to require California’s transit agencies to reduce criteria pollutants and exposure to toxic air contaminants by mandating the transition of the state’s urban bus population to zero-tailpipe emission transit buses. The mandate, which was originally included as part of ARB’s Fleet Rule for Transit Agencies (Fleet Rule), has gone through a series of delays, cancellations, and reinvention. The delays and cancellations were the result of a lack of commercially viable zero-tailpipe emission transit buses. After being permanently removed from the Fleet Rule, the mandate was reintroduced in May of 2015 as part of the proposed Advanced Clean Transit (ACT) regulation. At that time, ARB released a Discussion Document outlining the concepts envisioned for the proposed ACT regulation. The Discussion Document proposed that all transit agencies operating in California be required to begin purchasing zero-tailpipe emission buses starting in 2018. It was proposed that this mandate continue until California’s entire transit fleet was transitioned to zero-tailpipe emission transit buses in 2040. During the following two years, ARB held a series of ACT Workgroup meetings to investigate and further understand barriers that inhibit zero-tailpipe emission bus adoption, such as costs, safety conflicts, infrastructure installation, operating range, and utility supply. From these meetings, ARB sought to collect information to improve and revise the proposed ACT regulation. It was during these meetings, that transit agencies and associations actively urged ARB to consider a performance based approach rather than a purchase requirement to achieve ARB’s emission reduction goals. In March of 2017, ARB released the Revised Proposed 2016 State Strategy for the State Implementation Plan (SIP) which outlined the steps that California would take to reduce in-state emissions.1 Within the SIP, ARB proposed to reintroduce a zero-tailpipe emission transit bus purchase mandate under a new Innovative Clean Transit (ICT) regulation, effectively renaming ACT to ICT. Though draft regulatory language has yet to be released, the ICT regulation intends to maintain support for the long-term transition of California’s transit fleet to zero-tailpipe emission transit buses. If adopted, this would directly impact approximately 200 transit agencies and 11,000 urban transit buses operating in California. However, the ICT regulation appears to provide flexibility to, or reward, fleets for taking early action to reduce emissions by proactively implementing advanced technologies prior to implementation requirements in the proposed regulation. ARB is currently gathering additional data in order to draft the ICT regulation. It was initial anticipated that the ICT regulation would be considered for adoption at an ARB board hearing by the end of 2017. However, draft regulatory language has not been made public at the time of this report so it is likely that the ICT regulation will not be considered for adoption at an 1 Revised Proposed 2016 State Strategy for the State Implementation Plan, ARB, March 7, 2017 https://www.arb.ca.gov/planning/sip/2016sip/rev2016statesip.pdf Item 4-A 4/24/18 13 of 80 Item 4-A 4/24/18 ARB board hearing until 2018. If adopted, the implementation timeframe of the regulation would be 2018-2040. Consistent with the most recent implementation timeframe stated by the ARB, BBB’s fleet was analysed over the 2018-2040 timeframe. During this period, the cost and emissions profile of BBB’s existing fleet and the alternative deployment scenarios were evaluated. The results of this analysis present the cost and emissions profile for BBB’s existing fleet transitioned to a fleet of NZE natural gas transit buses and for BBB’s existing fleet transitioned to BEBs. Item 4-A 4/24/18 14 of 80 Item 4-A 4/24/18 4. TRANSIT BUS COST ANALYSIS A cost analysis was performed to characterize the operational costs for each of the three technologies. The operational cost of a transit bus is an aggregate of the individual cost factors that include: bus capital, fuel, operations and maintenance (O&M), midlife overhaul, fuelling infrastructure, and facility modification costs. For each technology, costs were generated on a per-mile and lifecycle basis using fleet composition, operational data, procedural data, and assumptions where necessary to characterize the recently commercialized technologies. 4.1. EXISTING TRANSIT BUS COST ANALYSIS Data provided by BBB on their existing transit buses was analysed to determine an average cost for each factor as a component of the overall cost. Detailed explanations of the cost assumptions used are included in APPENDIX B – Transit Bus Costs and Assumptions and APPENDIX C – Fuel and Fuelling Infrastructure Cost Assumptions. Capital Costs BBB’s existing fleet consists of several bus makes, models, and model years. In order to evaluate operational and lifecycle costs, assumptions were made about the typical bus platform and corresponding capital costs in order to come up with a composite that best represented vehicles that comprise BBB’s existing fleet. Fleet data provided by BBB contained the unit cost for each bus in BBB’s existing fleet. However, the data revealed significant variability in bus capital costs even across similarly sized buses. In addition to differences in makes, models, and specified features, cost variability was also attributed to economic factors such as increases in index prices. For this reason, it is assumed that the capital cost of BBB’s most recent bus procurements would be used as the baseline transit bus configuration for the analysis of BBB’s existing fleet. Table 1 below contains the capital cost assumed in the analysis. Capital Cost BBB Existing Transit Bus Incremental Cost Relative to Baseline 2016 40-foot Low Floor Bus $ 605,336/bus - Table 1: BBB existing transit bus capital cost Fuel Costs BBB’s transit fleet consumes approximately 2.1 million diesel gallons-equivalent (DGE) of RLNG annually. BBB’s total fuel costs are a combination of delivered RLNG, LCNG station O&M, and onsite staff costs necessary to support station operations. The cost of delivered RLNG includes commodity, transportation, and sales tax. It should be noted that included in the cost of delivered RLNG is the value of the credit generated from the Low Carbon Fuel Standard (LCFS). The average delivered fuel cost was determined using monthly fuel purchase records for RLNG purchased from Clean Energy between July 1, 2016 and December 1, 2016. Monthly volume and cost data was evaluated to identify the average unit cost of the fuel. LCNG station O&M costs were calculated using the average annual cost of the contract that BBB pays to Clean Energy for routine station maintenance and typical repairs that are required throughout the year. Station Item 4-A 4/24/18 15 of 80 Item 4-A 4/24/18 O&M costs were extrapolated across BBB’s average annual purchase volume to determine the contribution of LCNG station O&M to total fuel costs. Lastly, BBB employs a technician to support day-to-day LCNG station operations. Table 2 below displays BBB’s average total fuel cost and a breakdown of each cost component. BBB RLNG Fuel Costs Delivered Fuel $ 1.065/DGE Station O&M $ 0.118/DGE Onsite Staff $ 0.056/DGE Total Fuel Cost $ 1.239/DGE Table 2: BBB existing transit bus fuel costs Operations and Maintenance Costs The O&M costs for BBB’s existing transit buses were determined from service records for the maintenance and repairs performed on each vehicle within the fleet. The service records contained the O&M costs incurred from 2013 to present which provided a sufficient timeframe for evaluating the data for buses spanning several model years. Because bus O&M costs increase with the age of the bus, the data was analysed across individual makes and model years in order to come up with a reasonable cost assumption that best represented the average O&M costs for a bus near the midpoint of its useful life. The data provided by BBB consisted of O&M costs classified into four different categories: engine, transmission, brake, and other. The data allows for costs to be further classified as propulsion or non-propulsion costs. Engine and transmission maintenance and repairs were classified as propulsion related O&M costs. Brake and other maintenance and repairs were classified as non- propulsion related O&M costs. Because the average age of BBB’s fleet is slightly over six years, the entire dataset was used to determine average O&M costs. Table 3 contains the average O&M costs for BBB’s existing fleet. BBB Existing Transit Bus O&M Costs* Propulsion Related $ 0.196/mi Engine O&M $ 0.170/mi Transmission O&M $ 0.026/mi Non Propulsion Related $ 0.620/mi Brake O&M $ 0.048/mi Other O&M $ 0.572/mi Total O&M $ 0.816/mi * Excluding model year 2017 buses Table 3: BBB existing transit bus O&M costs Transit bus O&M costs were evaluated in such detail because certain components are more likely to vary from technology to technology while others can be assumed to be relatively unaffected across the range of powertrain technologies. For example, propulsion related O&M costs are likely to differ between BBBs existing transit buses and advanced technologies such as BEBs. For Item 4-A 4/24/18 16 of 80 Item 4-A 4/24/18 BEBs, brake repair costs are included as part of propulsion related O&M costs because the regenerative braking systems are integral to the propulsion system. Non-propulsion related maintenance costs, such as preventative maintenance inspections and other maintenance cost components, are not expected to vary from technology to technology. Midlife Overhaul Costs Midlife overhaul costs were determined from fleet maintenance records and adjusted based on BBB’s experience. Historically, BBB has performed midlife overhauls on an as-needed basis due to major component failures. However, BBB plans to standardize the timing of midlife overhauls so that they are routinely performed in the middle of the useful life of each bus. BBB’s midlife overhaul consists of rebuilding the existing engine, transmission, and brake system. Other aspects of the bus, such as driver area, seating upholstery, paint, etc., are also reconditioned as part of the midlife overhaul. However, the costs associated with performing these reconditioning activities are likely to remain relatively consistent across bus platforms regardless of the powertrain technology. Unlike the typical reconditioning activities that are consistent across bus platforms, the midlife costs associated with the powertrain vary significantly across alternative powertrain configurations. Since the ultimate objective of the analysis is to compare the existing transit fleet to the alternative powertrain configurations, only costs specifically related to the propulsion system are included as part of the midlife overhaul costs. Table 4 contains the midlife cost assumptions for BBB’s existing fleet. BBB Existing Transit Bus Midlife Overhaul Costs Engine Overhaul $ 17,000/bus Transmission Overhaul $ 8,000/bus Brake System Overhaul $ 2,000/bus Total Midlife Overhaul Cost $ 27,000/bus Table 4: BBB existing transit bus midlife overhaul costs Fuelling Infrastructure and Facility Modification Costs Transit agencies deploying a new technology are often faced with installing fuelling infrastructure, such as dispensers, chargers, fuelling islands/stations, etc. In addition, it is common that modifications to the existing facility be performed in order to comply with safety requirements specific to the fuel. Since the existing fuelling infrastructure and maintenance facility currently meet the needs of BBB’s natural gas fleet, it is assumed that no new fuelling infrastructure or facility modifications will be required to continue current operations. BBB is currently conducting an inventory assessment of its existing fuelling infrastructure. The inventory will aid in determining if the existing LCNG fuelling infrastructure will require replacement at some point during the evaluation period. In the event that the infrastructure requires replacement, the costs associated with a new LCNG or CNG fuelling station should be updated and factored in as part of the costs associated with the existing fleet. Item 4-A 4/24/18 17 of 80 Item 4-A 4/24/18 Existing Bus Operational and Total Lifecycle Costs To determine operational and lifecycle costs, assumptions about average fuel economy, annual mileage, and useful life were also required. Average fuel economy for BBB’s existing buses was calculated using fleet data provided by BBB. The data contained the mileage and fuel consumed for each bus between July 1, 2016 and December 31, 2016. In order to make a reasonable assumption that accounted for the diversity of BBB’s routes and the fuel economy of newer buses that would serve as the baseline replacement technology, fuel economy was calculated by taking an average of the in-service fuel economies for model year 2011 through model year 2016 40- foot transit buses. It is assumed that average annual mileage would be unaffected by model year, therefore, annual mileage was calculated by taking the average annual hub miles for BBB’s entire fleet. The analysis found that BBB’s useful life fluctuates from year-to-year due to funding availability, City Council authorization, and bus manufacturer backlogs. Per discussions with BBB, the intended and desired useful life of BBB’s buses is 12 years. Table 5 below provides a summary of the assumptions used for determining operational and total lifecycle costs. BBB Existing Natural Gas Transit Bus Average Annual Mileage Average Fuel Economy (mi/DGE) Intended Useful Life 32,250 mi/year 3.66 mi/DGE 12 years Table 5: BBB existing transit bus fuel economy, mileage, and useful life Using the cost factors and assumptions described above, BBB’s operational and total lifecycle costs were calculated. These costs serve as the baseline economic metrics for comparing the costs of BBB’s existing transit bus fleet to those of the alternative transit bus technologies. Table 6 below displays per mile and total lifecycle costs of BBB’s existing transit buses. Transit Bus Operational and Lifecycle Costs BBB Existing Transit Bus Incremental Cost Relative to Baseline Bus Capital Cost $ 1.564/mi - Fuel Cost $ 0.339/mi - Bus O&M $ 0.816/mi - Midlife Overhaul Cost $ 0.070/mi - Infrastructure Cost $ 0.000/mi - Total Operational Cost $ 2.789/mi - Total 12-Year Lifecycle Cost $ 1,079,343/bus - Table 6: BBB existing transit bus operational and lifecycle costs 4.2. NEAR -ZERO NOx EMISSION NATURAL GAS TRANSIT BUS COST ANALYSIS In 2016, the Cummins Westport ISL G Near Zero (NZ) natural gas engine received ARB emissions certification as the first engine to meet ARB’s optional 0.02 g/bhp-hr low NOx emission standard. Item 4-A 4/24/18 18 of 80 Item 4-A 4/24/18 This meant that the NOx emissions exhausted from the engine were 90% lower than ARB’s current NOx emission limit for heavy-duty engines. The ISL G NZ is similar to the ISL G natural gas engine that currently powers BBB’s existing transit bus fleet. Both engines feature the same stoichiometric cooled exhaust gas recirculation combustion technology, spark ignition, and a three-way catalyst (TWC). However, to meet the low NOx emission standard, closed crankcase ventilation (CCV) and a larger TWC were integrated into the engine. While these improvements are accompanied by a small increase in capital cost, deploying the technology within an existing natural gas fuelled transit fleet does not accompany many of the challenges often faced with alternative transit technologies. Similar to the analysis of BBB’s existing transit buses, an analysis was performed to evaluate the operational and lifecycle costs of NZE natural gas transit buses. Data provided by BBB combined with assumptions, where necessary, was analysed to determine an average cost for each factor as a component of the overall transit bus costs. Detailed explanations of the cost assumptions used are included in APPENDIX B – Transit Bus Costs and Assumptions and APPENDIX C – Fuel and Fuelling Infrastructure Cost Assumptions. Capital Costs Recent procurement data provided by BBB was used to determine the capital cost for NZE natural gas transit buses. Table 7 contains the capital cost assumed in the analysis. Capital Cost Near-Zero NOx CNG Transit Bus Incremental Cost Relative to Baseline 2017 40-foot Low Floor Bus $ 613,776/bus ↑ $8,440 Table 7: Near-zero NOx emission natural gas transit bus capital cost Fuel Costs Near-zero NOx emission natural gas transit buses are fuelled by natural gas with the same fuel properties as those required by BBB’s existing transit buses. For this reason, it is assumed that NZE natural gas transit buses would be fuelled using the same RLNG that BBB currently procures from Clean Energy. In addition, there would be no impact to BBB’s LCNG station O&M costs and the costs