Transit
Prepared by CCT with support from CTE
1 Table of Contents
List of Tables.......................................................................................................................................................... 3 List of Figures......................................................................................................................................................... 3 List of Abbreviations.............................................................................................................................................. 4 Executive Summary ............................................................................................................................................... 5 A Transit Agency Information ...............................................................................................................................6 CCT Profile.................................................................................................................................................................6 Service Area and Bus Service ...............................................................................................................................6 Ridership ..............................................................................................................................................................7 CCT Basic Information...............................................................................................................................................8 CCT Sustainability Goals..........................................................................................................................................10 B Rollout Plan General Information ..................................................................................................................... 11 Overview of the Innovative Clean Transit Regulation.............................................................................................11 CCT Rollout Plan General Information ....................................................................................................................11 Additional Agency Resources..................................................................................................................................12 C Technology Portfolio......................................................................................................................................... 13 ZEB Transition Technology Selection.......................................................................................................................13 Local Developments and Regional Market ........................................................................................................13 D Current Bus Fleet Composition and Future Bus Purchases................................................................................ 14 Fleet Assessment Methodology ..............................................................................................................................14 ZEB Cost Assumptions.............................................................................................................................................14 Description of CCT Current Fleet.............................................................................................................................15 Fleet ...................................................................................................................................................................15 Routes and Blocks..............................................................................................................................................15 Current Mileage and Fuel Consumption ............................................................................................................15 Zero-Emission Bus Procurement Plan and Schedule ...............................................................................................16 Additional Considerations.......................................................................................................................................17 E Facilities and Infrastructure Modifications........................................................................................................ 19 CCT Facility Configuration and Depot Layout .........................................................................................................19 Facilities Assessment Methodology ........................................................................................................................19 Infrastructure Upgrade Requirements to Support Zero-Emission Buses.................................................................20 Description of Depot Fueling Infrastructure Considered.........................................................................................20 BEB Charging Infrastructure Summary .............................................................................................................20 FCEB Fueling Infrastructure Summary ..............................................................................................................20 Prepared by CCT with support from CTE
2 F Providing Service in Disadvantaged Communities............................................................................................ 22 Providing Zero-Emission Service to DACs................................................................................................................22 Map of Disadvantaged Communities served by CCT ..............................................................................................23 Emissions Reductions for DACs...............................................................................................................................23 Estimated Ridership in DACs...................................................................................................................................25 G Workforce Training........................................................................................................................................... 26 CCT ZEB Training Plan .............................................................................................................................................26 OEM Training .....................................................................................................................................................26 Bus and Fueling Operations and Maintenance .............................................................................................26 ZEB Training Programs.......................................................................................................................................26 H Potential Funding Sources ................................................................................................................................ 28 Available Funding Opportunities.............................................................................................................................28 Federal ...............................................................................................................................................................28 State ...................................................................................................................................................................28 Local ...................................................................................................................................................................29 I Start-up and Scale-up Challenges....................................................................................................................... 30 Financial Challenges................................................................................................................................................30 Limitations of Current Technology..........................................................................................................................30 Appendix A – Approved Board Resolution ........................................................................................................... 31 Appendix B – Glossary ......................................................................................................................................... 32 Prepared by CCT with support from CTE
3 List of Tables
Table 1 - Fleet Assessment Cost Assumption ...................................................................................................................14 Table 2 - CCT Bus Capital Investment to Transition to a 100 % ZEB Fleet by 2040 ......................................................17 Table 3 - CCT Estimated Ridership in DACs....................................................................................................................25 List of Figures
Figure 1 - CCT Service Area ...........................................................................................................................................7 Figure 2 - CCT Jillson Depot Aerial Photo .......................................................................................................................9 Figure 3 – Rendering of Future Sheila St Depot .............................................................................................................10 Figure 4 - Projected Bus Procurements for ZEB Transition...............................................................................................16 Figure 5 - Annual Fleet Composition, ZEB Transition ......................................................................................................17 Figure 6 - Infrastructure Projects & Costs, ZEB Transition...............................................................................................21 Figure 7 - CCT Disadvantaged Communities Service Map..............................................................................................23 Prepared by CCT with support from CTE
4 List of Abbreviations
ADA: Americans with Disabilities Act
A&E: Architecture and Engineering
BEB: Battery Electric Bus
CA: California
CARB: California Air Resources Board
CNG: Compressed Natural Gas
COVID/COVID-19: Coronavirus Disease 2019 (SARS-CoV-2)
CTE: Center for Transportation and the Environment
DAC: Disadvantaged Community
FCEB: Fuel Cell Electric Bus
HVAC: Heating, Ventilation, and Air Conditioning
ICE: Internal Combustion Engine
ICT: Innovative Clean Transit
kW: Kilowatt
kWh: Kilowatt-Hour
MW: Megawatt
OEM: Original Equipment Manufacturer
PM: Particulate Matter
PPI: Producer Price Index
CPI: Consumer Price Index
RFP: Request for Proposals
SCE: Southern California Edison (SoCal Edison)
TDA: Transportation Development Act
VTT: Verification of Transit Training
ZEB: Zero-Emission Bus
A glossary of useful terms can also be found in Appendix B – Glossary Prepared by CCT with support from CTE
5 Executive Summary
City of Commerce Transit Service (CCT or the City) provides public transit services for the community in and around the city of Commerce in Los Angeles County, operating 6 fixed routes in the city, as well as Dial-A-Ride (DAR) micro transit service. CCT’s transit fleet as of 2023 consists of one (1) Compressed Natural Gas (CNG) 30’ bus, two (2) electric 30’ buses, eight (8) CNG 35’ buses, twelve (12) CNG 40’ buses, eight (8) CNG cutaways, three (3) gas cutaways, and two (2) electric cutaways.
CCT’s Rollout Plan achieves a zero-emission bus fleet in line with the 2040 target of the ICT Regulation. To achieve this goal, CCT will replace all CNG and gas buses with ZEBs when the vehicles reach the end of their useful life. CCT has committed to purchasing only ZEBs in the future and will begin by purchasing BEBs in the early years of the transition. CCT will determine the technology for later procurements based on its experience with early deployments of BEBs and observation of hydrogen infrastructure development in the area. CCT will make the decision to either continue pursuing a BEB only fleet or to add FCEBs in 2033. Regardless of the zero-emission technology path, CCT will have a fully ZEB fleet by 2035, which exceeds the ICT goal of 2040. The last of the City's CNG buses will reach end of life in 2034. The City's existing Transit Maintenance Facility (TMF) is located at 5555 Jillson Street, Commerce, CA 90040. The existing facility currently houses the transit operations, maintenance, and administration offices; however, the city is actively designing a new facility that will support the zero-emission fleet that will be located at 5926 Sheila St. Commerce CA 90040.
