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Written Public Comment: Zero-Emission Bus Rollout and Stantec Contract, Municipal Services Committee, April 28, 2026
From Ana Soulriver
Date Mon 4/27/2026 6:36 PM
To cityclerk <[email protected]>
I 1 attachment (212 KB)
Public Comment Hydrogen.pdf;
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Dear City Clerk,
Please accept the attached written public comment for the Municipal Services Committee meeting of April 28,2026, regarding the Pasadena Transit Zero-Emission Bus Rollout Plan update and the proposed contract with Stantec Consulting Services for hydrogen fueling station oversight.
Thank you for including it in the public record.
Respectfully,
Ana Soulriver
Ana Soulriver
®
Ana Soulriver
Pasadena, California
April 27,2026
Municipal Services Committee
City of Pasadena
100 North Garfield Avenue
Pasadena, California 91101
Re: Written Comment on Pasadena Transit Zero-Emission Bus Rollout and Proposed Hydrogen Fueling Station Contract (Stantec)
Dear Committee Members,
I am a Pasadena resident, environmental advocate, and community commissioner writing to offer comments on the Zero-Emission Bus Rollout Plan update and the proposed $316,800 contract with Stantec Consulting Services for hydrogen fueling station oversight. I write in genuine support of Pasadena's commitment to a fully zero- emission transit fleet. My comments center on one specific request: before the city proceeds further with hydrogen infrastructure investment, I am asking Director Joaquin T. Siques and the Department of Transportation to provide the Committee and the public with a direct, ten-year cost and emissions comparison between continuing on Renewable Natural Gas and proceeding with the hydrogen fuel cell strategy.
I. What the Public Record Currently Shows
The staff report presented today contains important and honest operational data. The finding that Pasadena Transit's battery electric bus averages approximately 80 miles per day against routes requiring up to 200 miles and 14 to 16 hour duty cycles is a real constraint. The staff conclusion that hydrogen fuel cell buses provide a one-to-one operational replacement for the current Renewable Natural Gas fleet, while battery electric would require a 2-to-i ratio and significant additional fleet costs, is a legitimate finding that deserves weight.
What the report does not yet provide, and what I believe the Committee needs before recommending further investment in hydrogen-specific infrastructure, is a direct comparison of the full ten-year cost picture between the city's current Renewable Natural Gas fleet and the proposed hydrogen fuel cell strategy. The public record shows the capital costs of hydrogen procurement and infrastructure. It does not yet show a side-by-side analysis of total cost of ownership, including fuel costs, maintenance, infrastructure operations, and the projected cost trajectory of green hydrogen supply through the First Public Hydrogen JPA.
II. The Data Request
i.
I am respectfully requesting that Director Siques prepare and present to the Committee, prior to the May 4 City Council hearing on the Stantec contract, a comparative analysis that addresses the following questions:
• Total ten-year cost of ownership for the hydrogen fuel cell strategy, including vehicle acquisition, fueling station construction and operations, hydrogen fuel costs under First Public Hydrogen contracts, and maintenance. Expressed as a per-mile and per-bus annual cost.
Total ten-year cost of remaining on Renewable Natural Gas for the existing fleet, including fuel costs, maintenance, and the cost of continued CARB compliance under the Innovative Clean Transit rule. This is not a recommendation to extend RNG indefinitely. It is a baseline against which the hydrogen investment should be measured.
The projected cost and availability of green hydrogen through the First Public Hydrogen JPA. Specifically, what is the contracted price per kilogram, what are the delivery guarantees, and what contingency provisions exist if the supply is delayed beyond the 2028 fueling station commissioning date? The lifecycle greenhouse gas emissions of the hydrogen strategy, accounting for the actual production method of the hydrogen to be delivered, not manufacturer or JPA projections alone. The city's experience with Renewable Natural Gas has demonstrated that a fuel is only as clean as its sourcing and supply chain.
Hydrogen is no different, and the Committee deserves a clear answer on this before further infrastructure is committed.
A comparison of battery electric bus performance projections for 2028 versus 2025 benchmarks, given the rapid improvement in battery technology and total cost of ownership across the industry. The current data is drawn from one bus procured under 2024 specifications. The 2028 procurement should be evaluated against 2028 technology.
III. Why This Analysis Matters Now
I am not asking the Committee to reverse the existing hydrogen bus contract or to forfeit the $38 million in grant funding tied to the current strategy. Those commitments are made, and the financial consequences of reversing them would be substantial. I am asking for the data that allows the Committee, the Council, and the public to understand what we are committing to before the infrastructure that locks in that strategy is built.
The Stantec contract, if approved, advances construction planning for a hydrogen fueling facility that will serve the city's fleet for decades. That is a long-term commitment. The city's own staff report acknowledges that a full plan update is scheduled ahead of the 2028 procurement. A ten-year comparative cost and emissions analysis, presented before May 4, would be exactly the kind of evidence that makes that 2028 review meaningful rather than a formality.