associated with BBB’s technician that supports day-to-day LCNG station operations. Table 8 displays BBB’s average total fuel cost and a breakdown of each cost component. Fuel Cost RLNG Incremental Cost Relative to Baseline Delivered Fuel $ 1.065/DGE - Station O&M $ 0.118/DGE - Onsite Staff $ 0.056/DGE - Total Fuel Cost $ 1.239/DGE - Table 8: Fuel costs for NZE natural gas transit buses Operations and Maintenance Costs Item 4-A 4/24/18 19 of 80 Item 4-A 4/24/18 Near-zero NOx emission natural gas transit bus O&M costs were determined from service records for the maintenance and repairs performed on BBB’s existing fleet and assumptions regarding additional costs related to the ISL G NZ’s increased complexity. Using the O&M data provided by BBB, assumptions were made regarding the potential impact on each of the four O&M cost categories described in the preceding section. Transmission, brake, and other O&M costs are not expected to be impacted as a result of deploying the ISL G NZ technology. However, the analysis assumes that engine O&M costs will increase by approximately 5% due to the increased complexity and cost of the NZE natural gas engine. Table 9 contains the O&M costs for NZE natural gas transit buses operating in BBB’s fleet. O&M Costs* Near-Zero NOx Emission Incremental Cost Relative to Baseline Propulsion Related $ 0.205/mi ↑ $ 0.009/mi Engine O&M $ 0.179/mi ↑ $ 0.009/mi Transmission O&M $ 0.026/mi $ 0.000/mi Non Propulsion Related $ 0.620/mi $ 0.000/mi Brake O&M $ 0.048/mi $ 0.000/mi Other O&M $ 0.572/mi $ 0.000/mi Total O&M $ 0.825/mi ↑ $ 0.009/mi * Excluding model year 2017 buses Table 9: O&M costs for NZE natural gas transit bus Midlife Overhaul Costs Midlife overhaul costs for NZE natural gas transit buses were determined from fleet maintenance records, BBB’s experience, and assumptions to account for the added complexity of the ISL G NZ natural gas engine. Similar to the methodology used for BBB’s existing transit buses, the analysis assumes that midlife overhauls will be performed at the middle of the buses useful life and only the costs specifically related to the buses propulsion system will be included as part of the analysis. The analysis assumes that ISL G NZ’s added complexity will increase engine overhaul costs by $3,000/bus. Further, it is assumed that midlife overhaul costs associated with the transmission and brake system will be the same as BBB’s existing transit buses. Table 10 contains the midlife cost assumptions for NZE natural gas transit buses operating within BBB’s fleet. Midlife Overhaul Costs Near-Zero NOx Emission Incremental Cost Relative to Baseline Engine Overhaul $ 20,000/bus ↑ $3,000/bus Transmission Overhaul $ 8,000/bus $0/bus Brake System Overhaul $ 2,000/bus $0/bus Total Midlife Overhaul Cost $ 30,000/bus ↑ $3,000/bus Table 10: Midlife overhaul costs for NZE natural gas transit buses Fuelling Infrastructure and Facility Modification Costs Item 4-A 4/24/18 20 of 80 Item 4-A 4/24/18 Since the existing fuelling infrastructure and maintenance facility currently meet the needs of BBB’s natural gas fleet, it is assumed that no new fuelling infrastructure or facility modifications will be required as a result of transitioning BBB’s fleet to NZE natural gas transit buses. Operational and Total Lifecycle Costs To determine operational and lifecycle costs, assumptions about average fuel economy, annual mileage, and useful life were also required. Average fuel economy for BBB’s existing fleet was previously calculated using fleet data provided by BBB. The data contained the mileage and fuel consumed for each bus between July 1, 2016 and December 31, 2016. In order to make a reasonable assumption that accounted for the diversity of BBB’s routes and the fuel economy of newer buses that would serve as the baseline replacement technology, fuel economy was calculated by taking an average of the in-service fuel economies for model year 2011 through model year 2016 40-foot transit buses. Near-zero NOx emission natural gas engine are slightly less efficient than the natural gas engines operating in BBB’s existing fleet. Using the test data contained on the ARB Executive Order for each engine, the NZE natural gas engine is 0.43% less efficient than the standard CNG engine certified to current emissions standards. It is assumed that average annual mileage and intended useful life would not change as a result of transitioning to a NZE natural gas fleet. Table 11 provides a summary of the assumptions used for determining operational and total lifecycle costs. Near-Zero NOx Emission Natural Gas Transit Bus Average Annual Mileage Average Fuel Economy (mi/DGE) Intended Useful Life 32,250 mi/year 3.64 mi/DGE 12 years Table 11: Near-zero NOx emission natural gas transit bus fuel economy, mileage, and useful life Using the cost factors and assumptions described above, operational and total lifecycle costs were calculated for a NZE natural gas transit bus. Table 12 displays per mile, annual, and total lifecycle costs of NZE natural gas transit bus operating within BBB’s fleet. Operational and Lifecycle Costs Near-Zero NOx CNG Transit Bus Incremental Cost Relative to Baseline Bus Capital Cost $ 1.586/mi ↑ $ 0.022/mi Fuel Cost $ 0.340/mi ↑ $ 0.001/mi Bus O&M $ 0.825/mi ↑ $ 0.009/mi Midlife Overhaul Cost $ 0.078/mi ↑ $ 0.008/mi Infrastructure Cost $ 0.000/mi $ 0.000/mi Total Operational Cost $ 2.829/mi ↑ $ 0.040/mi Total 12-Year Lifecycle Cost $ 1,094,823/bus ↑ $ 15,480/bus Table 12: Near-zero emission NOx natural gas transit bus operational and lifecycle costs The transition to NZE natural gas transit buses will increase BBB’s cost by $0.040/mi which translates to an increase of approximately $15,480/bus over a 12-year lifecycle. Item 4-A 4/24/18 21 of 80 Item 4-A 4/24/18 4.3. BATTERY ELECTRIC TRANSIT BUS COST ANALYSIS Similar to the preceding analysis of BBB’s existing and NZE natural gas transit buses, an analysis was performed to evaluate the operational and lifecycle costs of zero-tailpipe emission BEBs placed into BBB’s operations. Because of the inherent differences associated with today’s BEB technologies, the analysis for determining the costs of BEBs entailed a two stop process. The first step in the process was to conduct a technology and operational assessment to determine the BEB specifications that best met BBB’s operational requirements. Once the BEB specifications were determined, an analysis was performed to calculate the operational and lifecycle costs for a BEB. Data provided by BBB combined with assumptions, where necessary, was analysed to determine an average cost for each factor as a component of BEB costs. Detailed explanations of the cost assumptions used are included in APPENDIX B – Transit Bus Costs and Assumptions and APPENDIX C – Fuel and Fuelling Infrastructure Cost Assumptions. 4.3.1. BATTERY ELECTRIC BUS TECHNOLOGY & OPERATIONAL ASSESSMENT An operational and technology assessment was performed in order to evaluate the feasibility of replacing one of BBB’s existing transit buses with a zero-tailpipe emission BEB. BBB Assignment/Block Evaluation BBB’s bus assignment “blocks” were analysed to calculate the distribution of expected daily mileage for the BBB fleet. BBB operates 240 blocks of work each day which require 162 buses to be in service during peak periods. Approximately, half of the fleet operates one block per day and half operates two blocks per day. Buses that operate two blocks per day typically leave the depot early in the morning to cover the morning peak service and then return to the depot mid-morning. These buses lay-over at the depot for 2-4 hours during mid-day service and then leave again in the mid-afternoon to cover the evening peak service. Buses that operate one block per day also typically leave the depot early in the morning to cover the morning peak services but do not return to the depot until late afternoon or evening. These buses stay out in continuous service for 12-18 hours per day. Table 13: Summary of BBB’s assignments/blocks BBB’s peak service, which requires 162 buses, occurs between 4:30PM and 6:30PM. BBB’s morning peak service requires slightly fewer buses. Figure 1 and Figure 2 below displays the number of buses in-service and at the depot for each hour of the day based on the scheduled service blocks. As a critical input to the BEB charging analysis, it is used to calculate average load (kW) and average energy (kWh) by time of day for electric bus charging. HRS MILES HRS MILES MIN MAX MIN MAX Buses with 2 Blocks per day 80 160 5.9 46.2 11.8 92.4 3.5 15.8 36.6 138.0 Buses with 1 block per day 82 82 13.2 118.8 13.2 118.8 4.7 19.6 84.8 181.4 162 242 BLOCKSBUSES TOTAL HOURS/DAY MILES/DAYAVG per BLOCK AVG per Day Item 4-A 4/24/18 22 of 80 Item 4-A 4/24/18 Figure 1: Hourly distribution of BBB’s buses in operation during weekday service Figure 2: Hourly distribution of BBB’s buses at the depot during weekday service Next, expected weekday mileage for each bus was calculated using the assumption that the 82 longest blocks (in terms of mileage and in-service hours) would be performed by buses that only operate one block per day. The remaining 160 blocks were matched up using the first-in/first-out assumption (i.e. the block that returned to the depot the earliest in the morning was matched with the block leaving the depot earliest in the afternoon). Blocks were also matched up by bus length (32-ft, 40-ft, 60-ft). This resulted in a list of projected daily miles and hours for all 162 weekday peak buses. The results are summarized in Table 14 below and every bus is plotted in Figure 3. Item 4-A 4/24/18 23 of 80 Item 4-A 4/24/18 Table 14: Summary of BBB routes profiles Figure 3: In-service mileage distribution for BBB’s fleet On average, BBB’s fleet operates approximately 100 miles and 12 hours per day per bus. However, the results also indicate that approximately 50% of buses operate more than 100 miles. For BBB’s 40-ft and 60-ft buses, approximately 60% operate less than 100 miles per day and 40% operate more than 100 miles per day. For BBB’s 32-ft buses, approximately 40% operate less than 100 miles per day and 60% operate more than 100 miles per day. This can be seen more clearly in the Figure 4 and Figure 5 below. BLOCKS HOURS MILES MI HR HR MI 1 40-ft 16 190 1,401 87.5 11.9 7.4 9.3% 8.2% 3, 23 40-ft; 60-ft 43 278 2,899 67.4 6.5 10.4 13.6% 16.9% 5 40-ft 5 5 26 5.2 1.0 5.2 0.2% 0.2% 2, 7, 8, 9, 10, 27 40-ft; 60-ft 89 787 6,514 73.2 8.8 8.3 38.6% 38.0% 12 40-ft 14 109 661 47.2 7.8 6.1 5.4% 3.9% 14 40-ft 9 58 460 51.1 6.5 7.9 2.9% 2.7% 15 40-ft 5 31 190 38.1 6.2 6.1 1.5% 1.1% 16 32-ft 4 38 314 78.6 9.5 8.3 1.9% 1.8% 17 40-ft 5 36 290 58.0 7.1 8.2 1.7% 1.7% 18 32-ft 11 100 866 78.7 9.1 8.6 4.9% 5.1% 41 32-ft; 40-ft 3 22 207 68.9 7.2 9.6 1.1% 1.2% 42 32-ft 3 20 187 62.4 6.6 9.5 1.0% 1.1% 43 32-ft 3 11 87 28.9 3.7 7.7 0.6% 0.5% 44 40-ft 3 35 260 86.8 11.7 7.4 1.7% 1.5% Other interlines 40-ft 31 317 2,781 89.7 10.2 8.8 15.6% 16.2% TOTAL 244 2,037 17,143 70.3 8.3 8.4 100.0% 100.0% AVG MPH % of SYSTEM TOTALBUS TYPES AVG PER BLOCKTOTAL ON ROUTEROUTE Item 4-A 4/24/18 24 of 80 Item 4-A 4/24/18 Figure 4: Mileage distribution as a percentage of BBB’s total fleet Figure 5: Hourly distribution of buses as a percentage of BBB’s fleet Electric Bus Passenger Capacity and Performance Evaluation Using the information obtained from the assignment/block evaluation, the next step in the analysis was to identify which of the commercially available BEBs is best suited for BBB’s operations. The capacity and performance characteristics of three BEB manufacturers were evaluated (see Table 15) in order to identify which bus model(s) were capable of satisfying the passenger requirements of BBB’s existing fleet. The following table displays the capacity characteristics of currently Item 4-A 4/24/18 25 of 80 Item 4-A 4/24/18 available BEBs. As shown, BBB could utilize electric buses with up to ~450 kWh battery packs without negatively affecting passenger capacity. Buses with larger packs would have significantly reduced capacity (based on gross vehicle weight limits), which would require BBB to schedule more buses in order to maintain existing service levels without routinely loading buses beyond their designed weight carrying capacity. Table 15: Capacity and performance characteristics of commercially available BEBs It was also necessary to better understand the anticipated energy consumption of the BEB models relative to that of BBB’s existing transit buses. A transit bus fuel economy model was adapted to BBB’s service using the average in-service speed and fuel economy of BBB’s existing CNG buses. Electric buses were base-lined using the relative energy use (bkWh/mi) of CNG and BYD electric buses at LACMTA. Figure 6 displays the energy consumption estimated for the BEBs placed in BBB’s operations. The projected differences between BYD, New Flyer, and Proterra buses are based on the Altoona test data for each bus. Item 4-A 4/24/18 26 of 80 Item 4-A 4/24/18 Figure 6: Estimated energy consumption of commercially available BEBs Using the anticipated energy consumption for each bus, the “effective” and “reliable” range for BEBs placed in BBB’s operations was calculated. The “effective” and “reliable” range is based on installed battery capacity, expected energy use (kWh/mi) in BBB operations at 7 miles per hour (MPH) average speed, and assumed battery degradation over the useful life of a bus. The calculation uses expected energy use at an average speed of 7 MPH, rather than the fleet average speed of 9 MPH, to account for daily variability in range per bus based on driver behaviour, traffic, etc. Using the energy consumption for each BEB, the estimated reliable range per charge can be calculated throughout a bus’s useful life. Table 16 displays the projected reliable range per charge for each available bus model after 6-years and 12-years of service life. The table also displays the minimum required charger size for each bus to achieve 100% state of charge (SOC) while parked overnight at BBB’s depot. For a bus placed in BBB’s operations with a ~350 kWh battery pack, the “effective” and “reliable” range per charge is approximately 115 miles after 6-years of service life and 95 miles after 12-years of service life, based on installed battery capacity, expected energy use, and projected battery degradation over time. Buses placed in BBB service with the largest feasible battery pack (~450 kWh) would have about 30-35 miles greater effective “effective” and “reliable” range throughout their service life which translates to an approximate range of 150 miles at year 6 and 125 miles at year 12. As indicated below, 29 kW is the minimum charger size required for an XE40 equipped with a 480 kWh battery pack placed in BBB’s operations, based on expected daily energy use and available charge time at the depot. The following calculations are based on worst case energy use for the bus with the largest possible battery capacity. Item 4-A 4/24/18 27 of 80 Item 4-A 4/24/18 Table 16: Estimated “effective” and “reliable” range for commercially available BEBs Figure 7 overlays the “effective” and “reliable” range with the distribution of total daily miles for a BEB equipped with a ~450 kWh battery pack. With an “effective” and “reliable” range of approximately 150 miles at year 6, the majority of BBB’s assignments blocks can be serviced by a BEB with a ~450 kWh battery pack. Only 16 (6.6%) of the 240 daily weekday blocks are greater than 140 miles. It is reasonable to assume that as BBB transitions to BEBs, buses would initially be placed into service on blocks with shorter mileage and “electrify” the blocks with the longest mileage last. According to BBB’s replacement schedule, transitioning to a 100% BEB fleet would not occur until 2029. It is anticipated that advancements in battery and bus technology will improve over the next 12 years such that the buses with sufficient “effective” and “reliable” range and capacity are available. However, this would require BBB to dedicate specific buses to these higher mileage blocks. An alternative would be to split the longest individual blocks into multiple blocks which may impact the number of buses required during peak weekday operations. BYD XR XR+E2 E2+E2 max ebus XE40 XE40 BATTERY CAPACITY kWh 220 330 440 550 660 324 350 480 Fleet Average kWh/mi 2.08 2.20 2.25 2.34 2.43 2.56 2.36 2.45 Daily Maximum kWh/mi 2.24 2.37 2.42 2.52 2.62 2.75 2.55 2.64 at year 6 80 113 148 178 205 96 112 148 at year 12 66 94 123 148 171 80 93 123 kW 25 26 27 28 29 31 28 29 1 See fuel economy model. Fleet average is at 9 MPH, and daily maximum is at 7 MPH in-service speed. 