CCT bus service provides transportation opportunities to Disadvantaged Communities (DACs) and deploying zeroemission buses will help improve all communities in the CCT service area. The City will build upon an existing training structure for bus maintenance and operators to provide the necessary zero-emission bus (ZEB) training that will be required for the CCT to own and operate BEBs and FCEBs. The agency estimates that pursuing a ZEB fleet will cost $95M in capital and operations expenditure between 2023 and 2040, which will require significantly more funding than if they were not converting the fleet to zero-emission technologies. CCT plans to pursue funding opportunities at the federal, state, and local levels to help fill this funding gap.
Prepared by CCT with support from CTE
6 A
Transit Agency Information
CCT Profile
The City's existing Transit Maintenance Facility (TMF) is located at 5555 Jillson Street, Commerce, CA 90040. The existing facility currently houses the transit operations, maintenance, and administration offices. Approximately 202 City vehicles within the fleet, including 36 buses, facility maintenance equipment, automobiles, light trucks, and trailers, are maintained at the existing TMF. The new facility will be located at 5926 Sheila St. Commerce CA 90040 and will likely house additional vehicles. The City of Commerce, which spans approximately 6.5 square miles, is Southeast of downtown Los Angeles; the Commerce City Hall is about 5.8 miles from the Los Angeles Civic Center.
Approximately 71 percent of the city is designated for industrial and commercial land uses. Employment in the City of Commerce in 2020, the latest year for which data are available, was 54,624. The city's population in 2020 was estimated at 12,378 (CDF, 2020). CCT began in 1969 and has always operated a "fare-free" Transit and Dial-A-Ride (DAR) system. CCT operates six (6) bi-directional bus routes, three (3) within the City of Commerce. The remaining routes travel from the City of Commerce to downtown Los Angeles, the City of Bell Gardens, and Cal State University Los Angeles. Transit bus route(s) service hours are Monday- Sunday, 4:30 a.m. to 10:30 p.m.
Service Area and Bus Service
CCT public transit provides service in and around the city of Commerce, a suburban community located in Los Angeles County that is predominantly classified as disadvantaged by CalEnviroScreen standards. The City of Commerce operates a system that provides services on 6 fixed routes, three of which are entirely within the city limits while the other three provide connection to other transit systems. The current bus fleet consists of 23 buses and 13 cutaways.
In addition to fixed-route service, CCT provides dial-a-ride (DAR) service. This service is provided for Seniors who are 60 and older; persons with disabilities; and persons certified under the Americans with Disability Act (ADA), as well as non-ADA riders. Unlike fixed-route service, the DAR service does not run a set route, and so a single vehicle may provide trips both within and outside of a DAC during a single day. The DAR fleet consists of 13 cutaway vehicles.
CCT service map is illustrated in Figure 1.
Prepared by CCT with support from CTE
7 Figure 1 - CCT Service Area
Ridership
Annual system-wide ridership is approximately 875,622. The City's DAR service operates Monday-Friday from 8:00 a.m. to 5:00 p.m.; the annual ridership is approximately 50,000.
The Southeast region of Los Angeles is gridlocked during peak hours and congested most of the day. Providing reliable transit services to reduce single-occupancy automobile trips is essential to the region's health, economic sustainability, job access, access to schools and medical trips, and overall livability. The City of Commerce plans to update its bus fleet with zero-emission vehicles which will be critical to first-and-last mile connectivity to Metrolink connections and additional corridor service in the region, to reduce automobile dependency, encourage the use of alternative modes of transportation, reduce harmful emissions, and improve the lives of the people it serves.
Prepared by CCT with support from CTE
8 CCT Basic Information
Transit Agency’s Name: City of Commerce Transit Service Mailing Address: 5555 Jillson Street, Commerce, CA 90040 Transit Agency’s Air Districts: CCT is part of the South Coast Air Quality Management District (SCAQMD).
Transit Agency’s Air Basin: South Coast Air Basin
Total number of buses in Annual Maximum Service:
Urbanized Area: Approximately 6.5 square miles
Population of Urbanized Area: The City's population in 2020 was estimated at 12,378 (CDF, 2020) Contact Information for Inquiries on the CCT ICT Rollout Plan:
Contact name and title: Greg Guzman, Fleet Maintenance Manager Depot address: 5555 Jillson Street, Commerce, CA 90040
Tel: (323) 887-4419
Contact Email: [email protected]
Is your transit agency part of a Joint Group? No
Prepared by CCT with support from CTE
9 Fleet Facility
Figure 2 - CCT Jillson Depot Aerial Photo
The City's existing Transit Maintenance Facility (TMF) is located at 5555 Jillson Street, Commerce, CA 90040, approximately 0.5-mile northwest of the project site for the agency’s planned new facility at 5926 Sheila St.
Commerce CA 90040. The existing facility currently houses the transit operations, maintenance, and administration offices; however, the new facility will be better designed for accommodating the ZEB fleet. The City of Commerce plans to spend around $120M in building out the new facilities. Chargers to support early BEB deployments may be moved to the new facility when it is completed. If CCT will pursue FCEBs in later years, the new facility will be equipped with hydrogen detection equipment in the maintenance bays. A rendering of the new facility can be seen below.
Prepared by CCT with support from CTE
10 Figure 3 – Rendering of Future Sheila St Depot
CCT Sustainability Goals
California’s plan to address public health, air quality and climate protection goals includes the Innovative Clean Transit (ICT) regulation, which aims to reduce greenhouse gas (GHG), nitrogen oxide (NOx), and diesel particulate emissions, with which, CCT will be compliant at the conclusion of this project. To accomplish its sustainability goals, CCT is working to replace its CNG and gasoline fleet with 100% zero-emission vehicles by 2040 in accordance with ICT regulations.
CCT has developed a plan to transition to a fully zero emission bus (ZEB) fleet by 2040, in accordance with the Innovative Clean Transit (ICT) regulation, requiring all California transit agencies to follow zero-emission procurement guidelines with the goal of achieving 100% zero-emission fleets by 2040. CCT has committed to purchasing zero emission buses, demonstrating the agency’s commitment to reducing emissions. CCT’s transition to a fully ZEB fleet will ultimately benefit communities through cleaner air, greater independence from fossil fuels, and more environmental sustainability.
