Document Management Facility
U.S. Department of Transportation
400 Seventh Street, S.W.
Nassif Building Room PL-401
Washington, D.C. 20590-001

ATTN: Joseph N. Kanianthra, Associate Administrator for Vehicle Safety Research

RE: Docket No. NHTSA-2004-18039: NHTSA's Four-Year Plan for Hydrogen Fuel Cell, Fuel Cell and Alternative Fuel Vehicle Safety Research

Dear Mr. Kanianthra:

The Japan Automobile Manufacturers Association ("JAMA") appreciates the opportunity to submit these comments on NHTSA's Four-Year Plan for Hydrogen, Fuel Cell and Alternative Fuel Vehicle Safety Research [Docket No. NHTSA-2004-18039], and respectfully requests that NHTSA give them serious consideration.

General

Fuel cell vehicles belong to field of developing technology. Therefore, any current research in this area should not obstruct opportunities for future technology development related to fuel cell vehicles. To accomplish this goal, JAMA believes it is necessary for NHTSA's Four-Year Plan to accommodate a number of different technology choices.

Since in some cases a whole vehicle, rather than its individual components, may need to be considered as a single comprehensive system in order to ensure vehicle safety, JAMA believes that it is necessary to plan safety research based upon the principle that the vehicle is a single comprehensive system.

1.  Component Level Testing

JAMA supports the use of Helium as a suitable substitute gas for conducting crash fuel gas leak tests because of its chemical safety and ease of adjusting vehicle weight for crash tests.

Technical requirements on resistance to hydrogen embrittlement and the rigidity of fuel tanks, among other things, have been established in ISO standards, HGV2, and Japan's High-Pressure Gas Safety Law. Apparently, one objective of the NHTSA's Four-Year Plan is to verify the strength of the fuel containers prescribed in these existing standards and regulations against external pressure. In this regard JAMA hopes that the results of external force destruction testing will be evaluated together with the results of vehicle crash testing.

Hydrogen storage methods other than the storage in compressed/liquefied hydrogen tanks are still in the research stage. The degree of progress needs to be fully considered in planning the application of these methods.

JAMA also believes that, in vehicle fire testing, all fuel cell vehicles, gasoline vehicles and natural gas vehicles ought to be tested and evaluated under identical conditions. In addition, the flammability of automotive materials in hydrogen-fuel fires should be judged against the existing fire retardance regulation for vehicles and evaluated on the same grounds as flammability in gasoline and natural gas-powered vehicles.

2.  Fueling System Performance Test

The use of communications systems in connection with fueling systems will be desirable if such systems are intended and effective in enhancing convenience for vehicle users, such as shortening fuel filling time. Communications systems should not be used as a means of ensuring the safety of fuel cell vehicles and hydrogen service stations, since such fuel cell vehicles and hydrogen service stations must be complete and self-sufficient in ensuring their safety, without the necessity for such external systems.

If the permissible amount of hydrogen leak from the gas filling port is at an unignitable flow rate level, JAMA believes it unnecessary to require a safety grounding at the time of hydrogen filling.

3.  Whole-Vehicle Level Testing

NHTSA contemplates that vehicle manufacturers will be expected to supply test vehicles for crash tests. However, such vehicles are expensive and few are available because vehicle manufacturers must also secure test vehicles for their rupture and deterioration experiments. JAMA therefore requests that NHTSA develop an efficient research plan that specifically seeks to keep the number of vehicles required to be supplied by manufacturers as small as possible.

The ultimate objective of electric insulation on high-voltage systems is to protect vehicle users from electric shocks, but electric insulation is not the only means of achieving this objective. JAMA's recommended insulation resistance is 100 Ohm/V or more according to IEC 60479. JAMA believes that external recharging is unnecessary.

4.  CAFE (Corporate Average Fuel Efficiency)

These technologies will require a fuel efficiency measurement method that will provide satisfactory public information disclosure. JAMA recommends that NHTSA refer to the mode fuel efficiency measurement method for hydrogen fuel cell vehicles that was developed by JARI (Japan Automobile Research Institute) and has been proposed to ISO. However, the predicted population (fleet) of hydrogen fuel cell vehicles in use needs to be taken into account in incorporating such a measurement method into fuel efficiency requirements or CAFE calculation procedures.

5.  International Harmonization of Regulations

With regard to the international harmonization of fuel cell vehicle safety regulations, JAMA urges NHTSA to examine for reference the fuel cell vehicle safety regulation that Japan is scheduled to enact in about March 2005. JAMA looks forward to the establishment of a Global Technical Regulation for fuel cell vehicles.

JAMA hopes these comments are useful to NHTSA in connection with its planning. If NHTSA has any questions concerning these comments, please feel free to contact us.

Sincerely,


William C. Duncan, Ph.D.
General Director
JAMA Washington Office