Infrastructure Truck Regulation Implementation Group - November 4, 2025

Background

The California Air Resources Board (CARB) hosted a public Truck Regulation Implementation Group (TRIG) meeting to discuss infrastructure aspects of the Advanced Clean Fleets Regulation (ACF). This was the 5th meeting of the Infrastructure TRIG.

Presentations

This meeting focused on hydrogen cost and price as it affects fuel cell truck adoption, and strategies and incentives needed to bring hydrogen cost closer to diesel parity. Presentations and updates were given by representatives from the following entities:

Truck Dealership Perspective - Tom’s Truck Centers
Alliance for Renewable Clean Energy Systems (ARCHES) Overview – GoBiz
ARCHES hydrogen cost price assumptions – LBNL
Low Carbon Fuel Standard (LCFS) status update – CARB
Federal Production Tax credit and DOE H2 Demand Initiative – GoBiz
Hydrogen producer prospective - Air Liquide
Hydrogen Distribution via retail truck stops - Pilot Travel Centers
Presentations can be found here External Slides.
Updates from Nikola, Hyundai, Paccar, and Volvo on their fuel cell truck commercialization plans
Truck manufacturer updates are included in TRIG 5 CARB slides with the exception of Nikola, who provided a verbal update summarized below:
- Ole Hoefelmann from Nikola provided updates on both their fuel cell trucks and Hyla refueling systems. To date, Nikola has wholesaled 235 trucks, primarily in California. Their largest customer is IMC Logistics, with 50 fuel cell trucks in operation today. Hyla’s ambition is to build out safe reliable hydrogen refueling infrastructure to enable class 8 fuel cell electric truck (FCET) adoption at scale. Hyla has 3 objectives: 1) in conjunction with others, build a reliable network of heavy-duty hydrogen stations to support all heavy-duty FCETs; 2) work with all suppliers and subcontractors to ensure that the station equipment they provide is safe, reliable, available, and cost competitive; and 3) be a pivotal stakeholder in the establishment of the “Hydrogen Ecosystem” - with the objective of hydrogen dispensed at a price point enabling large-scale adoption of fuel cell technology. Nikola believes that investors in the hydrogen ecosystem, including trucking fleets, should strive toward achieving a price point for hydrogen that enables adoption and base their ROI on the price of hydrogen at the pump. (statement approved by Nikola)

A recording of these presentations and follow-up discussion can be found in the video recording of this meeting.

TRIG Panel Discussion

Panelists then asked clarifying questions about the above presentations followed by focused discussion. Following is a summary.

Hydrogen Economics and Outlook

Hydrogen costs remain a major concern for fleets, with prices averaging $12–$15 per kilogram—three times higher than diesel, explaining why fuel and truck incentives, and modular hydrogen stations have been key drivers promoting early fuel cell truck deployments.
Responding to a question about the increase in the retail price of hydrogen in the early 2020’s, Bill Zobel shared that it was partly due to an incident-induced supply chain disruption that occurred while filling high pressure tube trailers at the sole supplier of gaseous high-pressure hydrogen. In addition, the value of LCFS credits had dropped significantly, which limited how much the station could discount retail price.
Discussing hydrogen price in terms of "diesel parity" distracts from the broader value of hydrogen technology, such as reduced vehicle maintenance costs, improved driver satisfaction, and operational benefits.
Getting to scale and bringing the cost of hydrogen down through scale will require advancements in all three parts of the supply chain, as outlined in Air Liquide’s presentation. We need a business model that addresses the entire supply chain rather than assuming the free market will flesh out each challenge.
California’s hydrogen hubs award to ARCHES includes hydrogen production from 13 renewable electrolysis systems and 2 biomass-based production sites.
A number of learnings have gone into the heavy-duty hydrogen market to make sure that customers have a reliable experience. The goal is for truck drivers to have the same refueling experience as diesel. Pilot is planning for stations capable of doing back-to-back fills of 35-40 kg in 10-12 minutes.
Evaluating total cost of ownership (TCO) for parity should incorporate costs of maintenance, fuel, insurance, and residual values into the equation.
The lack of financing options for fuel cell truck purchases presents a barrier for truck buyers. Leveraging tools to drive down TCO as well as using loan and credit support programs such as iBank and climate financing to backstop loans gives financial institutions confidence to fund hydrogen projects.
Modular stations, like Nikola’s Hyla brand, are a critical near-term solution, enabling fleets to refuel while permanent infrastructure is being developed. Learnings from these pilot stations will inform future deployments of permanent fueling hubs. Challenges in getting a modular station permitted depends on the site location.
Mobile refuelers that supply gaseous hydrogen have a role in providing hydrogen to vehicles in emergency situations or when a permanent station is down. These units are not as able to fill as quickly as the modular liquid refuelers or brick-and-mortar stations.
Gaining and sharing real-world experiences on hydrogen station equipment performance should drive future hydrogen infrastructure innovation. Fleets are hesitant to make the necessary upfront investments. Grants for pilot projects that demonstrate both truck and fueling technology would help fleets gain experience to help inform future decisions.
Government policy, adequate hydrogen supply, robust distribution and fueling infrastructure, and cost of trucks all need to be addressed at the same time for success.
When planning for scale and considering a liquid versus gaseous station, Pilot decided on liquid because, while starting with a gaseous station would be cheaper, it would become increasingly expensive as demand for fuel increases. With a liquid station, they would be able to quickly accommodate increasing fuel demand as fuel cell truck traffic increases. Additionally, since truck OEMs are exploring onboard liquid hydrogen storage systems, it will be more practical and cost effective to add liquid dispensing to a station that already has liquid supply. This decision goes all the way up to the point of production and distribution. In addition, the supply chain for high pressure storage tubes for transporting hydrogen gas is fairly limited in the US. This is not the case for the equipment used to transport and store liquid hydrogen.
ARCHES will be coordinating across all 7 hydrogen hubs on infrastructure and vehicle roll out for truck and bus fleets, leveraging across multiple fleets and hubs to drive up volumes.
The first investments are likely to be with fleets that have return to base operations (i.e., transit) or repeatable point-to-point delivery (i.e., drayage). The amount of infrastructure needed for those first projects is limited to meeting the needs of each specific fleet.
Air Liquide shared that they have projects in 4 of the 7 hydrogen hubs across the US including the Pacific Northwest, Gulf Coast, Mid-West and Appalachian hubs. Air Liquide’s model is based on liquifying hydrogen that is being produced from the investments made in these hubs, then distributing liquid hydrogen to transportation sectors. Air Liquide is looking to develop partnerships with hydrogen station operators, truck and bus fleets and manufacturers who will be the hydrogen off-takers in these areas to help establish and support the first stages of what will eventually become heavy-duty station networks. Starting infrastructure development in California is good, but heavy-duty freight transport will need to be supported with national hydrogen station networks.