.;.'•';:.-
Nationally, clean hydrogen project cancellations have accelerated. Transit agencies in Southern California, including LA Metro, Santa Monica's Big Blue Bus, and Long Beach Transit, have made significant investments in battery electric fleets. Pasadena may ultimately be right that its specific duty cycles and route demands make hydrogen the better operational choice. I simply want to see that case made transparently, with full cost and emissions data, not assumed.
TV. Conclusion
Pasadena has earned its reputation as a city that takes climate seriously. The zero- emission bus transition is a public and visible expression of that commitment. I am asking Director Siques and the Department of Transportation to give the Committee and the community the full cost and emissions picture, so that our investment in hydrogen infrastructure is grounded in transparent, verified data rather than in projections alone.
Thank you for your consideration of these comments and for your service to this community.
Respectfully submitted,
Ana Soulriver
Pasadena Resident and Environmental Advocate
Commissioner, City of Pasadena Environmental Advisory Commission (Affiliation listed for identification only; this letter is submitted as a private resident) ^ Outlook
MSC
From Lauren Siegel
Date Man 4/27/2026 8:03 PM
To Official Records - City Clerk <[email protected]> Bl 1 attachment (108 KB)
2025-7-08 EAC Hydrogen Bus Recommendation Letter(1).pdf; Some people who received this message don't often get email fromLearn why this is important [A] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
Hi
Please attach EAC letter on Hydrogen Busses to the MSC agenda for public comment.
Thanks,
Lauren
Lauren Siegel
MS Sustainable Development and Resource Management
Pasadena Environmental Advisory Commissioner
linkedin.com/in/siegell/
To:
From:
Date:
Re:
Memorandum
Pasadena City Council
Environmental Advisory Commission
July 9, 2025
Concerns and Recommendations Regarding the Hydrogen-Based Zero Emission Bus Rollout Plan
The Environmental Advisory Commission, writes to express our appreciation for the City of Pasadena's continued leadership in advancing climate action and transitioning to a zero-emission municipal bus fleet.
The goal of a cleaner, healthier transit system aligns with our shared environmental and public health priorities. However, after reviewing the City's proposed Zero Emission Bus (ZEB) Rollout Plan presented on May 13, 2025, we feel compelled to raise serious concerns regarding the plan's reliance on hydrogen fuel cell electric buses (FCEBs) for the Pasadena Transit fleet.
While we understand that both battery electric buses (BEBs) and FCEBs are permissible under the California Air Resources Board's Innovative Clean Transit Rule, the heavy investment in hydrogen technology as the primary pathway raises questions regarding cost, safety, reliability, and climate efficacy:
1. Cost and Financial Risk
The plan anticipates spending over $150 million through 2028, with $100 million allocated to a Transit Operations and Maintenance Facility and $20.5 million to a hydrogen fueling station. Yet even with grant funding, over $31.5 million remains unfunded. Hydrogen buses are estimated to cost approximately $1.6 million per unit, compared to $1.3 million for BEBs, with significant additional costs for hydrogen fueling infrastructure. While the ZEB Rollout Plan anticipates that BEBs would require an additional 9 units, the marginal reduction in fleet size with FCEBs does not offset the substantial difference in capital and infrastructure costs. These figures suggest escalating financial burdens on local taxpayers, especially as long-term fuel and maintenance costs remain uncertain.
2. Fuel Supply and Emissions
Unlike battery electric vehicles, which can be charged using local grid electricity and increasingly renewable sources, hydrogen fuel must be imported by truck. This introduces both cost and reliability risks in addition to undermining climate benefits. Each delivery entails truck traffic (likely diesel trucks) through Pasadena's residential neighborhoods and along freeways, contributmg to greenhouse gas emissions, air pollution, and road safety risks.
Additionally, truly "green" hydrogen is not yet available at scale and even if it was, requires large amounts of electi-icity and water to produce, straining both energy and water resources. More commonly, hydrogen is produced from natural gas or so-called "renewable natural gas," both of which are energy- intensive processes that generate significant fossil fuel emissions. In this context, the logistics and environmental impacts of hydrogen make it a far less sustainable or reliable fuel choice than battery electric options. The City would be effectively swapping tailpipe emissions for upstream emissions from fossil-fueled supply chains.
3. Safety Concerns
Hydrogen is a highly flammable and pressurized gas, requiring strict containment protocols. The prospect of transporting and storing large quantities of hydrogen within City limits, particularly near homes or sensitive areas, is deeply concenung. The risk of leaks or accidents — whether durmg storage or transportation — cannot be entirely mitigated and raises serious questions about the pmdence of placing such facilities in a dense envu-onment like Pasadena.
4. Future Cost and Technology Uncertainty
Hydrogen is a relatively immature transit technology. During the ZEB Rollout Plan presentation, we were told that only one company in the world currently manufactures hydrogen fuel cell buses There is also a limited network of hydrogen fueling stations and a nanrow supply chain for parts and maintenance. This leaves us concerned about higher operating costs, longer downtimes, and greater dependency on a small set of specialized vendors. The risks of relying on a single manufacturer are not hypothetical — we are informed that fhe City has already experienced similar challenges with EV chargers that use proprietary technology, which have remained out of service due to lack of available repairs. In confa-ast, battery electric buses, when thoughtfully implemented using open standards and diverse suppliers, offer a strategic advantage: they benefit from a rapidly expanding market, declining costs, and widespread parts availability.