2 Assumes: Battery degradation 2.4%per year (based on BYD warranty; 70% capacity after 12 years) Depth of discharge 95% Daily maximum energy use (7 MPH) 3 Based on average daily energy use and: Average daily miles 106 miles Average daily in-service hours 12.5 hours Depot time not available for charging 2 hours Minimum required Charger Size 3 Proterra BusRANGE PER CHARGE NF PROJECTED BBB ENERGY USE 1 RELIABLE RANGE (Miles/Charge) 2 Item 4-A 4/24/18 28 of 80 Item 4-A 4/24/18 Figure 7: Distribution of total daily miles and “effective” and “reliable” range Battery Electric Bus Replacement Ratio Evaluation Given range limitations of BEBs, an evaluation was performed in order to assess where BEBs could replace BBB’s existing buses while maintaining the current level of service. It is worth of mention that the Federal Transit Administration (FTA) has specific requirement for the number of buses that a transit agency can have in addition to those required for service. FTA regulations mandate of spare ratio of equal to or less than 20%. While there has been discussion within the industry, including with the FTA, that the FTA may allow a spare ratio higher than 20% for fleets that operate battery electric and/or fuel cell transit buses, the FTA has not released an official statement permitting the increase in the spare ratio requirement. The analysis does not take into account the possibility that a higher replacement ratio may be necessary due to the potential lower reliability of newly commercialized technologies, such as BEBs. Figure 8 estimates the “replacement ratio” required to use only BEBs in BBB’s fleet, assuming that all will be charged exclusively at BBB’s facility using depot chargers. The vertical axis is electric bus range per charge (miles) and the horizontal axis is average replacement ratio (i.e. number of electric buses required to replace one of BBB’s existing CNG transit buses. As range per charge increases replacement ratio decreases. Item 4-A 4/24/18 29 of 80 Item 4-A 4/24/18 Figure 8: Estimated “replacement ratio” for buses charged exclusively at BBB’s depot This replacement ratio was calculated as follows: 1. Calculate % of buses with daily mileage less than the given range per charge – the replacement ratio for this percentage of the fleet is 1.0 2. Calculate average daily mileage for the remaining buses - the replacement ratio for this percentage of the fleet is Average Daily mileage ÷ miles per charge (>1.0) 3. The overall fleet average replacement ratio is the weighted average of the above two components In some cases, accommodating a depot-only charging strategy may require that long blocks of work (>average range/charge) be broken up into shorter blocks, which would increase the number of buses required during peak service. Some have posited that for buses that do two blocks per day you could extend their range by charging between blocks. The analysis indicates that for most buses that do two blocks, the “lay-over time” at the depot between blocks is only 2.5 – 3.5 hours. Not a long time – to extend range effectively one would need to have very high power chargers (which would increase cost, both for the charger and for the electricity). Also, the buses that do the longest daily mileage are not buses that do two blocks per day – they are in fact the buses that do only one block, but which stay out all day. For electric buses with a 350 kWh energy storage system, BBB would need to 5% – 15% more daily peak buses to operate the same service as the existing CNG buses, depending on whether battery packs are replaced as part of the bus’s midlife overhaul (6-year battery life) or whether the buses are operated for their full 12-year useful life with a single battery pack. Item 4-A 4/24/18 30 of 80 Item 4-A 4/24/18 Figure 9: Estimated “replacement ratio” for BEBs equipped with a ~350 kWh battery pack For electric buses with ~450 kWh battery packs BBB would need to 0.5% – 2% more daily peak buses to operate the same service as BBB’s existing CNG buses, depending on whether battery packs are replaced as part of the bus’s midlife overhaul. This equates to approximately 201 to 204 total buses compared to BBB’s current fleet of 200. Figure 10: Estimated “replacement ratio” for BEBs equipped with a ~450 kWh battery pack Item 4-A 4/24/18 31 of 80 Item 4-A 4/24/18 Electricity Consumption – Expected energy use (kWh/mi) in BBB service for available electric bus models Figure 11 displays the number of buses at the depot for each hour of the day based on the scheduled service blocks/assignments. This is a critical input to the charging analysis, as it will be used to calculate average load (kW) and average energy (kWh) by time of day for electric bus charging. Figure 11: Distribution of buses at the depot during weekday service Using the number of buses that return to the depot each hour and start to charge, and the charge rate (kW) for each bus, the total expected charge load (kW) for a full electric fleet was calculated for every hour of the day across a typical weekday. The minimum charge rate required is 30 kW based on available depot charge time (8 – 10 hours per bus). Increasing the charge rate to 50 kW will decrease charge time (to 5 – 6 hours per bus) and potentially increase operational flexibility, but it will also increase the average electricity cost due to increased demand charges. Mid-day charging (after morning peak buses return but before they go out again for afternoon peak) will also increase average electricity cost. Figure 12 displays the projected total weekday charging loads using both 30 kW and 50 kW depot chargers. Item 4-A 4/24/18 32 of 80 Item 4-A 4/24/18 Figure 12: Projected total weekday charging loads using 30 kW and 50 kW depot chargers Southern California Edison (SCE) has three available rate structures: TOU-8, TOU-EV-6, and TOU-8 Real-time pricing. These rates vary in terms of delivery charges ($/kWh), energy (generation) charges ($/kWh), and both facility and generation demand charges ($/kWh/month). TOU-8 and TOU-EV-6 can be combined with zero carbon electricity purchased through a third- party ESP (E3), as is BBB’s current practice, while TOU-8 real-time pricing cannot. Fig ure 13 and Figure 14 display the estimated average electricity costs for BBB bus charging using each of the available rate structures, across a range of charging rates. These projected average costs are based on the details of each rate structure and the projected weekday charging load shown above. Based on the analysis, the TOU-EV-6 rate structure is more economical than the TOU-8 rate structure, whether or not BBB continues to purchase 100% renewable electricity. The real- time pricing rate structure could result in lower average costs than TOU-EV-6, especially at low charge rates, but it entails additional risk such as higher costs on very hot summer days. In addition, this rate cannot be used in conjunction with the purchase of zero carbon electricity via a third-party ESP. Item 4-A 4/24/18 33 of 80 Item 4-A 4/24/18 Figure 13: Estimated average electricity cost assuming all charging occurs at night Figure 14: Estimated electricity costs assuming charging occurs at night and during the day when buses are not required for service LCFS Credit Trading Analysis Transit agencies operating in California can also generate low carbon fuel standard (LCFS) credits for deploying battery electric transit buses. The value of these credits can be realized by monetizing them in the marketplace. The proceeds from the sale of the credits can be used to offset the electricity costs incurred from charging the BEBs. Figure 15 displays that market value for LCFS credits in 2017 ranged from $80-$100 per metric ton ($/MT). Item 4-A 4/24/18 34 of 80 Item 4-A 4/24/18 Figure 15: 2017 average LCFS credit trading price At current market values, BBB’s BEBs will earn $0.08-$0.10/kWh which will offset the electricity costs calculated above. Figure 16: LCFS credit value for the 2017 range of LCFS credit trading prices Item 4-A 4/24/18 35 of 80 Item 4-A 4/24/18 Table 17: Projected LCFS credit values for battery electric transit buses 4.3.2. BATTERY ELECTRIC TRANSIT BUS COST ANALYSIS Using the results of the BEB technology and operational assessment, operational and lifecycle costs could be calculated. Similar to the analysis performed on BBB’s existing buses, the cost of battery electric transit bus technology is an aggregate of the individual cost factors that include: bus capital, fuel, operations and maintenance (O&M), midlife overhaul, charging infrastructure, and facility modification costs. Detailed explanations of the cost assumptions used are included in APPENDIX B – Transit Bus Costs and Assumptions and APPENDIX C – Fuel and Fuelling Infrastructure Cost Assumptions. Capital Costs BBB’s fleet consists of several bus makes, models, and model years. In order to evaluate operational and lifecycle costs, assumptions were made about the typical bus platform and corresponding capital costs in order to come up with a composite that best represented vehicles that comprise BBB’s existing fleet. The capital cost for a BEB was derived by comparing recent bid specifications submitted by BEB OEMs to local transit agencies to the specifications developed for BBB’s most recent bus procurement. The comparison identified equipment items that would need to be added to the BEB specification in order to have a comparably equipped BEB. Table 18 contains the capital cost for a comparably equipped battery electric assumed in the analysis. Capital Cost Battery Electric Transit Bus Incremental Cost Relative to Baseline 2017 40-foot Low Floor Bus with ~450 kWh Battery Pack $926,996/bus ↑ $321,660 Table 18: Battery electric transit bus capital costs Item 4-A 4/24/18 36 of 80 Item 4-A 4/24/18 As battery costs decline in the coming years, the capital cost for a battery electric transit bus will also decline. For BBB’s initial purchases, capital costs are based on a battery cost of $575/kWh. These costs are projected to decline to $405/kWh in 2020, $310/kWh in 2025, and to $218/kWh in 2030. Using these projected cost reductions, the capital cost of a 40-foot BEB equipped with a ~450 kWh battery pack is projected to be approximately $750,682 in 2030. Fuel Costs In order to compare fuel costs for a BEB to the fuel cost of BBB’s existing transit bus, an estimate for the cost of electricity was developed using the operational and performance characteristics described in Section 4.3.1. For battery electric transit buses, fuel costs are the net cost of electricity procured from Southern California Edison, costs incurred to maintain the charging infrastructure, and revenue generated from the sale of LCFS credits. The analysis assumes the BBB will continue purchasing 100% renewable carbon electricity under SCE’s TOU-EV-6 rate structure and that BBB will charge their BEBs at night and during the day when not required for service. Further, the analysis assumes that BBB will use 50 kW depot chargers. Table 19 contains a breakdown of the cost of electricity. Electricity Costs Under SCE’s TOU-EV-6 Using 50 kW Depot Chargers TOU-EV-6+E3 $0.173/kWh Depot Charger O&M $0.0063/kWh LCFS Credit Assuming Credit Value of $90/MT ($0.090/kWh) Net Electricity Cost $0.0893/kWh Table 19: Electricity costs for 50 kW depot chargers under SCE’s TOU-EV-6 rate structure Operations and Maintenance Costs Battery electric transit bus O&M costs were determined from service records for the maintenance and repairs performed on BBB’s existing fleet and assumptions regarding costs savings associated with battery electric powertrains. As performed in the preceding analyses, O&M costs are derived from service records provided by BBB which consisted of consisted of O&M costs classified in four different categories: engine, transmission, brake, and other. The data allows for costs to be classified as propulsion or non-propulsion costs. Engine and transmission maintenance and repairs were classified as propulsion related O&M costs. Brake and other maintenance and repairs were classified as non-propulsion related O&M costs. Because the average age of BBB’s fleet is slightly over six years, the entire dataset provided by BBB was used to determine average O&M costs. It is assumed that battery electric transit buses will reduce propulsion related (engine and transmission) O&M costs by 50% due to significantly reduced complexity of the powertrain. The analysis also assumes that brake-related O&M costs (a component of non-propulsion related O&M costs) will reduce brake-related O&M costs by 50% due to reduced brake wear associated with regenerative braking systems.2 Table 20 contains the O&M costs for battery electric transit buses operating in BBB’s fleet. 2 Literature Review on Transit Bus Maintenance Cost (Discussion Draft), August 2016, Advanced Clean Transit Program, California Air Resources Board Item 4-A 4/24/18 37 of 80 Item 4-A 4/24/18 O&M Costs* Battery Electric Transit Bus Incremental Cost Relative to Baseline Propulsion Related $ 0.098/mi ↓ $ 0.098/mi Engine O&M $ 0.085/mi ↓ $ 0.085/mi Transmission O&M $ 0.013/mi ↓ $ 0.013/mi Non Propulsion Related $ 0.596/mi ↓ $ 0.024/mi Brake O&M $ 0.024/mi ↓ $ 0.024/mi Other O&M $ 0.572/mi $ 0.000/mi Total O&M $ 0.694/mi ↓ $ 0.122/mi * Derived from BBB’s existing buses, excluding model year 2017 buses Table 20: Battery electric transit bus O&M costs Bus O&M costs were evaluated in such detail because certain components are more likely to vary from technology to technology while others can be assumed to be relatively unaffected across the range of powertrain technologies. For example, propulsion related O&M costs are likely to differ between BBBs existing fleet and advanced technologies such as BEBs. Except for brake- related maintenance costs, non-propulsion related maintenance costs, such as preventative maintenance inspections and other maintenance cost components, are not expected to vary from technology to technology. Midlife Overhaul Costs Midlife overhaul costs were determined from fleet maintenance records, BBB’s experience, and assumptions to account for the replacement of specific items unique to battery electric transit buses. Historically, midlife overhauls have been performed on an as-needed basis due to major component failures. However, BBB plans to standardize the timing of midlife overhauls so that they are routinely performed in the middle of the useful life of each bus. A midlife overhaul performed on BBB’s existing buses consists of rebuilding the existing engine, transmission, and brake system. Other aspects of the bus, such as driver area, seating upholstery, paint, etc., are also reconditioned as part of the midlife overhaul. However, the costs associated with performing these reconditioning activities are likely to remain relatively consistent across bus platforms regardless of the powertrain configuration. Unlike these typical reconditioning activities, the midlife costs associated with the powertrain may vary significantly across alternative powertrain configurations. Since the ultimate objective of the analysis is to compare the existing fleet to other propulsion systems, only costs specifically related to the propulsion system are included as part of the midlife overhaul costs. For battery electric transit buses, a midlife overhaul entails replacing or overhauling the drive motor, inverter, and energy storage system. Warranty coverages and terms vary from manufacturer to manufacturer. For example, BYD offers a 12-year battery performance warranty which would eliminate costs associated with replacing the battery as part of the midlife overhaul while New Flyer and Proterra only provide a 6-year warranty. Since the objective of the analysis is to estimate total lifecycle costs for a battery electric transit bus, a conservative approach was taken which also accounts for midlife overhaul costs associated with the energy storage system. The analysis assumes that Item 4-A 4/24/18 38 of 80 Item 4-A 4/24/18 the battery pack on each bus will require replacement at some point between year 6 and year 12. The specific time at which the replacement occurs will likely fluctuate from bus-to-bus based on individual cycle life and exposure to varying degrees of vibration. For example, a bus equipped with a 450 kWh battery pack that enters service in 2018 will likely require the battery pack to be replaced at some point between 2024 and 2030. As a result of projected reductions in battery costs, the replacement battery pack purchased in 2024 will be less expensive than the originally equipped battery pack. Table 21 contains the midlife overhaul cost assumptions for battery electric transit buses placed into service in 2018 and overhauled in 2024 based on a projected battery cost of $405/kWh. Midlife Overhaul Costs 2017 Battery Electric Transit Bus Incremental Cost Relative to Baseline Drive Motor and Inverter Overhaul $ 30,000/bus N/A 450 kWh Battery System Overhaul $ 182,250/bus N/A Total Midlife Overhaul Cost $ 212,250/bus ↑ $212,250/bus Table 21: Battery electric bus midlife overhaul costs Midlife overhaul costs for a ~450 kWh BEB are projected to decline to $169,500 by 2025 and to $128,100 by 2030 as a result of battery costs declining from $405/kWh in 2020 to $310/kWh in 2025, and to $218/kWh in 2030. The analysis assumes battery costs to remain constant 2030 and beyond. Fuelling Infrastructure and Facility Modification Costs Transit agencies deploying a new technology are often faced with installing fuelling infrastructure, such as dispensers, chargers, fuelling islands/stations, etc. In addition, it is common that modifications to the existing facility be performed in order to comply with safety requirements specific to the fuel. Deploying battery electric transit buses in BBB’s fleet would require the replacement of the existing fuelling infrastructure that currently meets the needs of BBB’s existing natural gas transit fleet. Estimating the cost of charging infrastructure presents significant uncertainties due to the limited number of large charging infrastructure buildouts combined with the physical constraints of BBB’s facility. Because the majority of charging will occur overnight when BBB’s entire fleet is parked at the facility, the analysis assumes a depot charger will be required for each BEB. To assess the costs associated with the charging infrastructure, BBB’s facility was evaluated to better understand the implications that the physical constraints would have on two variants of depot chargers. BYD BEBs come equipped with an on-board charger, therefor only a charging post containing the power adapter must be integrated into facility. BYD charging posts and power adapters have a footprint of approximately 2 feet by 2 feet. For other OEMS, such as New Flyer, BEBs do not come equipped with an on-board charger and therefor a charging unit and charging post containing the power adapter must be integrated into the facility. New Flyer has partnered with Siemens to provide depot chargers and charging posts for their BEBs. This type of system has a footprint of approximately 3.5 feet by 3.5 feet. In addition to the charger and charging post, Item 4-A 4/24/18 39 of 80 Item 4-A 4/24/18 12 inch diameter concrete-filled bollards must be installed on each side in order to protect against potential damage. The assessment of BBB’s facility revealed several challenges with installing charging infrastructure to service BBB’s fleet transitioned to BEBs. It is assumed that the transitioned fleet will continue parking as currently organized and that travel lanes and directions within the facility will be maintained. The existing parking lanes are approximately 12 feet wide which accommodate transit buses that are approximately 8.5 feet wide with a mirror-to-mirror width of approximately 11 feet. For ground-mounted chargers installations, chargers and charging posts are most commonly installed between the parking lanes in order to minimize the amount of intrusion into each lane. Depending on the type of depot charger employed, the charging infrastructure would protrude 2-3 feet into each parking lane, when accounting for both the charging units and the concrete-filled bollards. The location of the charging port on the transit bus further complicates this type of installation. For one of the parking lanes, the power adapter would be adjacent to the bus’s charging port while for the other parking lane, the power adapter would have to extend over the roof of the bus to reach the bus’s charging port. Charging infrastructure manufactures recommend that overhead canopies be installed to protect against rain. While this type of canopy can be designed such that it is equipped with a cable guide that enables the power adapter to reach the charging ports, it is ultimately the distance that the chargers and charging posts protrude in each parking lane that prevents a ground-mounted installation from being a viable option. An alternative to ground-mounted installation is the placement of the charging equipment on overhead structures. The overhead structures could be designed such that they span multiple parking lanes in order to limit the amount that the structure’s foundations protrude into the parking lanes. The installation of chargers on overhead structures will minimize the amount of underground improvements needed for power and control conduits and wiring. Power adapters would be suspended from the overhead structure in order to provide additional protection against damage and to eliminate potential trip hazards. Installation of the charging equipment on overhead structures appears to be the only viable option due to the physical constraints of BBB’s facility. Figure 17 displays a rendering of charging equipment installed on overhead structures. Figure 17: Renderings of depot chargers installed on overhead structures Table 22 contains the charging infrastructure costs for the initial fleet of battery electric transit buses operating within BBB’s fleet. Charger installation costs include engineering, design, Item 4-A 4/24/18 40 of 80 Item 4-A 4/24/18 permitting, construction and installation of wiring and conduit, upgrade of the depot power panel, transformers, and a backup generator to provide power in the event of a power outage. Charging Infrastructure Costs Battery Electric Bus Incremental Cost Relative to Baseline Charger Installation $ 46,000/bus N/A Depot Charger $ 50,000/bus N/A Overhead Structure $ 7,000/bus N/A Total Infrastructure Costs $ 103,000/bus ↑ $103,000/bus Table 22: Battery electric bus charging infrastructure costs The analysis assumes the useful life of a depot charger to be 12 years and the useful life of the charger installation and overhead structure to be 24 years. Therefore, once the fleet has been fully transitioned to BEBs, only the costs of depot charger will be incurred with subsequent BEB purchases. Operational and Total Lifecycle Costs To determine operational and lifecycle costs, assumptions about average fuel economy, annual mileage, and useful life were required. As described in Section 4.1, average fuel economy for BBB’s existing fleet was calculated using fleet data provided by BBB. Using this information, the fuel economy for battery electric transit buses was calculated based on the anticipated energy consumption of BEB models relative to the fuel economy of BBB’s existing transit buses. The result was the estimated energy consumption for BEBs that reflected BBB’s in-service operations. The analysis assumes that average annual mileage and the intended and desired useful life would be unaffected by technology type. Table 23 provides a summary of the assumptions used for determining operational and total lifecycle costs. Battery Electric Transit Bus Fleet Average Annual Mileage Average Fuel Economy (mi/DGE) Intended Useful Life 32,250 mi/year 15.25 mi/DGE (.408 mi/kWh) 12 years Table 23: Battery electric bus fuel economy, annual mileage, and useful life Using the cost factors and assumptions described above, operational and total lifecycle costs were calculated for a battery electric transit bus placed into BBB’s operations. Table 24 displays per mile, annual, and total lifecycle costs of a battery electric transit bus operating within BBB’s fleet. Operational and Lifecycle Costs 2017 Battery Electric Transit Bus Incremental Cost Relative to Baseline Item 4-A 4/24/18 41 of 80 Item 4-A 4/24/18 Bus Capital Cost $ 2.395/mi ↑ $ 0.831/mi Fuel Cost $ 0.219/mi ↓ $ 0.120/mi Bus O&M $ 0.694/mi ↓ $ 0.122/mi Midlife Overhaul Cost $ 0.548/mi ↑ $ 0.478/mi Infrastructure Cost $ 0.198/mi ↑ $ 0.198/mi Total Operational Cost $ 4.054/mi ↑ $ 1.265/mi Total 12-Year Lifecycle Cost $ 1,568,898/bus ↑ $ 489,555/bus Table 24: 2017 BEB operational and lifecycle costs For a BEB that enters service in 2018, BBB would incur an operational cost of $4.054/mile which is an increase of approximately $1.265/mile over BBB’s existing transit bus. Over a buses 12-year lifecycle, the higher operational cost of a battery electric transit bus translates to an increase of approximately $489,555/bus. Table 25 displays a similar comparison for a battery electric transit bus purchased in 2030. The costs below take into account reductions in projected battery costs from $575/kWh in 2017 to $218/kWh in 2030. As battery costs decline over time, they will result in reduced capital costs and midlife overhaul costs. Despite these reductions, a BEB purchased in 2030 increases BBB’s operational cost $0.593/mi which translates to an increase of approximately $229,491 over a buses 12-year lifecycle. Operational and Lifecycle Costs 2030 Battery Electric Transit Bus Incremental Cost Relative to Baseline Bus Capital Cost $ 1.940/mi ↑ $ 0.376/mi Fuel Cost $ 0.219/mi ↓ $ 0.120/mi Bus O&M $ 0.694/mi ↓ $ 0.122/mi Midlife Overhaul Cost $ 0.331/mi ↑ $ 0.261/mi Infrastructure Cost $ 0.198/mi ↑ $ 0.198/mi Total Operational Cost $ 3.382/mi ↑ $ 0.593/mi Total 12-Year Lifecycle Cost $ 1,308,834/bus ↑ $ 229,491/bus Table 25: 2030 BEB operational and lifecycle costs 4.4. SUMMARY OF TRANSIT BUS COST ANALYSIS A comparison of the three technologies reveals that battery electric transit buses placed into BBB’s operations will result in significantly higher operational and total lifecycle costs. The reason for this is due to the higher capital and infrastructure costs outweighing the benefits of that result from the increased efficiency and lower O&M costs of battery electric transit buses. Figure 18 and Figure 19 compare the operational and lifecycle costs for each of the three technologies if they were to enter service in 2018. Item 4-A 4/24/18 42 of 80 Item 4-A 4/24/18 Figure 18: 2017 BBB transit bus technology operational costs Figure 19: BBB transit bus technology lifecycle costs Because technologies evolve over time, it is important to understand the impact that these changes have on costs. Given the mature nature of BBB’s existing transit buses, only minor improvements in the technology are anticipated in the coming years and costs are anticipated to remain constant. Similarly, because NZE natural gas transit buses are an incremental improvement over BBB’s existing transit buses, significant reductions in operational costs are not anticipated. Some within the industry have speculated that there may be reductions in the incremental capital cost of NZE transit buses. However, such reductions in capital cost are not likely to have a significant impact on operational and total lifecycle costs. For example, a 50% reduction in the incremental cost of a NZE transit bus would result in an operational cost reduction of $0.011/mile. For newer technologies such as BEBs, more significant cost reductions are anticipated overtime. Figure 20 and Figure 21 display the impact that reduced battery costs will have on the operational and total lifecycle cost of a battery electric transit bus. Despite such cost reductions, battery electric transit buses placed in BBB’s operations will continue to carry a significant cost premium over both BBB’s existing buses as well as NZE natural gas transit buses. Item 4-A 4/24/18 43 of 80 Item 4-A 4/24/18 Figure 20: Projected BBB transit bus technology operational costs Figure 21: Projected BBB transit bus technology lifecycle costs Item 4-A 4/24/18 44 of 80 Item 4-A 4/24/18 5. TRANSIT BUS EMISSIONS ANALYSIS In addition to calculating the costs associated with each of the transit bus technologies, analysing the emissions that result from the deployment of each technology is of equal importance. The following section analyses and compares the well-to-wheel (WTW ) and tank-to-tank (TTW ) emissions associated with each of the three technologies. The emissions evaluated as part of the analysis include greenhouse gases (GHGs), oxides of nitrogen (NOx), and particulate matter (PM10). The results of the analysis provide a metric for each pollutant on a per-mile and total lifecycle basis. 5.1. EXISTING TRANSIT BUS EMISSIONS ANALYSIS The emissions of BBB’s existing transit fleet was analysed in order to come up with a baseline emissions profile that could be compared to that of NZE natural gas transit buses and battery electric transit buses. The emissions analysis assumes that BBB’s existing fleet will continue to be fuelled with RLNG currently supplied by Clean Energy. It is also assumed that fuel economy of BBB’s existing fleet will remain constant throughout the evaluation timeframe. Detailed explanations of the emissions assumptions used are included in APPENDIX D – Fuel Properties and Emissions Factors. Well-to-Wheel Greenhouse Gas Emissions Well-to-wheel GHG emissions were determined using the carbon intensity of the RLNG and the fleet’s average fuel economy. The RLNG that fuels BBB’s existing transit bus fleet is Clean Energy’s Redeem brand of renewable natural gas. Redeem renewable natural gas is derived from biogenic methane that is naturally generated by the decomposition of organic waste at landfills and other organic waste streams. The renewable natural gas that supplies the Redeem brand comes from a variety of sources that include Clean Energy owned and operated biomethane production facilities as well as from third party producers. Because there are a variety of sources, the carbon intensity (CI) for Redeem fuel was determined by taking an average CI for all of Clean Energy's approved LCNG pathways. This included all pathways for which landfill gas was converted to pipeline-quality biomethane, delivered to California via pipeline, liquefied at Clean Energy's Boron, CA plant, and delivered to a site within California where it is pumped to high pressure and then re-gasified to produce LCNG for use as a transportation fuel. Table 26 displays the WTW GHG emissions for BBB’s existing transit buses. WTW GHG Emissions BBB Existing Transit Bus WTW CO2e Emissions 1,474.5 g/mi Annual WTW CO2e Emissions 47.6 MT/yr Lifecycle WTW CO2e Emissions 571.2 MT/12-yrs Table 26: Well-to-wheel greenhouse gas emissions for BBB’s existing transit buses Item 4-A 4/24/18 45 of 80 Item 4-A 4/24/18 Well-to-Wheel and Tank-to-Wheel NOx Emissions To determine WTW NOx emissions, the analysis evaluated well-to-tank (WTT) and TTW (tailpipe) emissions separately. While ARB’s regulations target TTW emissions, it is important to evaluate the WTT (upstream) emissions for a complete understanding of total NOx emissions. For WTT NOx emissions, which include the “feedstock” and the “fuel”, CA-GREET reported an estimate of 130.07 grams per MMBtu (g/MMBtu). The estimate was derived by adjusting specific factors within California-modified Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (CA-GREET) model to best reflect an LFG to L-CNG pathway for RLNG produced in Southern California. It should be noted that the majority of these upstream emission are likely to occur outside of California because most of the renewable natural gas consumed in California originates from sources outside of the state. For BBB’s existing fleet, WTT NOx emissions were calculated to be 4.63 g/mi. Tank-to-wheel NOx emissions were calculated from the ARB certified engine emissions values (g/bhp-hr) and fuel use (DGE/mi). For the analysis of BBB’s existing fleet, certified engine emissions values were derived from ARB Executive Order (EO) A-021-0662 for model year 2017 Cummins ISL G 8.9 liter natural gas engine certified for urban bus applications. TTW NOx emissions for BBB’s existing transit bus were calculated to be 0.581 g/mi. Table 27 displays the WTW NOx emissions for BBB’s existing transit buses. WTW NOx Emissions – BBB Existing Transit Bus NOx Emissions Annual NOx Emissions Lifecycle NOx Emissions WTT NOx 4.530 g/mi 0.161 tons/yr 1.932 tons/12-yrs TTW NOx Emissions 0.581 g/mi 0.0207 tons/yr 0.248 tons/12-yrs WTW NOx Emissions 5.111 g/mi 0.1817 tons/yr 2.180 tons/12-yrs Table 27: Well-to-wheel NOx emission for BBB’s existing transit bus Well-to-Wheel and Tank-to-Wheel Particulate Matter Emissions To determine WTW PM10 emissions, the analysis evaluated WTT and TTW (tailpipe) emissions separately. For WTT PM10 emissions, which include the “feedstock” and the “fuel”, CA-GREET reported an estimate of -2.82 g/MMBtu based on the same factors described above that best reflect an LFG to L-CNG pathway for LNG produced in Southern California. CA-GREET reports negative PM10 emissions for the LFG to L-CNG pathway because LFG released from landfills is typically flared onsite. By capturing the LFG and using it as a transportation fuel, the emissions that would otherwise result from flaring are avoided. For BBB’s fleet, WTT PM10 emissions were calculated to be -0.0982 g/mi. Consistent with the method used for calculating TTW NOx emissions, TTW PM10 emissions were derived from the certified engine emissions values of the 2017 Cummins ISL G natural gas engine. Tank-to-wheel PM10 emissions for BBB’s existing transit bus was calculated to be 0.0091 g/mi. Table 28 displays the WTW PM10 emissions for BBB’s existing transit buses. Item 4-A 4/24/18 46 of 80 Item 4-A 