Fuel Cell Truck Adoption

Fleets like pilot programs that allow them to test fuel cell trucks before committing to full adoption (e.g. Tom’s Truck Center’s Try Before You Buy program). These programs could be expanded to dealership networks to ensure broader access to fuel cell trucks.
There is a need for fuel cell truck platforms that can be upfitted for use by municipal utilities.
Warrantees for assigned use do not allow some of the advanced tech vehicles to go off-road, which is a problem for utility companies.

Panelists shared anecdotes about how fuel cell trucks are improving driver experiences, attracting new drivers and encouraging retired drivers to return to work. Drivers are reporting greater satisfaction with grade-climbing capability and overall handling of fuel cell vehicles.
Government incentives for zero-emission vehicle like CaliforniaHVIP.org and low carbon fuel credits like LCFS are key enablers for fleets transitioning to fuel cell technology and critical to offsetting the high costs of fuel cell trucks and hydrogen.

Workforce Development and Training Needs

Workforce development needs to encompass the entire hydrogen ecosystem, including hydrogen production facilities, station construction, vehicle and station maintenance, and grant writing. Having skilled labor in the construction and operation of hydrogen stations will be critical, and comprehensive training programs are needed to prepare workers for the complexities of hydrogen infrastructure.

Closing Remarks

The discussion underscored the need for end-to-end solutions that seamlessly integrate hydrogen production and distribution, and vehicle operation, with shared risk among all stakeholders.
Stakeholders were encouraged to shift their narrative toward the overall value that hydrogen and fuel cell technology provides, moving beyond cost comparisons with diesel and toward operational parity and TCO.
Truck, fuel and infrastructure incentives are critically important to spur early adoption.
Rental and pilot programs give drivers hands-on experience will help us understand how these programs shape driver attitudes.
Having a nationwide network will become increasingly important as fuel cell technology advances in the freight sector.
ARCHES is interested in hearing about the needs of fleets – please email: Strategy@arches.org or hydrogen@gobiz.ca.gov.
Future meetings will be 1:00 to 3:00 the second Monday of every third month starting February 10, 2025.
Panelists were asked to think about topics to address at future Infrastructure TRIG meetings and email Leslie.Goodbody@arb.ca.gov with suggestions.
CARB staff will refresh the Infrastructure TRIG panel by first sending a notice from ZEV Fleet with a survey where people can respond if they are interested in being on the Infrastructure TRIG panel in 2025.

Panel Members in Attendance

Analisa Bevan, California Air Resources Board (CARB)
Marc Perry, California Energy Commission (CEC)
Adam Browning, Forum Mobility
Jimmy Andreoli, Baker Commodities, Inc.
Sam Wilson, Union of Concerned Scientists (UCS)
Joe Gagliano, Air Products
Lisa McGhee, Tom’s Truck Center
Kent Leacock, Mainspring Energy
Zachery Artozqui, Knife River Construction
Audrey Neuman, California Public Utilities Commission (CPUC)
Bascomb Gracian, Fuel Distribution/Energy Marketer
Erick Karlen, Pacific Gas & Electric (PG&E)
Chris Shimoda, California Trucking Association (CTA)
Frank Harris, California Municipal Utilities Association (CMUA)
Christina Marquez, International Brotherhood of Electrical Workers (IBEW 569)