Hydrogen-Fueled Medium- and Heavy-Duty Vehicles (MHDVs): Overview, Deployment Activities, and Considerations for Congress
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Hydrogen-Fueled Medium- and Heavy-Duty
Vehicles (MHDVs): Overview, Deployment
Activities, and Considerations for Congress
Updated April 21, 2025
Congressional Research Service
https://crsreports.congress.gov
R48507
SUMMARY
Hydrogen-Fueled Medium- and Heavy-Duty
Vehicles (MHDVs): Overview, Deployment
Activities, and Considerations for Congress
R48507
April 21, 2025
Martin C. Offutt
Analyst in Energy Policy
Fuel cell-electric vehicles consume hydrogen and atmospheric oxygen to provide electric power,
turning a motor while giving off only heat and water. The recent rise in fuel cell-electric vehicles
is often focused on light-duty vehicles (i.e., cars), and at the end of 2023, 16,900 were registered
in the United States. Vehicle manufacturers are nonetheless announcing demonstrations of small numbers of hydrogen-fueled
medium- and heavy-duty vehicles (MHDVs or “trucks”)—on-road vehicles weighing from 10,000 pounds up to 80,000
pounds, with cargo, for long-haul applications. These vehicles take advantage of the performance of the fuel cell powertrain
including emitting no pollutants.
MHDVs provide services essential to economic activity, including goods movement, passenger mobility, refuse collection
and hauling, cement mixing/delivery, and so forth. Fuel cell-electric trucks can provide these services as an emissions-free
alternative to their gasoline and diesel counterparts but have costs as much as two to three times as high. Globally, fuel cellelectric trucks lag their light-duty counterparts in adopting fuel cell-electric powertrains by more than three to one, according
to data from the International Energy Agency. The U.S. Department of Energy’s (DOE’s) U.S. National Clean Hydrogen
Strategy and Roadmap envisages hydrogen-fueled MHDVs as a way of decarbonizing an energy application that, according
to DOE, is otherwise “difficult to electrify.”
A number of programs funded in the Infrastructure Investment and Jobs Act (IIJA; P.L. 117-58) and P.L. 117-169, known as
the Inflation Reduction Act of 2022 (IRA), support the development and commercialization of hydrogen-fueled MHDVs.
The IIJA funded the Regional Clean Hydrogen Hubs at $8 billion and specified that at least one hub be based on the
transportation sector. According to news reports in March 2025, DOE was considering whether to discontinue funding for
some of the seven announced hydrogen hubs. Additional funding sources for MHDVs that could be applied to hydrogenfueled vehicles include, but are not limited to, the Clean Heavy-Duty Vehicles Program ($1 billion, IRA); the Reduction of
Truck Emissions at Port Facilities Grant Program ($400 million, IIJA); and the Port Infrastructure Development Program
($2.25 billion, IIJA, and over $500 million from annual appropriations from FY2022 through FY2024). A January 2025
executive order, “Unleashing American Energy,” and DOE’s reported plans to review all post-election awards may also
impact funding for clean energy and hydrogen.
Bills introduced in the 118th Congress that addressed hydrogen-fueled MHDVs included H.R. 3447, which would have added
a weight allowance for hydrogen fuel cell MHDVs on the Interstate Highway System; the Hydrogen for Trucks Act of 2023,
S. 648, and the Hydrogen for Trucks Act, H.R. 6871, both of which would have funded a demonstration program, including
refueling of fuel cell-electric trucks; and the Hydrogen for Ports Act of 2023, S. 647, and the Hydrogen for Ports Act, H.R.
6872, both of which would have authorized a grant program to support purchase of trucks for hauling offloaded cargo within
a port (i.e., drayage) and other shore-side hauling needs.
If Congress concludes that the continued development and deployment of hydrogen-fueled MHDVs is warranted, it might
consider the following legislative options:
•
adding a weight allowance for fuel cell MHDVs, as in H.R. 3447 (118th Congress), similar to the existing
allowance for natural gas and battery-electric vehicles;
•
legislating the incentives in the National Highway Traffic Safety Administration fuel consumption
standards for MHDVs that provide credits for advanced vehicle technology such as fuel cell-electric trucks;
•
offering incentives that encourage early deployment of fuel cell-electric MHDVs by fleets operating in the
long-haul and regional-haul goods movement business; and
•
providing tax relief for purchase of power equipment on board the vehicle that provides electric power
through a fuel cell.