4/24/18 WTW PM10 Emissions – BBB Existing Transit Bus PM10 Emissions Annual PM10 Emissions Lifecycle PM10 Emissions WTT PM10 -0.0982 g/mi -0.0035 tons/yr -0.042 tons/12-yrs TTW PM10 Emissions 0.0091 g/mi 0.00032 tons/yr 0.0038 tons/12-yrs WTW PM10 Emissions -0.0891 g/mi -0.0032 tons/yr -0.0382 tons/12-yrs Table 28: Well-to-wheel PM10 emission for BBB’s existing transit bus 5.2. NEAR -ZERO NOX EMISSION NATURAL GAS TRANSIT BUS EMISSIONS ANALYSIS The emissions of NZE natural gas transit bus technology was analysed in order to develop an emissions profile that could be compared to that of BBB’s existing transit buses described in Section 5.1. The results of the analysis provide a metric for each pollutant on a per-mile and total lifecycle basis for NZE natural gas transit buses. The emissions analysis assumes that the NZE natural gas transit bus will be fuelled with the RLNG that is currently supplied by Clean Energy. It is also assumed that fuel economy of BBB’s transitioned fleet will remain constant throughout the evaluation timeframe. Detailed explanations of the emissions assumptions used are included in APPENDIX D – Fuel Properties and Emissions Factors. Well-to-Wheel Greenhouse Gas Emissions Well-to-wheel GHG emissions were determined using the carbon intensity of the RLNG that fuels BBB’s existing transit buses and the estimated fuel economy of NZE natural gas transit buses which was derived from the average fuel economy of BBB’s existing transit buses. Table 29 displays the WTW GHG emissions for near-zero NOx natural gas transit buses operating within BBB’s fleet. WTW GHG Emissions Near-Zero NOx Natural Gas Transit Bus BBB’s Existing Transit Bus WTW CO2e Emissions 1,212.6 g/mi 1,474.5 g/mi Annual WTW CO2e Emissions 39.1 MT/yr 47.6 MT/yr Lifecycle WTW CO2e Emissions 469.2 MT/12-yrs 571.2 MT/12-yrs Table 29: Well-to-wheel greenhouse gas emission of a near-zero emission NOx natural gas transit bus Well-to-Wheel and Tank-to-Wheel NOx Emissions Similar to the NOx emissions analysis performed for BBB’s existing transit bus, the analysis evaluated WTT and TTW (tailpipe) emissions separately in order to provide a complete understanding of total NOx emissions. Because NZE natural gas transit buses are fuelled using the same RLNG that current fuels BBB’s existing transit buses, the same emission factor is used for calculating WTT NOx emissions. Using the estimate of 130.07 g/MMBtu derived in the previous section, WTT NOx emissions for BBB’s near-zero NOx natural gas bus was calculated to be 4.55 g/mi. Item 4-A 4/24/18 47 of 80 Item 4-A 4/24/18 Tank-to-wheel NOx emissions were calculated from the ARB certified engine emissions values (g/bhp-hr) and fuel use (DGE/mi). For the analysis of NZE natural gas transit buses operating within BBB’s fleet, certified engine emissions values were derived from ARB Executive Order (EO) A-021-0659 for model year 2017 Cummins ISL G Near Zero 8.9 liter natural gas engine certified for urban bus applications. TTW NOx emissions for BBB’s NZE natural gas transit bus were calculated to be 0.045 g/mi. Table 30 displays the WTW NOx emissions for BBB’s NZE natural gas transit buses. WTW NOx Emissions – Near-Zero NOx Emission Natural Gas Transit Bus NOx Emissions Annual NOx Emissions Lifecycle NOx Emissions WTT NOx 4.55 g/mi 0.162 tons/yr 1.944 tons/12-yrs TTW NOx Emissions 0.045 g/mi 0.0016 tons/yr 0.0192 tons/12-yrs WTW NOx Emissions 4.595 g/mi 0.1636 tons/yr 1.963 tons/12-yrs Table 30: Well-to-wheel NOx emissions for a NZE natural gas transit bus Well-to-Wheel and Tank-to-Wheel Particulate Matter Emissions Similar to the PM10 emissions analysis performed for BBB’s existing transit bus, the analysis evaluated WTT and TTW (tailpipe) emissions separately in order to provide a complete understanding of total PM10 emissions. Because NZE natural gas transit buses are fuelled using the same RLNG that current fuels BBB’s existing transit buses, the same emission factor is used for calculating WTT PM10 emissions. Using the estimate of -2.82 g/MMBtu derived in the previous section, WTT PM10 emissions for BBB’s near-zero NOx natural gas bus was calculated to be -0.0986 g/mi. Consistent with the method used for calculating TTW NOx emissions, TTW PM10 emissions were derived from the certified PM10 emissions values of the 2017 Cummins ISL G NZ natural gas engine. Tank-to-wheel PM10 emissions for near-zero NOx natural gas transit buses operating within BBB’s fleet were calculated to be 0.0091 g/mi. Table 31 displays the WTW PM10 emissions for a NZE natural gas transit bus operating within BBB’s fleet. WTW PM10 Emissions – Near-Zero NOx Emission Natural Gas Transit Bus PM10 Emissions Annual PM10 Emissions Lifecycle PM10 Emissions WTT PM10 -0.0986 g/mi -0.0035 tons/yr -0.042 tons/12-yrs TTW PM10 Emissions 0.0091 g/mi 0.00032 tons/yr 0.0038 tons/12-yrs WTW PM10 Emissions -0.0895 g/mi -0.0032 tons/yr -0.0383 tons/12-yrs Table 31: Well-to-wheel PM10 emission for a NZE natural gas transit bus Item 4-A 4/24/18 48 of 80 Item 4-A 4/24/18 5.3. BATTERY ELECTRIC TRANSIT BUS EMISSIONS ANALYSIS The emissions of zero-tailpipe emission battery electric transit bus technology was analysed in order to develop an emissions profile that could be compared to that of BBB’s existing transit bus and to that of a NZE natural gas transit bus. The emissions evaluated as part of the analysis include greenhouse gases, oxides of nitrogen, and particulate matter. The results of the analysis provide a metric for each pollutant on a per-mile and total lifecycle basis for battery electric transit buses. The emissions analysis assumes that the battery electric transit buses will be charged with the electricity mix that is currently being supplied to BBB by Southern California Edison and 3 Phases Renewables. It is also assumed that fuel economy of BBB’s transitioned fleet will remain constant throughout the evaluation timeframe. Detailed explanations of the emissions assumptions used are included in APPENDIX D – Fuel Properties and Emissions Factors. Well-to-Wheel Greenhouse Gas Emissions Well-to-wheel GHG emissions were determined using the carbon intensity of the renewable electricity provided by 3 Phases Renewables and the estimated average fuel economy of battery electric transit buses placed into BBB’s service operations. Table 32 displays the WTW GHG emissions for battery electric transit buses operating within BBB’s fleet. WTW GHG Emissions Battery Electric Transit Bus BBB’s Existing Transit Bus WTW CO2e Emissions 8.88 g/mi 1,474.5 g/mi Annual WTW CO2e Emissions 0.286 MT/yr 47.6 MT/yr Lifecycle WTW CO2e Emissions 3.43 MT/12-yrs 571.2 MT/12-yrs Table 32: Well-to-wheel greenhouse gas emission of a battery electric transit bus Well-to-Wheel and Tank-to-Wheel NOx Emissions Similar to the NOx emissions analysis performed in the preceding sections, the analysis evaluated WTT and TTW (tailpipe) emissions separately in order to provide a complete understanding of total NOx emissions. For WTT NOx emissions, which include the “feedstock” and the “fuel”, CA-GREET reported an estimate of 0.00740 grams per mega joule (g/MJ). The estimate was derived by adjusting specific factors within CA-GREET to best reflect the 100% renewable electricity that BBB procures from 3 Phases Renewables. It should be noted that these upstream emissions are likely to occur within California because the renewable electricity is sourced inside California. For BBB’s battery electric transit buses, WTT NOx emissions were calculated to be 0.0653 g/mi. There are no TTW NOx emissions from battery electric transit buses. Table 33 displays the WTW NOx emissions for a battery electric transit bus placed in BBB’s service operations. WTW NOx Emissions – Battery Electric Transit Bus Item 4-A 4/24/18 49 of 80 Item 4-A 4/24/18 NOx Emissions Annual NOx Emissions Lifecycle NOx Emissions WTT NOx 0.0653 g/mi 0.00232 tons/yr 0.0278 tons/12-yrs TTW NOx Emissions 0.000 g/mi 0.000 tons/yr 0.000 tons/12-yrs WTW NOx Emissions 0.0653 g/mi 0.00232 tons/yr 0.0278 tons/12-yrs Table 33: Well-to-wheel NOx emission for a battery electric transit bus Well-to-Wheel and Tank-to-Wheel Particulate Matter Emissions To determine WTW PM10 emissions, the analysis evaluated WTT and TTW (tailpipe) emissions separately. For WTT PM10 emissions, which include the “feedstock” and the “fuel”, CA-GREET reported an estimate of 0.00242 g/MJ based on the same factors described above that best reflect the 100% renewable electricity that BBB procures from 3 Phases Renewables. For BBB’s battery electric transit buses, WTT PM10 emissions were calculated to be 0.0213 g/mi. There are no TTW PM10 emissions from battery electric transit buses. Table 34 displays the WTW PM10 emissions for a battery electric transit buses placed in BBB’s operations. WTW PM10 Emissions – Battery Electric Transit Bus PM10 Emissions Annual PM10 Emissions Lifecycle PM10 Emissions WTT PM10 0.0213 g/mi 0.00076 tons/yr 0.00912 tons/12-yrs TTW PM10 Emissions 0.00 g/mi 0.00 tons/yr 0.00 tons/12-yrs WTW PM10 Emissions 0.0213 g/mi 0.00076 tons/yr 0.00912 tons/12-yrs Table 34: Well-to-wheel PM10 emissions for a battery electric transit bus 5.4. SUMMARY OF EMISSIONS ANALYSIS The following section compares the emissions profiles of each of the technologies. Figure 22 displays the WTW GHG emissions for each technology on a grams per mile basis. Battery electric transit buses fuelled with renewable electricity have a very low WTW GHG emissions profile that is over 99% lower than BBB’s existing transit buses. Item 4-A 4/24/18 50 of 80 Item 4-A 4/24/18 Figure 22: Well-to-wheel greenhouse gas emissions profile for each of the three technologies As described in the preceding sections, BBB currently procures zero carbon electricity. In the event that BBB ceases procuring zero carbon electricity, Figure 23 displays the WTW GHG emissions for each of the three technologies with battery electric transit buses fuelled with California’s average grid electricity mix.3 Figure 23: Well-to-wheel greenhouse gas emissions profile for each of the three technologies Figure 24 displays the WTW NOx emissions profile for each of the technologies. Despite NZE natural gas transit buses providing a 90% reduction of TTW NOx emissions, they only provide a 3 Well-to-wheel GHG emissions for battery electric transit buses analyzed using CA-GREET’s carbon intensity value of 105.16 gCO2e/MJ for California’s average grid electricity mix Item 4-A 4/24/18 51 of 80 Item 4-A 4/24/18 NOx reduction of approximately 10% on a WTW basis. In contrast, battery electric transit buses operating in BBB’s fleet area capable of reducing WTW NOx by nearly 99% compared to BBB’s existing transit buses. Figure 24: Well-to-wheel NOx emissions profile for each of the three technologies Figure 25 displays the WTW PM10 emissions profile for each of the technologies. As shown, BBB’s existing transit buses and NZE natural gas transit buses have the same PM10 emissions profile because the certified emissions value of the Cummins ISL G NZ is the same as the Cummins ISL G that is equipped in BBB’s existing transit buses and both technologies are fuelled by the same RLNG. While battery electric transit buses do not have TTW PM10 emissions they have a higher WTW PM10 emissions profile because of the WTT PM10 emissions. Figure 25: Well-to-wheel PM10 emission profiles for each of the three technologies Item 4-A 4/24/18 52 of 80 Item 4-A 4/24/18 6. BBB FLEET TRANSITION ANALYSIS – 2018-2040 In addition to evaluating the cost and emissions performance of the three technologies operating in within BBB’s fleet, fleet-wide costs and emissions were evaluated across the ICT regulatory timeframe. By assessing the economic and environmental performance over this period, the costs and emissions profile of BBB’s fleet transitioned to both NZE natural gas buses and zero-tailpipe emission battery electric transit buses could be compared to the baseline scenario developed for BBB’s existing transit bus fleet. As described Section 3, the implementation timeframe of the regulation is anticipated to begin in 2018 and continue through 2040. While the regulatory framework has not officially been established, ARB’s publicly available documents strongly suggest their intention of transitioning California’s entire transit fleet to zero emission technologies by 2040. The following sections describe the economic and emissions profile that would result during the 23-year implementation timeframe for each of the three scenarios. For each of the scenarios, it is assumed that the size of BBB’s fleet will not grow (aside from potential increases in fleet size associated with battery electric transit buses) and will remain constant during this period. The average useful life of BBB’s existing transit bus is approximately 12 years which would indicate that approximately 8.33% of the fleet (approximately 17 buses) is retired annually. However, actual retirements and replacements fluctuate from year to year. For this reason, the analysis assumes BBB’s current transit bus replacement schedule which has been extrapolated over the regulatory timeframe. A schedule containing the number of buses that will be replaced each year is included in APPENDIX A – Big Blue Bus Existing Fleet Characteristics and Assumptions. 6.1. BASELINE SCENARIO – ECONOMIC AND EMISSIONS ANALYSIS The baseline scenario identifies the costs and emissions that would result in the absence of any regulatory measure. Under this baseline scenario, the buses retired would be replaced with buses of similar features, costs, and emissions profiles that are characterized in Sections 4.1 and 5.1. Table 35 displays the operational costs that BBB would incur during the regulatory timeframe assuming that BBB’s existing fleet continues to move forward under the current acquisition and operational conditions. During the 23-year implementation timeframe of the ICT regulation, BBB would incur a cost of approximately $414 million. BBB Existing Fleet – Baseline Scenario Costs 2018-2040 Total Cost Incremental Cost Relative to Baseline Capital and Operational Costs $ 413,748,150 – Table 35: Economic cost of BBB’s existing fleet during ICT implementation timeframe Table 36 displays the emissions that would result during this same period as a result of continue to operate their existing natural gas buses fuelled by RLNG. Item 4-A 4/24/18 53 of 80 Item 4-A 4/24/18 BBB Existing Fleet – Baseline Scenario Emissions 2018-2040 Total Emissions Emission Reductions Relative to Baseline WTW CO2e Emissions (MT) 218,960 – TTW NOx Emissions (tons) 95.2 – WTW NOx Emissions (tons) 835.8 – TTW PM10 Emissions (tons) 1.47 – WTW PM10 Emissions (tons) -14.63 – Table 36: Emissions profile of BBB’s existing fleet during ICT implementation timeframe 6.2. NEAR -ZERO NOX EMISSION NATURAL GAS TRANSIT FLEET SCENARIO - ECONOMIC AND EMISSIONS ANALYSIS The near-zero NOX emission natural gas scenario identifies the costs and emissions that would result if BBB transitions its entire fleet to NZE CNG transit buses during regulatory timeframe. Under this scenario, the buses that BBB retires each year would be replaced with the NZE natural gas transit buses characterized in Sections 4.2 and 5.2. Because these buses are capable of providing comparable levels of service, no changes to fleet operations are assumed. Figure 26 displays how BBB’s fleet composition would change over the implementation timeframe as NZE natural gas transit buses are phased in. According to the current replacement schedule, BBB’s fleet would transition entirely to NZE natural gas transit buses by 2029. Figure 26: BBB fleet transitioned to NZE natural gas transit buses Table 37 displays the operational costs that BBB would incur during the 23-year regulatory timeframe assuming that the existing fleet is replaced with NZE natural gas transit buses under the current acquisition and operational conditions. During the implementation timeframe, BBB Item 4-A 4/24/18 54 of 80 Item 4-A 4/24/18 would incur a cost of approximately $418 million as a result of transitioning to the alternative technology. Near-Zero NOx Emission Natural Gas Fleet Costs – 2018-2040 Total Cost Incremental Cost Relative to Baseline Capital and Operational Costs $ 417,803,910 ↑ $ 4,055,760 Table 37: Economic costs of transitioning to NZE natural gas buses during ICT implementation timeframe Table 38 displays the emissions that would result during the timeframe as BBB’s existing fleet is replaced with NZE CNG transit buses. Near-Zero NOx Emission Natural Gas Fleet Emissions – 2018-2040 Total Emissions Emissions Relative to Baseline Scenario WTW CO2e Emissions (MT) 192,236 ↓ 26,724 TTW NOx Emissions (tons) 35.1 ↓ 60.1 WTW NOx Emissions (tons) 779.0 ↓ 56.8 TTW PM10 Emissions (tons) 1.48 ↑ 0.01 WTW PM10 Emissions (tons) -14.66 ↑ 0.03 Table 38: Emissions profile of transitioning BBB’s existing fleet to a near-zero NOx natural gas transit fleet during