Prepared by CCT with support from CTE
11 B
Rollout Plan General Information
Overview of the Innovative Clean Transit Regulation
On December 14, 2018, CARB enacted the Innovative Clean Transit (ICT) regulation, setting a goal for California public transit agencies to have zero-emission bus fleets by 2040. The regulation specifies the percentage of new bus procurements that must be zero-emission buses for each year of the transition period (2023–2040). The annual percentages for Small Transit agencies are as follows:
ICT Zero-Emission Bus Purchase Requirements for Small Agencies:
January 1, 2026 - 25% of all new bus purchases must be zero-emission January 1, 2027 - 25% of all new bus purchases must be zero-emission January 1, 2028 - 25% of all new bus purchases must be zero-emission January 1, 2029+ - 100% of all new bus purchases must be zero-emission March 2021-March 2050 – Annual compliance report due to CARB This purchasing schedule guides agency procurements to realize the goal of zero-emission fleets in 2040 while avoiding any early retirement of vehicles that have not reached the end of their useful life (12 years for transit buses providing fixed route service and 7 years for the cutaways providing DAR service). Agencies have the opportunity to request waivers that allow purchase deferrals, at the time of procurement, in the event of economic hardship or if zero-emission technology cannot meet the service requirements of a given route. These concessions recognize that zero-emission technologies may cost more than current internal combustion engine (ICE) technologies on a vehicle lifecycle basis and that zero-emission technology may not currently be able to meet all service requirements.
CCT Rollout Plan General Information
Rollout Plan’s Approval Date:
Resolution No:
Is a copy of the approved resolution attached to the Rollout Plan? Contact for Rollout Plan follow-up questions: Greg Guzman, Fleet Maintenance Manager Tel: (323) 887-4419
Contact Email: [email protected]
Who created the Rollout Plan?
This Rollout Plan was created by the City of Commerce, with assistance from the Center for Transportation and the Environment (CTE).
This document, the ICT Rollout Plan, contains the information for CCT zero-emission fleet transition trajectory as requested by the ICT Regulation. It is intended to outline the high-level plan for implementing the transition. The Rollout Plan provides estimated timelines based on information on bus purchases, infrastructure upgrades, workforce training, and other developments and expenses that were available at the time of writing.
Prepared by CCT with support from CTE
12 Additional Agency Resources
CCT agency website: https://www.ci.commerce.ca.us/city-hall/transportation Prepared by CCT with support from CTE
13 C
Technology Portfolio
ZEB Transition Technology Selection
CCT plans to transition its fleet to either a fully BEV fleet or a mix of BEV and FCEV buses and cutaways. As part of CCT’s 2023 Low-No application, the agency put forth a plan to transition to a fully electric fleet. Given the length of the agency’s blocks, which are just over 100 daily miles at most for fixed route buses, BEBs will likely have sufficient range to meet the agency’s service requirements without on-route charging. However, the city is interested in hydrogen fuel cell technology and the extended range and flexibility these vehicles can offer and plans to monitor developments in the industry to inform the decision of whether or not to pivot their transition strategy to include FCEBs around 2033. For this reason, the fuel type of purchases from 2033 onward was not specified beyond a commitment to zero-emission technology. By 2040, CCT expects to operate a fully zero-emission fleet of 39 transit vehicles.
Local Developments and Regional Market
California has become a global leader for zero-emission buses, as well as the zero-emission fuel and fueling infrastructure required to support these vehicles. California is home to several bus OEMs that manufacture zeroemission buses. Although three of these OEMs do not currently build FCEBs, growing demand for this vehicle technology may encourage these manufacturers to enter the market.
The state legislature has fostered growth in zero-emission fuels through the state’s Low-Carbon Fuel Standard (LCFS) program, which incentivizes the consumption of fuels with a lower carbon intensity than traditional combustion fuels and through funding opportunities offered by CARB and CEC. The state’s electrical utility companies have also supported the transition to ZEB technology by offering incentive programs for heavy duty EV charging infrastructure and service upgrades. California BEB deployments represent 37% of the nation’s BEB deployments. 1 California also has one of the most mature hydrogen fueling networks in the nation. The state’s hydrogen market has developed to support the growing number of fuel cell electric vehicles on the roads in the state. California has at least seven heavy-duty and transit-operated fueling stations in operation and at least nine more in development.
Additionally, the number of hydrogen production and distribution centers is growing to meet increased hydrogen demand as it gains popularity as a transportation fuel. California FCEB deployments represent 75% of the nation’s FCEB deployments.6
1 CALSTART. 2021. THE ADVANCED TECHNOLOGY TRANSIT BUS INDEX: A NORTH AMERICAN ZEB INVENTORY REPORT. https://calstart.org/wp-content/uploads/2022/01/2021-ZIO-ZEB-Final-Report_1.3.21.pdf Prepared by CCT with support from CTE
14 D
Current Bus Fleet Composition and Future Bus
Purchases
Fleet Assessment Methodology
CCT has developed a timeline for the replacement of existing buses with ZEBs. The timeline is consistent with CCT fleet replacement plan that is based on the twelve-year service life of transit buses and seven-year service life of cutaways. This assessment also includes a projection of fleet capital costs over the transition timeline.
ZEB Cost Assumptions
CTE and CCT developed cost assumptions for future bus purchases. Key assumptions for bus costs for the CCT Transition Plan are as follows:
● Configurable option pricing is included. An estimated $184k for buses and $89k for cutaways was provided by CCT for this expense.
● Capital vehicle costs are derived from 2023 industry average pricing of national state contracts and tax (10.25%). Fuel Cell Cutaway pricing is a price estimation due to lack of market information. ● Costs for retrofits or bus conversions are not included. Procurements assume new vehicle costs.