5. Battery Electric Buses as a Viable and Preferable Alternative Battery electric buses, which are already designated for Dial-A-Ride service in Pasadena's plan, offer a lower-risk and more scalable path to zero emissions. BEBs do not rely on fuel unports, produce no local emissions, and can leverage existing investments in the electrical grid and renewable energy. Other agencies across the state, including LA Metro, have made significant investments in BEBs, recognizing their potential for long-term operational cost savings and climate resilience.
Recomm endation
We urge the City Council to reconsider the current emphasis on hydrogen fuel cell buses and mstead consider prioritizing a battery-electric fleet transition for both Pasadena Transit and Dial-A-Ride. To that end, we also recommend commissioning an updated comparative analysis oflifecycle emissions, total cost of ownership, and safety implications for BEB versus FCEB pathways — mcluding localized supply chain impacts. However, cost is not the only factor to consider; the significantly greater risks to safety associated with hydrogen fuel compared to electric transportation infrastructure must also be fully accounted for in the City's decision-making.
Our Commission is conunitted to supporting Pasadena's transition to a sustainable, zero-emission future.
We believe that with careful planning and community-centered investonent, this goal can be achieved in a manner that maximizes both environmental benefit and public safety.
Outlook
NRDC comments on Item #1 - Municipal Services Committee From Rubin, Carter
Date Tue 4/28/2026 6:45 AM
To Jones, Justin <[email protected]>
Cc Cole, Rick <[email protected]>; Hampton, Tyron <[email protected]>; cityclerk <[email protected]>; Lyon, Jason <[email protected]>,· [email protected] <[email protected]>,· h4osey. Lisa <[email protected]>; Gao, Beilei < [email protected]>
I 1 attachment (127 KB)
NRDC Pasadena Clean Bus Letter.pdf;
Some people who received this message don't often get email from iLearn why this is important [A] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
Good morning Committee Members and staff,
I hope this finds you well. I'm writing to encourage Pasadena to pursue electrification of its transit fleet with battery electric buses. Please find our letter with additional details attached.
Feel free to reach out if you have any questions.
Thanks,
Carter
CARTER RUBIN
Director, State Transportation Advocacy
Climate and Energy
NATURAL RESOURCES
DEFENSE COUNCIL
NRDC
HT^^
April 28, 2026
Hon. Chair Justin Jones
Pasadena City Hall, Council Chamber
loo North Garfield Ave, Room 8249
RE: Item #l - Contract for Hydrogen Fueling Station Consulting Services Dear Honorable Chair Jones and Councilmembers,
On behalf of Natural Resources Defense Council (NRDC) I'm writing to both support Pasadena's efforts to eliminate emissions from the operations of its municipal bus fleet, and to advocate that the city pursue a pathway of direct electrification with battery electric buses.
NRDC is an international environmental organization with a long history of advocacy in Southern California to clean up our local air.
NRDC has supported a targeted deployment of hydrogen in sectors like fertilizer, steel, and maritime shipping that are otherwise difficult to electrify. But because hydrogen production is energy-intensive and can require new infrastructure build-out, it's imperative to produce and deploy hydrogen strategically in end uses that lead to net positive climate impacts.
In our report, "Hitting the Mark: How Targeted Deployment of Hydrogen Can Maximize Climate Benefits, we found that battery electric vehicles can achieve zero emission while using one-fifth as much electricity as a fuel-cell electric vehicle requires to travel the same distance1.
With competition for clean electricity, strategic deployment of hydrogen is essential for maximizing climate benefits. Hydrogen use should not be prioritized in sectors that have direct electric alternatives, such as transit buses.
Further, the transit industry is quickly aligning around battery electric buses as the dominant option for zero emissions bus fleets. According to California Air Resources Board data, there are 879 battery electric public transit buses in operation in the state, and only 170 hydrogen buses2. Globally there were 70,000 electric buses sold worldwide in 2024.3
lhttps://www.nrdc.org/sites/default/files/2025-ll/Hydrogen_Pathways_Report_R_25- 10-C_04_locked.pdf
2https://ww2.arb.ca.gov/our-work/programs/innovative-clean-transit/reporting-tool- data
3https://www.iea.org/reports/global-ev-outlook-2025/trends-in-heavy-duty-electric- vehicles
NATURAL RESOURCES DEFENSE COUNCIL
1314 2ND STREET i SANTA MONICA, CA i 30401 T 310.434.2300 F 310.434.2393 i NRDC.ORG Focusing on electrification with battery electric buses will ensure that Pasadena has access to a growing industry supplying battery electric buses, charging infrastructure and support services.
For these reasons, we encourage the committee to direct staff to pursue a battery electric approach for its bus fleet. Thank you for your consideration.
Sincerely,
^^^^<
Carter Rubin
Director, Station Transportation Advocacy
Cc: David Reyes, General Manager
Lisa Hosey, Assistant City Attorney
Betty Gao, Recording Secretary