ICT implementation timeframe 6.3. ZERO-TAILPIPE EMISSION BATTERY ELECTRIC TRANSIT FLEET SCENARIO – ECONOMIC AND EMISSIONS ANALYSIS The battery electric transit bus scenario identifies the costs and emissions that would result if BBB transitions its existing fleet to zero-tailpipe emission battery electric transit buses during regulatory timeframe. Under this scenario, the buses that BBB retires each year would be replaced with the battery electric transit buses characterized in Sections 4.3 and 5.3. The battery electric transit bus operational and technology assessment found that transitioning to BEBs with ~450 kWh battery packs, BBB would need to 0.5% – 2% more daily peak buses to operate the same service as BBB’s existing natural gas buses. This equates to a fleet size of approximately 201 to 204 total buses compared to BBB’s current fleet of 200. However, because the transitioning to BEBs will occur over time, it is reasonable to assume that improvements in battery electric transit bus technology (i.e. increased battery capacity, weight reductions, etc.) will also occur. For this reason, the analysis assumes that BBB will not need to increase its fleet size and that battery electric transit buses procured later in during the transition will benefit from such performance improvements, thus, eliminating the need for 1 to 4 additional buses. Figure 27 displays how BBB’s fleet composition would change over the implementation timeframe as battery electric transit buses are phased in. According to the current replacement schedule, BBB’s fleet would transition entirely to battery electric transit buses by 2029. Item 4-A 4/24/18 55 of 80 Item 4-A 4/24/18 Figure 27: BBB fleet transitioned to battery electric transit buses Table 39 displays the operational costs that BBB would incur during the 23-year regulatory timeframe assuming that the existing fleet is replaced with zero-tailpipe emission battery electric transit buses under the current acquisition and operational conditions. During the implementation timeframe, BBB would incur a cost of approximately $492 million as a result of transitioning to the alternative technology. Battery Electric Fleet Costs – 2018-2040 Total Cost Incremental Cost Relative to Baseline Capital and Operational Costs $ 492,001,711 ↑ $ 78,253,561 Table 39: Economic costs of transitioning to battery electric transit buses during ICT implementation timeframe Table 40 displays the emissions that would result during the timeframe as BBB’s existing fleet is replaced with battery electric transit buses. BBB Battery Electric Fleet Emissions – 2018-2040 Total Emissions Emissions Relative to Baseline Scenario WTW CO2e Emissions (MT) 70,205 ↓ 148,755 TTW NOx Emissions (tons) 30.1 ↓ 65.1 WTW NOx Emissions (tons) 271.9 ↓ 563.9 TTW PM10 Emissions (tons) 0.47 ↓ 1.00 WTW PM10 Emissions (tons) -2.24 ↑ 12.39 Table 40: Emissions profile of transitioning BBB’s existing fleet to a near-zero NOx natural gas transit fleet during ICT implementation timeframe Item 4-A 4/24/18 56 of 80 Item 4-A 4/24/18 6.4. SUMMARY AND CONCLUSIONS A comparison of the economic and cost profiles of BBB’s existing fleet to that of the two alternative scenarios allows for a detailed assessment of the costs of the emissions reductions associated with each technology pathway. As indicated in Figure 28, transitioning BBB’s fleet to NZE natural gas transit buses will result in a 12% reduction in WTW GHG emissions despite that the Cummins ISL G NZ engine is slightly less efficient than the Cummins ISL G engine in BBB’s existing transit buses. Transitioning BBB’s existing fleet to BEBs will significantly reduce fleet GHG emissions by approximately 150,000 MT during the timeframe. Eliminating 150,000 MT of GHG emissions is equivalent to eliminating nearly 18 million gallons of gasoline or nearly 350,000 gallons of diesel from being consumed.4 However, these reductions come at a cost of approximately $78 million or approximately $526/MT . The majority (approximately 99%) of WTW GHGs emitted during the transition to BEBs are attributable to the emissions from BBB’s existing transit buses as they are retired during the timeframe. Figure 28: Fleet well-to-wheel greenhouse gas emissions during implementation timeframe Figure 29 displays the fleet WTW GHG emissions for transitioning the existing fleet to BEB’s fuelled by California’s average grid electricity mix.3 In the event that BBB ceases to procure zero carbon electricity, transitioning BBB’s existing fleet to BEBs will reduce fleet GHG emissions by approximately 56,000 MT during the timeframe. 4 Greenhouse Gas Equivalencies Calculator, Environmental Protection Agency, https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator Item 4-A 4/24/18 57 of 80 Item 4-A 4/24/18 Figure 29: Fleet well-to-wheel greenhouse gas emissions during implementation timeframe Figure 30 displays the TTW NOx emissions that will result from each deployment scenario. As indicated, transitioning to either of the alternative technologies will yield significant TTW NOx emission reductions. Transitioning to NZE natural gas transit buses yields a 63% reduction from the baseline while the transition to BEBs yields a 68% reduction from the baseline. Though the reductions achieved by each scenario are comparable, there is a significant difference in the costs that will be incurred. At an incremental cost of approximately $4 million, the 60.1 tons of NOx reduced as a result of transitioning to a NZE natural gas fleet will cost approximately $67,484/ton. At an incremental cost of $78 million, the 65.1 tons of NOx reduced as a result of transitioning to a BEB fleet will cost approximately $1,202,852/ton. A comparison of the two alternative scenarios reveals that the additional 5.0 tons of NOx reductions that result from transitioning to a BEB fleet will cost BBB approximately $74 million. Item 4-A 4/24/18 58 of 80 Item 4-A 4/24/18 Figure 30: Fleet tank-to-wheel NOx emissions during implementation timeframe Figure 31 displays the TTW PM10 emissions that will result from each deployment scenario. As indicated, transitioning to a NZE natural gas transit fleet will result in a very small increase in PM10 emissions. The reason for this is because the Cummins ISL G NZ is slightly less efficient than the Cummins ISL G that is equipped in BBB’s existing transit buses. In contrast, transitioning to BEBs yields a 68% reduction from the baseline scenario. While this is a significant percent reduction, the PM emissions from each of the scenarios is very small because natural gas engines have extremely low PM10 emissions. Figure 31: Fleet tank-to-wheel PM10 emissions during implementation timeframe Item 4-A 4/24/18 59 of 80 Item 4-A 4/24/18 The results of the analysis are based on projections of significant operating cost reductions for battery electric buses over time. These reductions are based on large reductions in battery storage costs and projections of revenue from the ARB LCFS program. GNA acknowledges that changes in these assumptions will have a dramatic impact on the total estimated project costs. Should battery storage costs remain constant (and not fall over time as projected), the incremental cost of converting the entire fleet to electric buses would increase to approximately $130 million as opposed to approximately $78 million. In the event that battery storage costs remain constant and the market value of LCFS credits declines by 50%, the incremental cost of converting the entire fleet to electric buses would rise to approximately $141 million. If the market for LCFS credits is eliminated entirely and battery prices remain constant, the incremental cost for converting BBB’s fleet to battery electric buses would rise further to approximately $152 million. Taking into account the uncertainty that exists when making projections about the future, the analysis estimates that the incremental cost of converting BBB’s existing fleet to a fleet of battery electric buses ranges from approximately $78 million to $152 million during the timeframe (2018-2040). Item 4-A 4/24/18 60 of 80 Item 4-A 4/24/18 APPENDIX A – Big Blue Bus Existing Fleet Characteristics and Assumptions BBB Fleet Data Metric Values/Comments Data Source Average Annual Total Miles per bus 32,250 GNA Analysis of BBB fleet data Average Miles per assignment 70.81 GNA Analysis of BBB fleet data Average In-service Bus Speed (MPH) 8.87 GNA Analysis of BBB fleet data Average Daily In-Service Hours per bus 8.15 GNA Analysis of BBB fleet data Bus Retirement Average Age 12 years Per BBB standard procedure BBB Fleet Retirement Schedule – 2018-2040 Year Buses Retired Buses Purchased Y0 2017 27 27 Y1 2018 21 21 Y2 2019 0 0 Y3 2020 0 0 Y4 2021 0 0 Y5 2022 5 5 Y6 2023 10 10 Y7 2024 30 30 Y8 2025 29 29 Y9 2026 29 29 Y10 2027 18 18 Y11 2028 29 29 Y12 2029 34 34 Y13 2030 14 14 Y14 2031 21 21 Y15 2032 0 0 Y16 2033 0 0 Y17 2034 0 0 Y18 2035 5 5 Y19 2036 10 10 Y20 2037 30 30 Y21 2038 29 29 Y22 2039 29 29 Y23 2040 18 18 Item 4-A 4/24/18 61 of 80 Item 4-A 4/24/18 APPENDIX B – Transit Bus Costs and Assumptions CNG Bus Fuel Economy Year Mile/DGE Source Description 2016 3.66 Fuel economy data was calculated by taking an average of the in-service fuel economies for BBB’s model year 2011 through model year 2016 40-foot transit buses. Capital Costs Year $/Bus (constant 2016) Source Description 2016 $605,336 Bus capital costs are based on BBB’s recent bus purchases for 2017 Gillig CNG transit buses. O&M Costs Year Description $/mile (constant 2016) Source Description 2016 Propulsion $0.196 O&M costs are based on BBB’s historical cost data. Propulsion related O&M costs for CNG transit buses include costs related directly to the propulsion system. Non-propulsion O&M costs include costs related to brake replacements and costs for other repairs unrelated to the propulsion system. Non- Propulsion $0.620 Total O&M $0.816 Mid-Life Overhaul Costs Year $/Bus (constant 2016) Source Description 2016 $27,000 CNG mid-life overhaul costs are based on BBB’s historical cost data. Midlife overhaul costs include approximately $17,000 – engine rebuild, $8,000 – transmission overhaul, and $2,000 brake system rebuilds. Near-Zero NOx CNG Transit Bus Fuel Economy Year Mile/DGE Source Description 2017 3.64 Fuel economy data was calculated by taking an average of the in- service fuel economies for BBB’s model year 2011 through model year 2016 40-foot transit buses and adjusting for the fuel efficiency of the near-zero NOx CNG engine. A comparison of the certified CO2 emissions contained in ARB Executive Orders A-021-0662 and A- 021-0659 revealed the near-zero NOx CNG engine is 0.0043% less efficient than the similar CNG engine certified to the current emissions standard. Capital Costs Year $/Bus (constant 2016) Source Description 2017 $613,776 Bus capital costs are based on recent bus procurements for 2017 40- foot Gillig near-zero NOx CNG transit buses. The incremental cost of the near-zero NOx engine technology is $8,440/bus. Year Description $/mile Source Description Item 4-A 4/24/18 62 of 80 Item 4-A 4/24/18 O&M Costs (constant 2016) 2017 Propulsion $0.205 O&M costs near-zero NOx CNG transit buses are based on a combination of BBB’s historical cost data and an assumption to account for the increased complexity of the near-zero NOx engine. It is assumed that the increased complexity of the near-zero NOx engine will result in slightly higher O&M costs. The analysis assumes that engine related O&M costs will be 5% higher than engine related O&M costs for BBB’s existing transit buses. Propulsion related (engine and transmission) O&M costs for CNG transit buses include costs related directly to the propulsion system. Non- propulsion O&M costs include costs related to brake replacements and costs for other repairs unrelated to the propulsion system. Non- Propulsion $0.620 Total O&M $0.825 Mid-Life Overhaul Costs Year $/Bus (constant 2016) Source Description 2017 $30,000 Near-zero NOx CNG mid-life overhaul costs are based on a combination of BBB’s historical cost data and an assumption to account for the additional costs associated with the increased complexity of the near-zero NOx engine. The analysis assumes engine related midlife overhaul costs to be $3,000 higher than the costs for BBB’s existing transit buses. Midlife overhaul costs include approximately $20,000 – engine rebuild, $8,000 – transmission overhaul, and $2,000 brake system rebuilds. Battery Electric Transit Bus Fuel Economy Year Mile/DGE Source Description 2017 15.25 Fuel economy for BEBs was calculated using the average of the in- service fuel economies for BBB’s model year 2011 through model year 2016 40-foot transit buses. Using the in-service fuel economies and average route speeds, an estimate for the fuel efficiency of BEBs placed in BBB’s operations was derived. Using the model, the estimated fuel efficiency of extended range BEBs was found to be 2.45 kWh/mile (equivalent to 15.25 mi/DGE). Capital Costs Year $/Bus (constant 2016) Source Description 2017- 2019 2020- 2024 2025- 2029 $926,996 $843,037 $796,119 Bus capital costs are based on the base price of a 40-foot extended range electric bus with a ~450 kWh energy storage system. The capital costs were derived from information generated for ARB’s ICT working group meetings and information provided by BBB. Per ARB’s Item 4-A 4/24/18 63 of 80 Item 4-A 4/24/18 2030+ $750,682 Bus Prices Analysis (Draft)5, the pre-tax base price of a 40-foot Proterra extended range electric bus with a 330 kWh battery pack is $749,000. This price includes ADA and standard equipment but does not include fare boxes or other bus options like cameras. The analysis includes standard features that BBB specifies in their bus procurements and BBB’s standard cost for ADA equipment. The analysis also includes the costs associated with the additional 120 kWh battery capacity that is required to meet BBB’s operations. Battery costs and projected reductions are based on ARB’s Battery Cost for Heavy-Duty Electric Vehicles - (Discussion Draft). ARB estimate that the 2017 cost of $575/kWh will decline to $405/kWh (2020), $310/kWh (2025), and $218/kWh (2030).6 Using these projections, the capital cost of an extended range 40-foot electric bus with a ~450 kWh battery pack were estimated for buses procured in 2017-2019, 2020-2024, 2025-2029, and 2030+. Below is the capital cost for a 2017 40-foot bus: Base Price 330 kWh (excluding ADA equipment): $699,315 Additional 120 kWh Battery Capacity: $69,000 UTC Camera System: $7,500 Luminator Color Head Design: $7,009 Thermo Guard Passenger Glass: $6,548 Trapeze Transitmaster: $10,000 Total Taxable Amount: $799,372 State & Local Taxes (9.75%): $77,939 ADA – Non-taxable: $49,685 Total (Base, Tax, & ADA): $926,996 The incremental cost of the battery electric is $321,660/bus. O&M Costs Year Descriptio n $/mile (constant 2016) Source Description 2017 Propulsion $0.098 O&M costs for battery electric transit buses are based on a combination of BBB’s historical data and assumptions to account for the reduced O&M costs associated with the decreased complexity of the battery electric propulsion system. The analysis assumes that propulsion related O&M costs for battery electric transit buses to be 50% less than propulsion related O&M costs for BBB’s existing transit buses. The assumed propulsion related O&M cost reductions are consistent with a similar report produced for LACMTA and derived from LACMTA’s and other fleet’s experience with battery electric transit buses. Additionally, battery electric powertrains include regenerative braking Non- Propulsion $0.596 Total O&M $0.694 5 Bus Prices Analysis (Draft) - Updated on 2/10/2017, California Air Resources Board 6 Battery Cost for Heavy-Duty Electric Vehicles (Discussion Draft), Revised August 22, 2016, California Air Resources Board Item 4-A 4/24/18 64 of 80 Item 4-A 4/24/18 systems that significantly reduce the amount of brake repairs required. The analysis assumes that O&M costs for brake repairs to be 50% less than brake-related O&M costs for BBB’s existing transit buses. The assumed brake-related O&M cost reductions are based on ARB’s Literature Review on Transit Bus Maintenance Cost (Discussion Draft) - August 2016.7 Because brake repairs are traditionally included as part of non-propulsion related O&M, the reduced costs attributed to the battery electric propulsion system are reflected non-propulsion related O&M costs. Mid-Life Overhaul Costs Year $/Bus (constant 2016) Source Description 2017- 2019 2020- 2024 2025- 2029 2030+ $288,750 $212,250 $169,500 $128,100 Battery electric transit bus midlife costs are estimated from information provided by bus OEMs to ARB, Altoona test results, and assumptions to account for specific components of a battery electric powertrains that may require replacement or reconditioning as part of the midlife overhaul. The total cost includes repairs to the drive motors, inverter, and energy storage system. Battery replacement costs are based are based on a ~450 kWh battery pack and account for projected battery cost reductions. Battery cost reductions are based on ARB’s Battery Cost for Heavy-Duty Electric Vehicles - (Discussion Draft). ARB estimate that the 2017 cost of $575/kWh will decline to $405/kWh (2020), $310/kWh (2025), and $218/kWh (2030). Using these projections, the cost of replacing a ~450 kWh battery pack are assumed to be $258,750 (2017-2019), $182,250 (2020-2024), $139,500 (2025-2029), $98,100 (2030+). It is assumed that battery costs beyond 2030 will remain constant. In addition, replacement or reconditioning of a battery electric transit bus’s drive motor and inverter may be required as part of the midlife overhaul at a cost of $30,000. The model assumes that the cost for a midlife overhaul are the costs that will be incurred 6 years from the date the bus was initially purchased; a 2018 model year bus will be overhauled in 2024 at a cost of $212,250. 