Table 1 - Fleet Assessment Cost Assumption
Fuel Type
Length Electric Fuel Cell^
Cutaway $402,000 $478,000*
30’ $993,000 $1,258,000*
35’ $1,207,000 $1,543,000
40’ $1,275,000 $1,543,000
^Fuel Cell vehicle pricing was assumed for vehicles that were unspecified ZEB technology *Bus size not currently available for this technology
Prepared by CCT with support from CTE
15 Description of CCT Current Fleet
Fleet
As of 2022, the CCT bus fleet includes eight (8) CNG cutaways, three (3) gas cutaways, and two (2) electric cutaways used for DAR paratransit service and one (1) Compressed Natural Gas (CNG) 30’ bus, eight (8) CNG 35’ buses, and twelve (12) CNG 40’ buses used for fixed-route service with two (2) additional BEBs expected in 2023. CCT also plans to expand the fleet by 2 more BEBs in 2024. Bus services operate out of one depot in Commerce, CA. Operations, maintenance, and fueling functions are performed at an offsite facility in Ontario, CA.
Routes and Blocks
CCT operates 6 fixed routes as shown in Figure 1, as well as micro transit on-demand service. Buses are assigned to blocks in two shifts, a morning and an afternoon shift. Buses return to the depot for 0-60 minutes for a total daily milage of 90-134 miles.
Current Mileage and Fuel Consumption
Annual mileage of the fleet: In FY21-22, CCT’s vehicles travelled 444,629 miles in service and 474,200 miles total.
Annual fuel consumption: 137,294 GGE (CNG and Gasoline)
Prepared by CCT with support from CTE
16 Zero-Emission Bus Procurement Plan and Schedule
CCT will provide demand response service with a fleet of thirteen (13) zero emission cutaways. Fixed route service will be performed by 30’, 35’ and 40’ ZEBs. CCT’s fleet transition strategy is to replace their CNG and gas vehicles with battery electric vehicles until 2033, at which point they may switch to purchasing fuel cell vehicles, which will allow them to respond to changes in the zero-emission vehicle market. It is assumed that a portion of the zero emission vehicles procured after 2033 will be fuel cell, but the number is yet to be determined. Figure 4 below provides the number of each bus type that will be purchased each year through 2040 with this replacement strategy and the total cost of that procurement. The price for the undetermined zero emission vehicles is assumed to be the price for fuel cell vehicles to prepare CCT for the most conservative funding needs.
Figure 4 - Projected Bus Procurements for ZEB Transition Figure 5 demonstrates the annual composition of CCT fleet through 2040. By 2040, CCT bus fleet will consist entirely of ZEBs. The fleet will increase by two buses in 2024 with the purchase of two additional 35’ electric buses and then will remain the same size throughout the transition period.
Prepared by CCT with support from CTE
17 Figure 5 - Annual Fleet Composition, ZEB Transition
As seen Table 2 the capital investment required for purchasing ZEBs is around $85M over the period from 2023- 2040, which is significantly higher than for CNG buses. This highlights the importance of staying vigilant in the search for funding opportunities to help fill this gap.
Table 2 - CCT Bus Capital Investment to Transition to a 100 % ZEB Fleet by 2040 Total Investment
Bus Capital Costs $85 M
Additional Considerations
When purchasing ZEBs, the process may differ slightly from the process CCT currently uses to purchase vehicles.
First, when contracting with ZEB manufacturers, CCT will ensure expectations are clear between the bus OEM and the City. As with CNG purchases the agreement should be clear regarding the bus configurations, technical capabilities, build and acceptance process, production timing with infrastructure, warranties, training, and other contract requirements. Additionally, by developing and negotiating specification language collaboratively with the bus vendor(s), CCT can work with the vendor(s) to customize the bus to their needs as much as is appropriate, help advance the industry based on agency requirements and recommended advancements, ensure the acceptance and payment process is fully clarified ahead of time, fully document the planned capabilities of the bus to ensure accountability, and generally preempt any unmet expectations. Special attention will be given in defining the technical capabilities of the vehicle, since defining these for ZEBs may differ from ICE buses.
When developing RFPs and contracting for ZEB procurements, CCT will specify the source of funding for the vehicle purchases to ensure grant compliance, outline data access requirements, define the price and payment terms, establish a delivery timeline, and outline acceptance and performance requirements. CCT will test the buses upon delivery for expected performance in range, acceleration, gradeability, highway performance, and maneuverability.
Any such performance requirements must be included in the technical specification portion of the RFP and contract to be binding for the OEM. Defining technical specifications for ZEBs will also differ slightly from their current CNG vehicles since they will need to include requirements for hydrogen fuel cell and battery performance. It is also recommended that CCT purchase an extended battery warranty for the vehicles, which should be specified in the RFP and contract.
Prepared by CCT with support from CTE
18 FCEB procurement will also differ from ICE procurements since there are fewer OEMs presently manufacturing these vehicles, although this is expected to change with increasing demand. CCT will also be able to apply for additional funding for these vehicles through zero-emission vehicle specific funding opportunities, which are discussed further in which are discussed further in Section H.
Prepared by CCT with support from CTE
19 E
Facilities and Infrastructure Modifications
CCT Facility Configuration and Depot Layout
Depot Address: Current: 5555 Jillson Street, Commerce, CA 90040 The City plans to move to a new facility at 5926 Sheila St. Commerce CA 90040 by 2033. Charging infrastructure installed at the current facility may be moved to the new facility. Costs associated with re-installation are not included.
Electric Utility:
Southern California Edison (SCE)
Located in a NOx Exempt Area?
No
Bus Parking Capacity:
Approximately 202 fleet vehicles, including 36 buses, facility maintenance equipment, automobiles, light-duty trucks, and trailers
Parking capacity at the new facility is unknown at this time Current Vehicle Types Supported:
Gasoline and CNG
Propulsion Types That Will be Supported at Completion of ZEB Transition:
Battery electric and possibly hydrogen fuel cell electric propulsion Facilities Assessment Methodology
BEB deployments require installation of charging stations and improvements to existing electrical infrastructure.
FCEB deployments require installation of a fueling station and may require improvements such as upgrades to the switchgear or utility service connections. Planning and design work, including development of detailed electrical and construction drawings required for permitting, is also necessary once specific fueling equipment has been selected. Since it is likely that CCT will pursue FCEBs in later years of the transition, the cost of a hydrogen fueling station was included in this assessment.
Building off of the fleet procurement schedule that was outlined in the Fleet Assessment, CTE then uses industry average pricing to develop infrastructure scenarios that estimate the cost of building out the infrastructure necessary to support a full fleet transition to ZEBs. This plan assumes that infrastructure projects will be completed prior to each bus delivery although costs are shown in the year the buses are expected to arrive. To project the costs of fueling infrastructure, CTE used industry pricing based on project experience and an infrastructure build timeline based on the procurement timeline. These projects are described in detail below.
