I am writing to provide…

I am writing to provide comments on behalf of the Canadian rail industry regarding the Ontario Low-Carbon Hydrogen Strategy Discussion Paper (Discussion Paper)

The Railway Association of Canada (RAC) represents freight and passenger railway companies that move more than 100 million people and $360 billion worth of goods in Canada each year. Freight railways move about 50 percent of the country’s goods destined for export (by volume) and 70 percent of intercity freight traffic in Canada. As the voice of Canada’s railway industry, the RAC advocates on behalf of its members to ensure that the rail sector remains globally competitive, sustainable, and safe.

The RAC would like to acknowledge the Province of Ontario’s efforts to work with other levels of government and the private sector in a collaborative approach to reducing carbon emissions. The impacts of climate change affect us all and identifying and implementing innovative solutions will require that we all work together. We believe that the production and use of hydrogen represents the type of innovation that can support decarbonization efforts while also boosting the economy and job creation.

Collaboration is at the heart of the Canadian railway industry’s efforts to decarbonize its operations. For over twenty-five years, Canada’s railways have worked with the federal government to reduce emissions produced by locomotives. Since 1995, Transport Canada and the RAC have signed four Memoranda of Understanding (MOU) to establish voluntary reduction targets for emissions produced by locomotives in Canada. Performance under the MOU agreements has been positive, with railways demonstrating that investments in technology and more efficient operating practices are improving fuel economy and reducing emissions.

The most recent MOU, signed in 2018, includes a commitment to collaborate on a comprehensive pathway to reduce emissions produced by the railway sector (Rail Pathway Initiative). This Rail Pathways Development project, underway now, will align government and industry efforts to support the development, testing, and commercialization of next-generation technologies that will allow for deep reductions of emissions from the rail sector, including hydrogen co-combustion and hydrogen fuel cells, among other options.

A key principle of the Discussion Paper is to use hydrogen “where and when it makes sense” and seeks to “focus on areas where hydrogen is most likely to become cost-competitive ...”. Based on the initial findings of the Rail Pathways Development project, this will prove to be true for many applications in the rail sector, including equipment used in rail yards, as well as in locomotives used in various applications. As noted in Canada’s Hydrogen Strategy, “Rail … applications are well suited to hydrogen because their energy intense duty cycles and long ranges make them particularly hard to electrify.”

 
The Discussion Paper identified hydrogen as an alternative or complement to diesel fuel in the medium to long term: after 2030. In fact, Cummins fuel cells are already powering Alstom regional commuter trains in commercial operation internationally. In Canada, pilot projects are testing hydrogen fuel cell-powered rail (hydrail) in Canada now both in shunter (Southern Railway of British Columbia) and mainline freight locomotives (CP Rail), and Metrolinx has been investigating the feasibility of using a hydrail system for the GO rail network. Furthermore, as Cummins and Next Hydrogen manufacturing facilities exist in Ontario, this could allow for partnership opportunities to help testing of hydrogen fuels cells for railway operations. The Government of Ontario can promote partnerships between regional fuel cell developers and rail companies on discussions regarding hydrogen pilot projects in the rail sector.

Commercial use of hydrail technology is possible in Ontario by, or even prior to 2030, and could therefore contribute to Ontario’s 2030 greenhouse gas emission reduction target. In order to make this a reality, however, pilot deployments of hydrail technologies in Ontario are necessary. Unlike in other areas, technology development in the rail sector must rely on rail companies to provide the assets (trains) to use in demonstration and pilot projects, and the person-hours to support these projects. This will require financial support from the province.

Further, rail is a capital-intensive sector, and locomotives are long-term assets. Each locomotive represents an investment of several million dollars and is expected to last for upwards of forty years. Where refueling infrastructure is also required, that cost becomes significantly higher. Once the technology is commercially available, our view is that funding will be required to support the rail industry in making the transition to hydrogen.

In developing a hydrogen strategy, the RAC further encourages the province of Ontario to consider that for regions identified as potential producers or users of hydrogen that are not serviced by existing pipelines, rail provides an efficient and economical option for transporting it. Railways may also provide a viable option for the storage, production, and usage of hydrogen at rail-yard facilities, which can provide an option to generate electricity to power the grids when hydrogen is not required.

We also encourage the province to explore and support training and knowledge needs of the railway sector to build capacity and hydrogen knowledge within rail companies. The goal of such training would be to educate rail companies on new hydrogen technologies from successful pilot projects, academia, and vendors from across the world.

Developing standards for hydrogen fuel quality should be considered as part of the strategy. Lower-grade hydrogen can be suitable for use in combustion processes but will lead to fouling in high-end fuel cells. Standards ensure that railways understand the type and quality of hydrogen fuel purchased so that compliance with OEM requirements and warranties can be met.

The RAC appreciates the opportunity to provide input to the development of the provincial hydrogen strategy and looks forward to further discussions on this topic.

Sincerely,

Caroline Healey
Executive Vice-President and General Counsel
Railway Association of Canada