7 Literature Review on Transit Bus Maintenance Cost (Discussion Draft), August 2016, Advanced Clean Transit Program, California Air Resources Board Item 4-A 4/24/18 65 of 80 Item 4-A 4/24/18 APPENDIX C – Fuel and Fuelling Infrastructure Cost Assumptions Fuel Cost Assumptions RNG Year $/unit (constant 2016) Source Description 2016 $1.239 $/DGE RNG fuel cost is based on BBB’s average direct and indirect fuel costs incurred by BBB between July 1, 2016 and December 31, 2016. Included are commodity costs, LCNG station operation and maintenance costs, and onsite technician costs. Commodity costs include the direct fuel cost plus taxes and take into account for a $0.15 savings for LCFS credits. Station O&M costs are based on the average historical cost of BBB’s station service contract with the fuel provider. In addition, station O&M costs include the fully burden cost for one full time equivalent employee dedicated to day-to-day support for the LCNG station. Due to minimal electricity demand of an LCNG station, the cost of electricity is considered negligible. Electricity 2017 $0.0893 $/kWh Fuel cost for a battery electric transit bus is a composite of electricity costs, demand charges, charger O&M, and LCFS credits. It is assumed that BBB will continue to purchase a higher percentage of renewables in their electricity mix. As a result, the analysis factors in this additional cost in the total cost of electricity. As discussed in the narrative, a cost model analysing the new electricity demand was developed for the available rates structures. The analysis assumes the TOU-EV6 +E3 rate structure and 50 kW depot chargers with mid-day charging. The cost of electricity was calculated to be $0.173/kWh. The cost of maintaining depot chargers is estimated to be $500/charger/year (per ARB Transit Working Group Meeting – Cost Data Sources, 6/26/2017) which translates to $0.0063/kWh in BBB’s operations. It is assumed that LCFS credits will offset electricity costs by $0.090/kWh. Therefore, BBB’s net cost of electricity is $0.0893/kWh. Fuelling Infrastructure Cost Assumptions Electric Charging Infrastructure Year $/Bus (constant 2016) Source Description 2016 $103,000 Charging infrastructure costs include both the costs for the charging equipment and the costs for installation. It is assumed that one depot charger will be required for each battery electric transit bus. The analysis determined that a 50 kW charger would be sufficient for an overnight charging strategy. The cost for depot chargers varies significantly across the BEB OEMs. For example, the purchase of each BYD BEB comes with an on- board charger and a charger pedestal. A comparable Proterra BEB requires Proterra’s 60 kW depot charger which costs Item 4-A 4/24/18 66 of 80 Item 4-A 4/24/18 $50,000 according to information that Proterra provided to ARB as part of the most recent transit working group meeting. The analysis assumes that one charger will be required each BEB at cost of $50,000 for each depot charger. It is assumed that the useful life of a charger is approximately 12 years. In addition to the cost of the charging equipment, charging infrastructure costs also include installation costs. Installation costs include wiring and conduit, transformers, engineering, design, permitting, utility upgrades, and a back-up generator(s) to provide power in the event of an outage. Antelope Valley Transit Authority’s (AVTA) charging infrastructure build out of 89 depot chargers cost $5,000,000 (Phase 1 - $4,500,000 and Phase 2 - $500,000). However, these costs include power adapters and weatherproof hoods specific to BYD buses that are equipped with on-board chargers. After deducting these costs, AVTA’s build-out cost $4,110,000 or $46,180/charger. The analysis assumes a charger installation cost of $46,000/charger. It was determined that mounting the depot chargers on an overhead structure, at an estimated cost of $1,331,250 or $6,656/bus, is the only viable option given BBB’s facility constraints. It is assumed that the useful life of the charger installation and overhead structure is approximately 24 years. The analysis assumes the total cost for depot charging infrastructure to $103,000/bus (Installation Costs - $46,000, Charger Costs - $50,000, and Structure Costs - $7,000). Item 4-A 4/24/18 67 of 80 Item 4-A 4/24/18 APPENDIX D – Fuel Properties and Emissions Factors Fuel Properties Value Low-Sulfur Diesel LHV 127,460 Btu/DGE CA-GREET 2.0 Low-Sulfur Diesel Density 3,142 g/gal CA-GREET 2.0 Low-Sulfur Diesel % Carbon by Weight 86.5% CA-GREET 2.0 CA Gasoline LHV 109,786 Btu/GGE CA-GREET 2.0 LNG LHV 74,720 Btu/gal CA-GREET 2.0 NG LHV 983 Btu/ft3 CA-GREET 2.0 Electricity (MJ per kWh) 3.6 CNG Transit Bus Emissions Factors Value Description WTT CO2e -26.14 gCO2e/MJ WTT CO2e emissions were modelled in CA-GREET using GNA’s estimates of values representative of LNG produced in Southern California from landfill gas. The estimated values are based on landfill gas to pipeline-quality biomethane, delivered via pipeline to CA, liquefied in CA, and trucked to Santa Monica. The regasification step was not included in the CA- GREET model because, looking at the pictures of the L-CNG station, BBB appears to be using ambient vaporizers. Ambient vaporizers do not require electricity to operate so they were not included in the regasification process in the pathway calculations. TTW CO2e 66.27 gCO2e/MJ TTW CO2e emissions were derived from the certified emissions values contained in ARB EO A-021-0662 for model year 2017 Cummins ISL G 8.9 liter natural gas engine certified for urban bus applications. CO2e emissions include CO, CH4, and N2O. To convert emissions values to CO2e, global warming potentials (GWPs) for CH4 (25) and N2O (298) were sourced from CA-GREET 2.0. WTT NOx 130.07 g/mmBtu WTT NOx emissions were modelled in CA-GREET using GNA’s estimates of values representative of LNG produced in Southern California from landfill gas TTW NOx 0.581 g/mi TTW NOx emissions were derived from the certified emissions values contained in ARB EO A-021-0662 for model year 2017 Cummins ISL G 8.9 liter natural gas engine certified for urban bus applications. WTT PM10 -2.82 g/mmBtu WTT PM10 emissions were modelled in CA-GREET using GNA’s estimates of values representative of LNG produced in Southern California from landfill gas TTW PM10 0.0091 g/mi TTW PM10 emissions were derived from the certified emissions values contained in ARB EO A-021-0662 for model year 2017 Cummins ISL G 8.9 liter natural gas engine certified for urban bus applications. Near-Zero NOx CNG Transit Bus Emissions Factors Value Description Item 4-A 4/24/18 68 of 80 Item 4-A 4/24/18 WTT CO2e -26.14 gCO2e/MJ WTT CO2e emissions were modelled in CA-GREET using GNA’s estimates of values representative of LNG produced in Southern California from landfill gas. The estimated values are based on landfill gas to pipeline-quality biomethane, delivered via pipeline to CA, liquefied in CA, and trucked to Santa Monica. The regasification step was not included in the CA- GREET model because, looking at the pictures of the L-CNG station, BBB appears to be using ambient vaporizers. Ambient vaporizers do not require electricity to operate so they were not included in the regasification process in the pathway calculations. TTW CO2e 59.00 gCO2e/MJ TTW CO2e emissions were derived from the certified emissions values contained in ARB EO A-021-0659 for model year 2017 Cummins ISL G Near Zero 8.9 liter natural gas engine certified to ARB’s low-NOx standard (0.02 g/bhp-hr) for urban bus applications. CO2e emissions include CO, CH4, and N2O. To convert emissions values to CO2e, global warming potentials (GWPs) for CH4 (25) and N2O (298) were sourced from CA-GREET 2.0. WTT NOx 130.07 g/mmBtu WTT NOx emissions were modelled in CA-GREET using GNA’s estimates of values representative of LNG produced in Southern California from landfill gas TTW NOx 0.045 g/mi TTW NOx emissions were derived from the certified emissions values contained in ARB EO A-021-0659 for model year 2016 Cummins ISL G 8.9 liter natural gas engine certified to ARB’s low-NOx standard (0.02 g/bhp-hr) for urban bus applications. WTT PM10 -2.82 g/mmBtu WTT PM10 emissions were modelled in CA-GREET using GNA’s estimates of values representative of LNG produced in Southern California from landfill gas TTW PM10 0.0091 g/mi TTW PM10 emissions were derived from the certified emissions values contained in ARB EO A-021-0659 for model year 2017 Cummins ISL G 8.9 liter natural gas engine certified to ARB’s low-NOx standard (0.02 g/bhp-hr) for urban bus applications. Battery Electric Transit Bus Emissions Factors Value Description WTT CO2e 1.0073 gCO2e/MJ WTT CO2e emissions were modelled in CA-GREET using GNA’s estimates of values representative of the electricity that BBB procures from Southern California Edison and 3 Phases Renewables. Per BBB’s contract with 3 Phases Renewables, BBB receives 100% renewable electricity with a renewable energy mix consisting of over 90% wind and solar energy sources. The electricity mix in CA- GREET was adjusted to a mix of 45.00% solar, 45.00% wind, 6.02% hydroelectric, 2.58% geothermal, and 1.40% biomass. TTW CO2e 0.00 gCO2e/MJ N/A Item 4-A 4/24/18 69 of 80 Item 4-A 4/24/18 WTT NOx 0.007399 g/MJ WTT NOx emissions were modelled in CA-GREET using GNA’s estimates of values representative of electricity that BBB procures from Southern California Edison and 3 Phases Renewables. TTW NOx 0.00 g/mi N/A WTT PM10 0.002418 g/MJ WTT PM10 emissions were modelled in CA-GREET using GNA’s estimates of values representative of electricity that BBB procures from Southern California Edison and 3 Phases Renewables. TTW PM10 0.00 g/mi N/A Item 4-A 4/24/18 70 of 80 Item 4-A 4/24/18 I t e m 4 - A 4 / 2 4 / 1 8 7 1 o f 8 0 I t e m 4 - A 4 / 2 4 / 1 8 I t e m 4 - A 4 / 2 4 / 1 8 7 2 o f 8 0 I t e m 4 - A 4 / 2 4 / 1 8 I t e m 4 - A 4 / 2 4 / 1 8 7 3 o f 8 0 I t e m 4 - A 4 / 2 4 / 1 8 1 Vernice Hankins From:Diane Forte <Diane.Forte@sce.com> Sent:Monday, April 23, 2018 5:09 PM To:councilmtgitems Subject:comments: Santa Monica City Council Agenda Item for 4/24/2018 4.A: Study Session - Fleet Composition Study and Recommended Action - support Southern California Edison (SCE) supports the City of Santa Monica’s move to electrify the Big Blue Bus fleet and to lead by example with the use of battery electric buses to achieve a goal of zero emissions, and applauds the consideration to purchase up to 10 battery electric buses.  We appreciate Santa Monica’s staff efforts in thoughtfully considering the many factors around the ultimate electrification of the City’s entire bus fleet, moving toward a zero‐emission scenario with the direction of City Council, and look forward to continue to partner with the City to help meet the infrastructure needs to support that fleet.  All Californians, deserve clean, zero‐emission electric transportation. And this zero‐emission technology is available now for battery electric buses, as demonstrated by commitments and efforts under way at Foothill, LA Metro and other transit agencies.  While we have previously pointed out in a letter to the City Manager some inaccuracies in the study ‐ overestimate of electrification costs and underestimation of benefits ‐ we’d like to point out a few undisputable facts from the staff report that the council might consider when providing guidance that the staff seeks for bus electrification: o On page three, it shows that 23 buses will need to be purchased in the next two years. o Staff has identified 23 potential charging unit locations within the maintenance yard where BEBs could be charged overnight. o And, with a useful life of 12 years, the entire bus fleet will turnover by 2030.  Procurement decisions made and guidance provided now will impact Californians for generations to come. It is therefore important that we invest wisely. Electricity is the cleanest transportation fuel available today, and holds the greatest promise for a carbon‐free and particulate matter/pollution‐free environment.  SCE will continue to be a partner with Santa Monica and provide subject matter expertise to help in paving the way for zero emissions.  Again, thank you for your leadership and commitment toward building our clean energy future. Diane Forte Government Relations Manager Local Public Affairs Southern California Edison (SCE) Item 4-A 4/24/18 74 of 80 Item 4-A 4/24/18 Item 4-A 4/24/18 75 of 80 Item 4-A 4/24/18 Electric Bus Letter 4/23/2018 P a g e | 2 will provide direction to develop a real EV bus implementation that the City can be proud to lift up as a model. A. If Santa Monica Wants to Continue its Role as an Environmental Leader, it Needs a Real EV Bus Plan. We appreciate the fact that the Staff Report provides the context for the shift to an all- electric fleet conversion. The Staff Report mentions the significant efforts of the Los Angeles Department of Transportation (LA DOT), Los Angeles County Metro (Metro), Foothill Transit, and King County Metro, all of which have taken earnest efforts to have full electric bus fleets deployed or significant quantities of electric buses on order. Further, BBB’s sister agencies, Metro and LA DOT have gone even further than a simple commitment to electric buses – both agencies have also committed to powering their buses with clean energy sources (such as solar); prioritizing electrification in overburdened communities; and using federally-approved economic development policies, such as the U.S. Employment Plan, to stimulate electric bus manufacturing in the state and broader U.S. Beyond Metro and LA DOT, there are municipalities throughout the U.S. that are also making an aggressive push towards an electric bus future. Jurisdictions as diverse as Anchorage, AK; Aspen, CO; Dallas, TX; Denver, CO; Fresno, CA; Greenville, SC; Lancaster, CA; Louisville, KY; Moline, IL; Park City, UT; San Jose, CA; San Mateo, CA; Santa Barbara, CA; Stockton, CA; Visalia, CA; Washington, DC; John F. Kennedy Airport; NY; Los Angeles World Airports, CA; Marin, CA; Modesto, CA; Philadelphia, PA; Worcester, MA; Everett, WA; and Lexington, KY have all made commitments to tackling air and climate pollution through either having more EV buses than Santa Monica on the road now or plans to deploy many more than what Santa Monica is proposing in its EV bus plan. In so doing, each of these locations have also addressed agency concerns regarding operational and other challenges of integrating electric buses into the transit fleet. The Staff Report claims it “recommends a responsible approach to first prototyping the application of electric bus operation on the BBB system, and moving forward with the implementation of a proof of concept program with measurable outcomes for success with a small fleet of electric buses over the next 2 years to lay the groundwork for a transition to a 100% zero-emissions fleet.” This approach is neither “responsible,” nor will it truly “lay the groundwork” for achieving the City Council’s vision. While other transit agencies are leaving BBB behind, Santa Monica’s transit agency will be spending time on a “proof of concept” for a technology that works and is proven. We understand that a conversion to electric buses is difficult. It requires significant work from agency staff, electrical utilities, a pool of highly trained workers to build our buses, and our union brothers and sisters in the skilled trades to help build the infrastructure, and political leadership. But we’re surprised by an undercurrent of fear that permeates this staff report. Santa Monica has earned the reputation of a city that understands the importance of taking bold action to protect the environment for the sake of current and future generations. Therefore, we were surprised to see BBB has exhibited such reluctance to join other transit agencies that are working to figure