Prepared by CCT with support from CTE
20 Infrastructure Upgrade Requirements to Support Zero-Emission Buses Description of Depot Fueling Infrastructure Considered
Since CCT plans to monitor ZEB technology developments and will start down the path to zero-emission by pursuing battery electric technology, charging infrastructure is required to service a total of at least 26 battery electric vehicles. If FCEVs are pursued for a mixed technology fleet, hydrogen fueling infrastructure for up to 35 fuel cell vehicles to support a completely zero-emission bus fleet by 2040. Because there are separate costs associated with each type of ZEB technology, the facilities assessment for this scenario is broken down by each fuel type. The total cost for mixed fleet fueling infrastructure is approximately $10.5M. Note that charging infrastructure installed at the current facility may be moved to the new facility. The new facility will be designed with sufficient electrical capacity for the existing chargers and any planned additions.
BEB Charging Infrastructure Summary
In order to support the BEB portion of the fleet, CCT will need to work with a contractor to conduct detailed infrastructure planning, purchase chargers and dispensers, and add service capacity to their site. The estimated infrastructure costs for these technology & infrastructure expenses are as follows:
● INFRASTRUCTURE PLANNING. Building charging infrastructure requires planning at the depot. This assessment assumes that a planning project costs $200,000 and occurs only once per depot. The total cost of planning projects for CCT’s depot is estimated at $200,000.
● DISPENSERS AND CHARGERS. CCT’s BEB charging depot will consist of eight chargers with two dispensers per charger for full size buses and ten level 2 chargers with one dispenser each. Prices are estimated at $120,000 for a 150kW charger with two dispensers at around $10,000 each. With contingency, this assumes equipment costs of nearly $200,000 per charger. Level 2 chargers are estimated at $3,000 per charger, which includes contingency and installation costs.
● ELECTRIC SERVICE UPGRADE. CCT requires an estimated 2 MW of additional electricity capacity by 2040 to accommodate charging for 26 BEBs. To meet the growing demand for electricity, the depot will need to upgrade its system to at least 2 MW of capacity by 2040. This is estimated to cost around $552k over the transition period.
The estimated total BEB infrastructure cost for CCT is shown below in Figure 5. The costs for charging equipment totals approximately $2.3M over the transition period.
FCEB Fueling Infrastructure Summary
As previously discussed, City of Commerce will likely pursue FCEBs beginning in 2033, but plans to see how the market plays out before committing to the technology. Assuming they do pursue FCEBs, they will need to acquire hydrogen fueling equipment in order to operate these vehicles. Like BEB infrastructure, a FCEB infrastructure deployment will also require hiring an infrastructure planning contractor. Hydrogen storage and fueling equipment will also be a required capital project for a hydrogen station build to allow CCT to fuel their hydrogen fuel cell vehicles on site. Infrastructure is assumed to be built out in one project that will conclude prior to the first FCEB deployment in 2033. The estimated infrastructure costs for these technology & infrastructure expenses are as follows:
● INFRASTRUCTURE PLANNING. Building hydrogen infrastructure requires planning at the depot. This assessment assumes that a planning project costs $200,000 and occurs only once per depot. The total cost of planning projects for CCT single depot will be approximately $200,000. ● MAINTENANCE BAY UPGRADES. Maintenance bay upgrades are not included in CCT costs since they plan to build a new facility and will design the bays to be hydrogen maintenance compliant as part of that build.
Prepared by CCT with support from CTE
21 ● HYDROGEN FUELING INFRASTRUCTURE. CCT fueling solutions were projected based on fuel consumption needs and approximately right-sized. Hydrogen infrastructure maintenance and operations are covered in the price of fuel in the fuel assessment. CCT’s hydrogen depot is estimated to cost $7.8 M.
Figure 6 shows the estimated infrastructure costs for the FCEB technology with shared hydrogen infrastructure, totaling to approximately $8 M.
Figure 6 - Infrastructure Projects & Costs, ZEB Transition Utility Partnership Review
The City of Commerce is working with the Utility provider, Southern California Edison (SCE) who currently serves the yard where the buses are stored and charged. SCE has been active in sharing information related to its EV rates and incentives offered and the CCT is aware that taking advantage of these benefits and ensuring a successful battery electric bus deployment requires close, ongoing coordination with SCE. The City will stay in contact with SCE and will share electrification plans as they evolve to help the utility understand future loads so that any required grid infrastructure improvements can be addressed prior to implementation. CCT recognizes SCE as a critical partner in electrification and will continue to partner with SCE after the planning stages so that charge management strategies and fleet expansion efforts can be coordinated effectively.
Further, the City understands establishing and maintaining a partnership with the alternative fuel provider will be critical to successfully deploy FCEVs and maintaining operations. Hydrogen fueling requires a plan for infrastructure installation, delivery, storage, dispensing, and upgrades to maintenance facilities. CCT will stay aware of the local hydrogen supply market.
Prepared by CCT with support from CTE
22 F
Providing Service in Disadvantaged
Communities
Providing Zero-Emission Service to DACs
In California, CARB defines disadvantaged communities (DACs) as communities that are both socioeconomically disadvantaged and environmentally disadvantaged due to local air quality. Lower income neighborhoods are often exposed to greater vehicle pollution levels due to proximity to freeways and the ports, which puts these communities at greater risk of health issues associated with tailpipe emissions.2 ZEBs will reduce energy consumption, harmful emissions, and direct carbon emissions within the disadvantaged communities CCT serves. The City of Commerce includes 10 different census tracts designated as DACs. Commerce’s fixed routes that are in and pass through DACs, along with their stops are shown in Figure 6 below.
Environmental impacts, both from climate change and from local pollutants, disproportionately affect transit riders.
For instance, poor air quality from tailpipe emissions and extreme heat harm riders waiting for buses at roadside stops. The transition to zero-emission technology will benefit the region by reducing fine particulate pollution and improving overall air quality. In turn, the fleet transition will support better public health outcomes for residents in DACs served by the selected routes.
Public transit has the potential to improve social equity by providing mobility options to low-income residents lacking access to a personal vehicle and helping to meet their daily needs. In California, transit use is closely correlated with car-less households as they are five times more likely to use public transit than households with at least one vehicle.3 Although 21% of Californians in a zero-vehicle household are vehicle free by choice, 79% do not have a vehicle due to financial limitations. Many low-income people therefore rely solely on public transportation for their mobility needs.4 CCT’s current fleet of fixed route and DAR CNG buses consume136,294 Gasoline Gallons Equivalent (GGE) of fuel per year, operating for approximately 474,200 miles per year. Moving CCT fleet to zero-emission technology will help alleviate the pollution from tailpipe emissions, which will improve the health of communities impacted by NOx and particulate matter emissions and all local communities.