out this necessary transition to electric buses. Our climate future demands a rapid transition to electric buses, which represents superior technology when considering air quality and climate pollution issues. Item 4-A 4/24/18 76 of 80 Item 4-A 4/24/18 Electric Bus Letter 4/23/2018 P a g e | 3 B. BBB Cost Estimates are Out of Line With Other Assessments. We appreciate that Gladstein Neandross and Associates and Ramboll Environ have admitted the following: electric buses reduce more air and climate pollution. The environmental benefits are even greater for agencies like BBB, which procure zero carbon electricity. These findings that electric buses produce fewer emissions of criteria pollutants and climate pollution than methane buses – even those using lower-NOx engines and powered by out-of-state landfill gas is important to this discussion. But even with these concessions about the environmental superiority of electric buses, the cost estimates that are being used appear to miss several critical opportunities. First, the analysis excludes many of the following new programs or amendments to existing programs meant to help transit agencies as they shift to electric buses. a. Hybrid and Zero Emissions Truck and Bus Voucher Program (HVIP) funding has increased: i. The California Air Resources Board (CARB) offers the HVIP to accelerate the purchase of cleaner, more efficient buses in California. The pool of available funding last year was $21.4 million and now it’s $182 million with a carve out of at least $35 million for public transit buses. Thus, there is more HVIP funding just for transit buses than existed for all HVIP eligible vehicles in the previous year (i.e., electric trucks, school buses and other vehicles). ii. The amount of the incentive per bus has increased. For the most common transit bus type, (40’) the incentive increased from $95,000 to $150,000 per bus plus an additional $15,000 if the bus operates in a disadvantaged community. iii. A new incentive was created for 60’ buses of $175,000 per bus plus $15,000 if operating in a disadvantaged community. iv. A new incentive was created to pay up to $30,000 per bus charger. b. Under SB 350 (2015) the investor owned utilities (IOUs), including Southern California Edison (SCE) have now filed applications to the California Public Utilities Commission (CPUC) requesting: i. To pay for the electrical infrastructure upgrades needed to the bus depots and the “make readies” (trenching and electric cabling from the depot meter to the charger pedestals). The CPUC has already approved funds for Southern California Edison (SCE) territory through the priority review program. In some cases, the IOUs are also providing rebates to help pay for the chargers as well. ii. More favorable tariffs for lower electricity costs for transit agencies and heavy-duty trucks. Item 4-A 4/24/18 77 of 80 Item 4-A 4/24/18 Electric Bus Letter 4/23/2018 P a g e | 4 The CPUC is expected to rule on these as early as next month.1 c.Improvements to the Low-Carbon Fuel Standard (LCFS) program are approaching. The current program provides significant financial support for Zero Emission Bus fuel costs and can cover much, all or potentially even more than the annual cost of electricity for an electric bus, depending on charging protocols. Access to LCFS funds will not be restricted once CARB’s Innovative Clean Transit (ICT) standard is put in place. Further, CARB is currently moving through a process to update this program and is expected to finalize these changes this year. If proposed improvements are adopted, it could increase the amount of credits by 30 percent or more for electricity used as a transportation fuel. C.The Proposed “Pilot” Program is too Cautious. The following is a summary of the proposed strategy to potentially deploy one electric bus: Authorize staff to work with the Federal Transit Administration (FTA) Office of Innovation, FTA Region 9 Office, and Gillig, LLC for the procurement of one 40-foot electric propelled bus from Gillig, LLC under the FTA’s Prototype Waiver Program that would be produced in December 2018, and placed into revenue service in January 2019. This proposal does not reflect the environmental ambitions and thoughtful nature of a city like Santa Monica. First, why would BBB limit its work on electric buses to one company? There should be some process to allow all electric bus manufacturers to compete to bring the best technology to Santa Monica. Second, it concerns us that the program is contingent on FTA’s prototype waiver program. At least on first blush it appears that a simple battery electric bus would not even qualify for this prototype waiver program, which is designed for buses that are not deployed in transit applications. Electric buses have turned the corner of prototype, and we think its important for the City of Santa Monica to acknowledge and embrace the current state of the technology. Third, why is the program limited to one bus? Entities across the country are deploying multiple buses, and Santa Monica should commit to deploying more buses. To more fully meet the need to convert the fleet to electric buses, Santa Monica should do the following: 1)Set a near-term goal of 5-20 buses deployed using the best technology through a competitive process. 2)While buses are being procured, the City Council should direct staff to develop an infrastructure plan that seeks to act quickly to avail itself of Southern California Edison’s investments given that natural gas fueling interests and others have 1 Incidentally, your current fuel provider, Clean Energy Fuels, participated in this proceeding and advocated for significantly reducing the total budget that Southern California Edison could use for electrical charging infrastructure, which according to the most recent filing of the California Transit Associations could negatively impact transit agencies in getting necessary charging infrastructure. Item 4-A 4/24/18 78 of 80 Item 4-A 4/24/18 Electric Bus Letter 4/23/2018 P a g e | 5 aggressively advocated to reduce the pot of funding for charging infrastructure for agencies like Santa Monica. 3)The City should work with Jobs to Move America and other groups to make sure that as we make this necessary transition, we ensure the creation of good jobs. Conclusion Other transit agencies in the state and across the country are bypassing Santa Monica BBB with commitments to truly zero emissions transportation. Now is the time for our leaders in Santa Monica to get serious about shifting to electric buses, instead of the half measures and unnecessarily slow approaches that were outlined in the staff report. We believe Santa Monica should not wait to be forced into action by state regulation, losing environmental and economic development benefits, as well as funding opportunities along the way. We believe Santa Monica can and must beat the state deadline and seek to transition to all electric buses by 2030 in order to remain a strong leader on air quality and climate change solutions. We also believe Santa Monica should make the same bold commitments that LA Metro and LA DOT made regarding powering their bus fleets with clean energy sources; prioritizing electrification in environmental justice communities; and using the U.S. Employment Plan to incentivize EV bus manufacturing in the state and U.S. This will require immediate and decisive action, a real infrastructure and vehicle deployment strategy, and most importantly, political leadership. Our organizations stand ready to help BBB and the City of Santa Monica take the required actions to achieve these goals, and are happy to work closely with staff to make BBB the environmental leaders Santa Monica residents, BBB users, and the region deserves. Sincerely, Adriano L. Martinez Earthjustice Michelle Kinman Environment California Alex Nagy Food and Water Watch Jennifer Kropke IBEW Local Union 11 Erika Thi Patterson Jobs to Move America Item 4-A 4/24/18 79 of 80 Item 4-A 4/24/18 Electric Bus Letter 4/23/2018 P a g e | 6 Carter Rubin Mobility and Climate Advocate Healthy People & Thriving Communities Program Natural Resources Defense Council Carlo De La Cruz Sierra Club cc: Rick Cole, Santa Monica City Manager, rick.cole@smgov.net Item 4-A 4/24/18 80 of 80 Item 4-A 4/24/18 Council Meeting April 24, 2018 Comparative Green Fleet Analysis & Recommended Electric Bus Tr ansition Plan For Council Consideration 2 •Provide guidance to staff on future implementation of BBB vehicle propulsion technology •Provide feedback regarding proof of concept program to evaluate operational effectiveness and efficiency of a sub-fleet of up to 10 battery electric buses and requisite BBB yard infrastructure •Authorize staff to work with the FTA and Gillig, LLC to procure one 40-foot electric-propelled bus from Gillig, LLC, to be produced in December 2018 and placed into revenue service in January 2019 •BBB Facility: 1660 7th Street •11 -acre facility housing 200 buses and 7 Dial-a-Ride vehicles •Maintenance facility, administrative functions, fueling and wash bays, bus yard, and staff parking •RNG fuel storage: 56,000 US gal. for average daily fuel consumption of 12,000 gal. •Operations •13.6 million passengers annually •Service area of 58 square miles •During peak service Monday-Friday, BBB operates 240 daily assignments with 167 buses in service BBB’s Existing Operations and Fleet Composition 3 •Entire fleet fueled by renewable natural gas (RNG) •62.5 % compressed natural gas (CNG) •37.5 % liquefied natural gas (LNG) •All LNG buses will be retired by 2019BBB’s Existing Fleet (Baseline)Ty pe of Bus # of Buses 30-35 foot 19 40-foot 153 60-foot 28 TOTAL 200 4 •Comparative analysis assessing economic and environmental benefits of transitioning BBB’s fleet to green alternative technologies between 2018 –2040 •Full transition to either of tw o alternatives by 2030 (1)Near-zero emission NOx natural gas buses (2)Battery electric buses •Ti meframe aligns with California Air Resources Board’s (ARB) proposed Innovative Clean Tr ansit Regulatory timeframe •With rapidly changing technology, study uses best available data at this time Study Purpose 5 •ARB Advanced Clean Tr ansit regulation renamed to Innovative Clean Tr ansit (ICT) •Proposed timeline of mandate •Achieve zero-emission transit in California by 2040 •ARB’s draft regulatory language is anticipated for review Spring 2018 and adoption June 2018 ARB ICT Regulation 6 •NZE NOx buses would keep fueling with RNG •NZE Nox technology primarily reduces tailpipe emissions •First engine to meet ARB’s optional NOx emission standard •90% lower NOx emissions than ARB’s current standard for heavy-duty engines •BBB receiving 20 new NZE NOx buses in October 2018 Alternative 1: Near-Zero Emission (NZE) NOx Natural Gas Buses 7 •Zero emissions •Fueled with 100% renewable electricity •Dependent on BBB’s continued procurement of renewable electricity •Feasibility: ~450 kWh battery pack provides range of approx. 150 miles at year 6 and 125 miles at year 12 •7% of BBB’s weekday assignments > 140 miles •On average, 80% of BBB bus travel <120 miles/day Alternative 2: Battery Electric Buses (BEB) 8 Fleet Transition Analysis •Fleet-wide costs and emissions were evaluated over the anticipated ICT regulatory timeframe (2018-2040) •BBB’s existing fleet is the baseline for the tw o alternative scenarios •Assumptions •BBB’s actual retirement schedule extrapolated over timeframe •Tr ansition of the entire fleet (200 buses) would occur in 2029/30 •No fleet growth during timeframe 9 •Replacement schedules are identical Fleet Tr ansition Analysis 10 Emissions Analysis: Methodology •Ty pes of analyses •Well-to-Ta nk (WTT): emissions from fuel extraction to production •Ta nk-to-Wheel (TTW): tailpipe emissions from combustion of fuel •(TTW emissions are likely the target of ARB’s regulations.) •Well-to-Wheel (WTW): combination of WTT and TTW emissions •Measured Outputs •Greenhouse Gas (GHG) •NOx •PM10 11 Cost Analysis: Methodology •Costs were analyzed across four time periods: 2017, 2020, 2025, 2030+ •Cost Factors •Capital •Fuel Cost & Fuel Use •O&M •Infrastructure and Facility Modifications •Midlife Overhaul •Assumptions •Annual mileage: 32,250 •Useful life: 12 years 12 •NZE NOx fleet will reduce GHG emissions by 12% •BEB fleet will reduce GHG emissions by 68%, as long as BBB continues to procure 100% renewable electricity Fleet Tr ansition Analysis: GHG Emissions 13 •BEB will reduce GHG emissions by 26%, using CA average grid mix estimates Fleet Tr ansition Analysis: GHG Emissions 14 Fleet Tr ansition Analysis: NOxEmissions •NZE NOx fleet will reduce TTW NOx emissions by 63% •BEB will reduce TTW NOx emissions by 68% 15 •Tr ansitioning BBB’s existing fleet to a NZE NOx fleet will not significantly change TTW PM10 emissions •Tr ansitioning BBB’s existing fleet to a BEB fleet will reduce TTW PM10 emissions by 68% (approx. 1.0 ton)Fleet Tr ansition Analysis: PM10Emissions 16 •BBB’s existing CNG fleet provide lowest operational costs ($2.789/mile) Cost Analysis: Per Mile Operating Costs 17 Cost Analysis: Lifecycle Costs per Bus NZE NOx NG Bus 2017 BEB 2030 BEB Incremental Lifecycle Costs Compared to Baseline $15,480 $489,555 $229,491 18 •Costs increase under both scenarios Cost Analysis: Entire Fleet Fleet Transition Analysis –2018-2040 Fleet Type BBB Existing (Baseline) NZE NOx Emission NG Battery Electric Bus Capital and Operational Costs $413,748,150 $417,803,910 $492,001,711 Difference from Baseline $4,055,760 $78,253,561 19 Emission Reduction Cost Effectiveness 2018-2040 NZE NOx NG Fleet BEB Fleet Relative to Baseline Incremental Cost Increase $4,055,760 $78,253,561 GHG Reduction (metric tons) 26,724 148,755 WTW NOx Reduction (tons) 56.8 563.9 TTW NOx Reduction (tons) 60.1 65.1 Cost- Effectiveness1 GHG ($/metric ton)$152/MT $526/MT WTW NOx ($/ton)$71,404/ton $138,772/ton TTW NOx ($/ton)$67,484/ton $1,202,052/ton 1 Assumes that 100% of cost increase attributed to each pollutant 20 •FTA LoNo Grant –Zero Emission/Low Emission Tr ansit Buses & Facilities •Hybrid & Zero Emission Tr uck & Voucher Incentive Program (HVIP) •$110,000 per bus •Caltrans –Tr ansit & Intercity Rail Capital Program (TIRCP) •BBB has an application for 10 zero emission buses •Metro Bus Operations Subcommittee (BOS 15%) •$17M annually, competitive for municipal operators •CPUC/SCE –Medium-and Heavy-duty vehicle charging infrastructure Funding Opportunities 21 Context for All-Electric Fleet Conversion Agencies in the region that have committed to all-electric fleets by 2030: •LA Metro –100 zero emission vehicles on order •LADOT –4 zero emission vehicles on the road; 25 more ordered •Foothill Transit –30 zero emission buses; 14 in regular service •Long Beach Tr ansit –10 zero emission vehicles on the road •AV TA –10 zero emission buses on the road; committed to 85-bus battery electric fleet by end of 2019 22 Study done in June 2017 on Foothill Tr ansit buses compared performance of Proterra battery electric buses vs. Foothill's NABI CNG buses •Proterra Battery Electric Bus Performance •12 BEBs studied averaged more than 6,000 miles betw een road calls (surpassing target of 4,000) in 900,000+ miles •On-route chargers operated reliably with minimal issues •High voltage batteries showed little to no sign of capacity degradation •Tr ade-offs •BBB’s LNG and CNG fleet average 18,000+ MBRC •On-route charged buses had shorter range •Range decreases in summer when using HVAC system •Charger availability needed for successful vehicle deployment •Albuquerque &Long Beach have had delayed BEB deliveries from vendors, delaying project launches Context for All-Electric Fleet – Existing Study 23 •Ya rd / Facilities Site Feasibility Assessment •Duel fueled fleet complexity •Route Specific Energy Analysis •Tr aining Staff on New Technology •In-Depth Infrastructure Engineering Study with SCE •With Southern California Edison •Continue to Monitor Electric Bus Technology and Costs •Operational feedback from the industry •Work with OEMs on vehicle evaluations Next Steps 24 •LA Regional Electric Bus Group •Work with peers for implementation solutions •Zero Emission Bus Procurement Committee •State-wide collaborative effort to develop options to buy buses from state procurements •Continue to apply for existing and new grants •To fund proof of concept project for up to 10 new electric buses Challenges and Opportunities 25 For Council Consideration •Provide guidance to staff on future implementation of BBB vehicle propulsion technology •Provide feedback regarding proof of concept program to evaluate operational effectiveness and efficiency of a sub-fleet of up to 10 battery electric buses and requisite BBB yard infrastructure •Authorize staff to work with the FTA and Gillig, LLC to procure one 40-foot electric-propelled bus from Gillig, LLC, to be produced in December 2018 and placed into revenue service in January 2019 26