Access to quality transit services provides residents with a means of transportation to go to work, to attend school, to access health care services, and run errands. By purchasing new vehicles and decreasing the overall age of its fleet, CCT is also able to improve service reliability and therefore maintain the capacity to serve low-income and disadvantaged populations. Replacing ICE vehicles with zero-emission vehicles will also benefit these populations by improving local air quality and reducing exposure to harmful emissions from diesel exhaust. 2 Reichmuth, David. 2019. Inequitable Exposure to Air Pollution from Vehicles in California. Cambridge, MA: Union of Concerned Scientists. https://www.ucsusa.org/resources/inequitable-exposure-air-pollution-vehicles-california-2019 3Grengs, Joe; Levine, Jonathan; and Shen, Qingyun. (2013). Evaluating transportation equity: An inter-metropolitan comparison of regional accessibility and urban form. FTA Report No. 0066. For the Federal Transit Administration 4 Paul, J & Taylor, BD. 2021. Who Lives in Transit Friendly Neighborhoods? An Analysis of California Neighborhoods Over Time.
Transportation Research Interdisciplinary Perspectives. 10 (2001) 100341. https://reader.elsevier.com/reader/sd/pii/S2590198221000488?token=CABB49E7FF438A88A19D1137A2B1851806514EF576E9 A2D9462D3FAF1F6283574907562519709F8AD53DEC3CF95ACF27&originRegion=us-east-1&originCreation=20220216190930 Prepared by CCT with support from CTE
23 Map of Disadvantaged Communities served by CCT
Figure 7 - CCT Disadvantaged Communities Service Map
CCT operates service in a region of California that is dominantly classified as a DAC. This means that a large portion of CCT’s riders are economically and environmentally disadvantaged.
Emissions Reductions for DACs
Greenhouse gasses (GHG) are the compounds primarily responsible for atmospheric warming and include carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). The effects of greenhouse gasses are not localized to the immediate area where the emissions are produced. Regardless of their point of origin, greenhouse gasses contribute to overall global warming and climate change.
Criteria pollutants include carbon monoxide (CO), nitrogen oxides (NOx), particulate matter under 10 and 2.5 microns (PM10 and PM2.5), volatile organic compounds (VOC), and sulfur oxides (SOX). These pollutants are considered harmful to human health because they are linked to cardiovascular issues, respiratory complications, or other adverse health effects.5 These compounds are also commonly responsible for acid rain and smog. Criteria 5 Institute of Medicine. Toward Environmental Justice: Research, Education, and Health Policy Needs. Washington, DC: National Academy Press, 1999; O’Neill MS, et al. Health, wealth, and air pollution: Advancing theory and methods. Environ Health Perspect. 2003; 111: 1861-1870; Finkelstein et al. Relation between income, air pollution and mortality: A cohort study. CMAJ. 2003; 169:
Prepared by CCT with support from CTE
24 pollutants cause economic, environmental, and health effects locally where they are emitted. CARB defines DACs in part as disadvantaged by poor air quality because polluting industries or freight routes have often been cited in these communities. The resulting decrease in air quality has led to poorer health and quality of life outcomes for residents.
The transportation sector is the largest contributor to greenhouse gas emissions in the United States, accounting for more than 30% of total emissions, and within this sector, 25% of these emissions come from the medium- and heavyduty markets, yet these markets account for less than 5% of the total number of vehicles. Electrifying these vehicles can have an outsized impact on pollution, fossil-fuel dependency, and climate change. ZEBs are four times more fuel efficient than comparable new diesel buses. Better fuel efficiency means less waste when converting the potential energy in the fuel to motive power. Less waste not only means less pollution, it results in more efficient use of natural resources. By transitioning to ZEBs from diesel buses, CCT zero-emission fleet will produce fewer carbon emissions and fewer harmful pollutants from the vehicle tailpipes. Considering DACs experience significantly more pollution from harmful emissions, communities disadvantaged by pollution served by CCT fleet will therefore directly benefit from the reduced tailpipe emissions of ZEBs compared to ICE buses.
CCT operates in an area that has been historically disadvantaged, serves 25 census tracts of persistent poverty, has a high historically underrepresented population, and has borne a disproportionate share of the effects of carbonbased transit pollution. The purchase of electric buses will address past wrongs done to the community will help speed the environmental recovery process. CCT’s use of electric buses will realize a significant reduction in emissions and will bring substantial environmental, economic, and social benefits to the customers and communities that CCT serves. The area is also a certified Food Desert and transit service in the area is critical to connect the residents of the underserved community that CCT serves to food and grocery services. It will also connect residents to healthcare and educational services.
397-402; Zeka A, Zanobetti A, Schwartz J. Short term effects of particulate matter on cause specific mortality: effects of lags and modification by city characteristics. Occup Environ Med. 2006; 62: 718-725.
Prepared by CCT with support from CTE
25 Estimated Ridership in DACs
Table 3 - CCT Estimated Ridership in DACs
Justice40 Disadvantaged Community Served Actual or Estimated Annual Ridership Count Commerce, CA 950,000
East Los Angeles, CA 150,000
Bell Gardens, CA 175,000
Los Angeles, CA 275,000
Prepared by CCT with support from CTE
26 G
Workforce Training
CCT ZEB Training Plan
OEM Training
CCT plans to take advantage of trainings from the bus manufacturers and station suppliers, including maintenance and operations training, station operations and fueling safety, first responder training and other trainings that may be offered by the technology providers. OEM trainings provide critical information on operations and maintenance aspects specific to the equipment model procured. Additionally, many procurement contracts include train-thetrainer courses through which small numbers of agency staff are trained and subsequently train agency colleagues.
This method provides a cost-efficient opportunity to provide widespread agency training on new equipment and technologies.
Bus and Fueling Operations and Maintenance
The transition to a zero-emission fleet will have significant effects on CCT workforce. Meaningful investment is required to upskill maintenance staff and bus operators trained in ICE vehicle maintenance and ICE fueling infrastructure.
CCT training staff will work closely with the OEM providing vehicles to ensure all mechanics, service employees, and bus operators complete necessary training prior to deploying ZEB technology and that these staff undergo refresher training annually and as needed. CCT staff will also be able to bring up any issues or questions they may have about their training with their trainers. Additionally, trainers will observe classes periodically to determine if any staff would benefit from further training.
ZEB Training Programs
Several early ZEB adopters have created learning centers for other agencies embarking on their ZEB transition journeys. One such agency is SunLine Transit Agency, which provides service to the Coachella Valley and hosts the West Coast Center of Excellence in Zero Emission Technology (CoEZET). The Center of Excellence supports transit agency adoption, zero-emission commercialization and investment in workforce training. Similarly, AC Transit offers training courses covering hybrid and zero-emission technologies through their ZEB University program. CCT plans to take advantage of these trainings offered by experienced agencies.
There are several transit agencies within and around Los Angeles County that have successfully begun their transition to zero-emission technology. California has at least seven heavy-duty and transit-operated fueling stations in operation and at least nine more in development6
. Additionally, the number of hydrogen production and distribution centers is growing to meet increased hydrogen demand as it gains popularity as a transportation fuel. At present, there are two heavy-duty, transit-operated hydrogen fueling stations in the neighboring San Bernadino and Orange 6 Hydrogen Refueling Stations in California, California Energy Commission: https://www.energy.ca.gov/data-reports/energyalmanac/zero-emission-vehicle-and-infrastructure-statistics/hydrogen-refueling Prepared by CCT with support from CTE
27 counties within 40 miles of CCT, and two planned transit-operated hydrogen fueling stations in Los Angeles County and Pomona. In addition, private hydrogen fueling stations are in development and should be commissioned before the end of the fleet transition timeline.
In the region, Omnitrans, a public transit agency serving the San Bernadino Valley recently received $9.3 million from the Federal Transit Administration (FTA) under the FY2022 Low-No Emission Vehicle Program to develop hydrogen refueling infrastructure and launch a workforce development program. Similarly, Sunline Transit Agency has received $7.8 million to upgrade their liquid hydrogen refueling infrastructure. The presence of hydrogen fueling infrastructure projects, especially in the counties of Riverside and San Bernadino, demonstrates the feasibility of fuel cell electric technology for transit in the region. These agencies can serve as a resource for CCT to use when implementing zero-emission technology and supporting programs into their services.
Prepared by CCT with support from CTE
28 H
Potential Funding Sources
Available Funding Opportunities
Federal
CCT is exploring federal grants through the following funding programs: Federal Transit Administration’s (FTA) Urbanized Area Formula program (5307); discretionary grant programs such as the Bus and Bus Facilities (B&BF) program, Low or No Emission Vehicle Deployment Program (Low-No), and Better Utilizing Investments to Leverage Development (BUILD) grant; and other available federal discretionary grant programs. Since CCT is operated as a department in the city, rather than a transportation agency, CCT may not be an eligible recipient under all these funding opportunities, but would be interested in partnering with organizations such as Caltrans or with nearby agencies who are eligible in order to secure funding.
Annual Reliable Funding
● Federal Transportation Administration (FTA)
o Urbanized Area Formula program
o State of Good Repair Grants
o Bus and Bus Facilities Formula grants
Future Funding Opportunities
● United States Department of Transportation (USDOT)
o Better Utilizing Investments to Leverage Development (BUILD) Grants ● Federal Transportation Administration (FTA)
o Bus and Bus Facilities Discretionary Grant
o State of Good Repair Grants
o Capital Investment Grants – New Starts
o Capital Investment Grants – Small Starts
o Low-or No-Emission Vehicle Grant
o Metropolitan & Statewide Planning and Non-Metropolitan Transportation Planning ● Federal Highway Administration (FHWA)
o Congestion Mitigation and Air Quality Improvement Program through SCAG o Surface Transportation Block Grant Program through SCAG o Carbon Reduction Program
● Environmental Protection Agency (EPA)
o Environmental Justice Collaborative Program-Solving Cooperative Agreement Program State
CCT will also seek funding from state resources through grant opportunities including but not limited to Senate Bill 1 State of Good Repair (SGR), Transit and Intercity Rail Capital Program (TIRCP), Low Carbon Transit Operations Program (LCTOP) funding, the California Energy Commission’s Clean Transportation Program as well as Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP) for bus purchases when available. As with federal funding opportunities, CCT would explore partnering with eligible agencies in cases where they are not directly eligible.
Prepared by CCT with support from CTE
29 Annual Reliable Funding
● Administered by California Department of Transportation (Caltrans) o Transportation Development Act Funds
▪ Local Transportation Funds
▪ State Transit Assistance (STA)
o State of Good Repair (SB 1 funds)
o Low Carbon Transit Operations Program (LCTOP)
Future Funding Opportunities
● California Air Resources Board (CARB)
o Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP) o State Volkswagen Settlement Mitigation
o Carl Moyer Memorial Air Quality Standards Attainment Program o Cap-and-Trade Funding
o Low Carbon Fuel Standard (LCFS)
● California Transportation Commission (CTC)
o State Transportation Improvement Program (STIP)
o Solution for Congested Corridor Programs (SCCP)
o Local Partnership Program (LPP)
● California Department of Transportation (Caltrans)
o Transit and Intercity Rail Capital Program
o Transportation Development Credits
o New Employment Credit
● California Energy Commission
Local
Additionally, CCT will pursue local funding opportunities, such as toll credits, to support zero-emission bus deployment. While the aforementioned funding opportunities are mentioned by name, CCT will not be limited to these sources and will regularly assess opportunities for fiscal support for the ZEB program.
Legislation Supporting the Zero-Emission Transition
Policies and regulations supporting the transition to zero-emission are proliferating as the efforts to decarbonize the transportation sector expand. CCT is monitoring the implementation of relevant policies and legislation. With the passage of the Bipartisan Infrastructure Law and issuance of Executive Order 14008: Tackling the Climate Crisis at Home and Abroad, the federal government has set a renewed focus on zero-emission transit. CCT’s goal to deploy zero-emission vehicles supports the federal administration's priorities of renewing transit systems, reducing Greenhouse Gas emissions from public transportation, equity, creation of good paying jobs, and connecting communities. State legislation such as the Innovative Clean Transit Regulation further supports the replacement of fossil-fuel vehicles on the roads of California. Moreover, on August 25, 2022, the CARB approved the Advanced Clean Cars II Rule, requiring all new vehicles sold in California to be zero-emission vehicles (ZEVs) by 2035.
Prepared by CCT with support from CTE
30 I
Start-up and Scale-up Challenges
Financial Challenges
Challenges can arise with any new propulsion technology, its corresponding infrastructure, or in training operators and maintenance staff. Nearly all transit agencies must contend with the cost barriers posed by zero-emission technologies. The current market cost of ZEBs is between $980,000 and $1,310,000, which is about $320,000 to $650,000 more costly than traditional CNG buses. The predicted costs of zero-emission cutaways are between $300,000 and $370,000, which is about $120,000 and $200,000 more costly than traditional ICE cutaways.
Additionally, the necessary infrastructure to support these buses adds to the financial burden of transitioning to a ZEB fleet. CCT will seek financial support to cover the cost of their FCEBs from the resources discussed in Section H.
The costs of required fueling infrastructure and fueling operations for ZEB technologies pose another hurdle for transit agencies transitioning to zero-emission service. Continued financial support at the local, state and federal level to offset the capital cost of this new infrastructure is imperative. For alternative fuels such as hydrogen, financial support from state and federal grant opportunities for green hydrogen supply chains and increasing economies of scale on the production side will ultimately benefit transit agencies deploying and planning for FCEBs and BEBs.
CARB can support CCT by ensuring continued funding for the incremental cost of zero-emission buses and fueling infrastructure. Funding opportunities should emphasize proper transition and deployment planning and should not preclude hiring consultants to ensure best practices and successful deployments. The price and availability of hydrogen, both renewable and not, continue to be challenges that can be allayed by legislation subsidizing and encouraging renewable fuel production.
Limitations of Current Technology
Beyond cost barriers, transit agencies must also ensure that available zero-emission technologies can meet basic service requirements of the agency’s duty cycles. The applicability of specific zero-emission technologies will vary widely among service areas and agencies. As such, it is critical that transit agencies in need of technical and planning support have access to these resources to avoid failed deployment efforts. Support in the form of technical consultants and experienced zero-emission transit planners will be critical to turning Rollout Plans into successful deployments and tangible emissions reductions.
In addition to the uncertainty of technology improvements, there are other risks to consider in trying to estimate costs over the 17-year transition period. Although current BEB range limitations may be improved over time as a result of advancements in battery energy capacity and more efficient components, battery degradation may reintroduce range limitations, which is a cost and performance risk to an all-BEB fleet over time. While this can be mitigated by on-route charging, there may be emergency scenarios where the buses are expected to perform offroute or atypical service. In these emergency scenarios that require use of BEBs, agencies may face challenges performing emergency response roles expected of them in support of fire and police operations. Furthermore, fleetwide energy service requirements, power redundancy, and resilience may be difficult to achieve at any given depot in an all-BEB scenario. Although FCEBs may not be subject to these same limitations, higher capital equipment costs and availability of hydrogen may constrain FCEB solutions.
Prepared by CCT with support from CTE
31 Appendix A – Approved Board Resolution
32 Appendix B – Glossary
Auxiliary Energy: Energy consumed (usually as a by time measure, such as “x”kW/hour) to operate all support systems for non-drivetrain demands, such as HVAC and interior lighting.
Battery Electric Bus: Zero-emission bus that uses onboard battery packs to power all bus systems.
Battery Nameplate Capacity: The maximum rated output of a battery under specific conditions designated by the manufacturer. Battery nameplate capacity is commonly expressed in kWh and is usually indicated on a nameplate physically attached to the battery.
Block: Refers to a vehicle schedule, the daily assignment for an individual bus. One or more runs can work a block.
A driver schedule is known as a “run.”
Charging Equipment: The equipment that encompasses all the components needed to convert, control and transfer electricity from the grid to the vehicle for the purpose of charging batteries. May include chargers, controllers, couplers, transformers, ventilation, etc.
Depot Charging: Centralized BEB charging at a transit agency's garage, maintenance facility, or transit center. With depot charging, BEBs are not limited to specific routes, but must be taken out of service to charge.
Energy: Quantity of work, measured in kWh for ZEBs.
Energy Efficiency: Metric to evaluate the performance of ZEBs. Defined in kWh/mi for BEBs, mi/kg of hydrogen for FCEBs, or miles per diesel gallon equivalent for any bus type.
Fuel Cell Electric Bus: Zero-emission bus that utilizes onboard hydrogen storage, a fuel cell system, and batteries.
The fuel cell uses hydrogen to produce electricity, with the waste products of heat and water. The electricity powers the batteries, which powers the bus.
Greenhouse Gas Emissions: Zero-emission buses have no harmful emissions that result from diesel combustion.
Common GHGs associated with diesel combustion include carbon dioxide (CO2), carbon monoxide (CO), nitrous oxides (NOx), volatile organic compounds (VOCs), and particulate matter (PM). These emissions negatively impact air quality and contribute to climate change impacts.
Hydrogen Fueling Station: The location that houses the hydrogen production (if produced onsite), storage, compression, and dispensing equipment to support fuel cell electric buses.
On-route Charging: BEB charging while on the route. With proper planning, on-route charged BEBs can operate indefinitely, and one charger can charge multiple buses.
Operating Range: Driving range of a vehicle using only power from its electric battery pack to travel a given driving cycle.
Route Modeling: A cost-effective method to assess the operational requirements of ZEBs by estimating the energy consumption on various routes using specific bus specifications and route features.
Prepared by CCT with support from CTE
33 Useful Life: FTA definition of the amount of time a transit vehicle can be expected to operate based on vehicle size and seating capacity. The useful life defined for transit buses is 12-years. For cutaways, the useful life is 7 years.
Validation Procedure: to confirm that the actual bus performance is in line with expected performance. Results of validation testing can be used to refine bus modeling parameters and to inform deployment plans. Results of validation testing are typically not grounds for acceptance or non-acceptance of a bus.
Zero-Emission Vehicle: A vehicle that emits no tailpipe emissions from the onboard source of power. This is used to reference battery-electric and fuel cell electric vehicles, exclusively, in this report.
Well-to-wheel Emissions: Quantity of greenhouse gas, criteria pollutants, and/or other harmful emissions that includes emissions from energy use and emissions from vehicle operation. For BEBs, well-to-wheel emissions would take into account the carbon intensity of the grid used to charge the buses. For FCEBs, well-to-wheel emissions would take into account the energy to produce, transport, and deliver the hydrogen to the vehicle