Congressional Research Service
Hydrogen-Fueled Medium- and Heavy-Duty Vehicles
Contents
Introduction ..................................................................................................................................... 1
Status and Characteristics of MHDVs ............................................................................................. 2
Variety and Configuration of MHDVs ...................................................................................... 2
Operations ................................................................................................................................. 3
Fuel Consumption and Range ............................................................................................. 3
Corridors ............................................................................................................................. 4
Status of Hydrogen and MHDVs .............................................................................................. 4
Demonstrations and Beyond ............................................................................................... 5
Infrastructure ....................................................................................................................... 8
Government Goals and Pledges ................................................................................................ 9
Federal Programs on Energy Use and Purchase of MHDVs ......................................................... 10
Fuel Consumption Regulations ............................................................................................... 10
Origin ................................................................................................................................ 10
Direct Compliance .............................................................................................................11
Fuel Consumption Credits .................................................................................................11
Advanced Technology Vehicles and the Impact on Compliance .......................................11
Federal Excise Tax .................................................................................................................. 12
Types of Federal Excise Tax that Apply to Trucks............................................................ 12
Exemptions to the Federal Excise Tax on Equipment ...................................................... 12
Vehicle Requirements: Range and Cargo Capacity ....................................................................... 12
Overview ................................................................................................................................. 12
Performance Requirements ............................................................................................... 13
Cargo Requirements .......................................................................................................... 14
Three Studies of Class 8 Combination Vehicles ..................................................................... 15
Argonne National Laboratory ........................................................................................... 15
National Renewable Energy Laboratory (NREL) ............................................................. 17
International Council on Clean Transportation ................................................................. 19
Industry Benchmark on Vehicle Range: The Experience of Nikola ........................................ 21
Trade-Offs Involving Parcel Delivery Vehicles (Class 4) ....................................................... 22
Vehicle Cost ................................................................................................................................... 23
Recent Developments .................................................................................................................... 24
Financial Assistance Programs on Deployment of Hydrogen Trucks ..................................... 24
Charging and Fueling Infrastructure (CFI): Grants and Tax Credits ................................ 25
Alternative Fuel Refueling Property Credit: Internal Revenue Code Section 30C........... 26
Clean Heavy-Duty Vehicles Program ............................................................................... 26
Reduction of Truck Emissions at Port Facilities Grant Program ...................................... 26
Clean Ports Program ......................................................................................................... 27
Port Infrastructure Development Program ........................................................................ 27
Regional Clean Hydrogen Hubs ....................................................................................... 28
Advanced Technology Vehicle Manufacturing (ATVM) Loan Program .......................... 28
Domestic Manufacturing Conversion Grants ................................................................... 28
Commercial Clean Vehicles: Internal Revenue Code Section 45W ................................. 29
Summary and Framework ................................................................................................. 29
California Programs on Truck Portfolios and Fleets ............................................................... 32
Advanced Clean Fleets Regulation ................................................................................... 32
Advanced Clean Trucks Regulation.................................................................................. 32
Congressional Research Service
Hydrogen-Fueled Medium- and Heavy-Duty Vehicles
Legislation Introduced in the 118th Congress ................................................................................ 33
Summary and Framework for Consideration .......................................................................... 34
Considerations for Congress.......................................................................................................... 36
Risks of Government Support for Hydrogen-Fueled Trucks .................................................. 36
Streamlining Federal Programs ............................................................................................... 36
Addressing Deployment of Fuel Cell-Electric Trucks ............................................................ 36
Fleet Operations ................................................................................................................ 36
Fuel Consumption Standards ............................................................................................ 38
Federal Excise Tax ............................................................................................................ 39
Loan Programs .................................................................................................................. 39
Summary of Options and Framework ............................................................................... 40
Oversight ................................................................................................................................. 42
Success of Early Deployment ........................................................................................... 42
The Role of MHDVs in Regional Clean Hydrogen Hubs................................................. 42
Grants and Contracts ......................................................................................................... 42
Figures
Figure 1. Examples of Class 4 and Class 8 Vehicles ..................................................................... 13
Figure 2. Argonne National Laboratory Simulation of Three Powertrains in a Class 8
Long-Haul Tractor-Trailer Vehicle in High- and Low-Technology Cases ................................. 16
Figure 3. NREL Vehicle Simulation of Three Powertrains in a Class 8 Long-Haul TractorTrailer Vehicle in Aggressive and Conservative Technology Cases ........................................... 18
Figure 4. ICCT Simulation of Three Powertrains in a Class 8 Long-Haul Combination
Tractor-Trailer in Current and Future Cases............................................................................... 20
Figure 5. Simulation of Three Powertrains in a Class 4 Delivery Vehicle .................................... 23
Tables
Table 1. Nikola Motor Corporation’s Estimated Ranges and Weights for Class 8 TractorTrailers........................................................................................................................................ 22
Table 2. Framework for Analysis of Programs That Could Apply to Hydrogen Truck
Deployment ................................................................................................................................ 30
Table 3. Bills in the 118th Congress That Addressed Deployment of Hydrogen MHDVs ............ 35
Table 4. Options Congress Could Consider for Deployment of Fuel Cell-Electric MHDVs ........ 41
Contacts
Author Information........................................................................................................................ 43
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Hydrogen-Fueled Medium- and Heavy-Duty Vehicles
Introduction
The recent rise in hydrogen fuel cell-electric vehicles (FCEVs) is often focused on light-duty
vehicles (LDVs, i.e., cars), and there were 16,900 fuel cell-electric LDVs registered in the United
States at the end of 2023.1 Vehicle manufacturers are nonetheless announcing demonstration of
small numbers of hydrogen fuel cell medium- and heavy-duty vehicles (MHDVs, or “trucks”),
which are vehicles 10,000 pounds (lb.) or heavier, including cargo, such as delivery trucks, refuse
haulers, tow trucks, and motor coaches.2 In small demonstration programs, the fuel cell-electric
powertrain has been shown to be generally adaptable to the requirements of these vehicles and
may carry with it certain advantages, such as superior torque when moving from a standstill (i.e.,
“launch”), lower noise, and no tailpipe emissions. Early deployment is focusing on whether
hydrogen fuel cell-electric MHDVs could provide onboard fuel storage to satisfy the necessary
refueling range and have the cargo space- and weight-capacity to move goods. Programs and
policies in the United States and in other countries focus on hydrogen-fueled MHDVs as a means
of reducing fossil fuel use to decarbonize transportation.
FCEVs have been sold, leased, or demonstrated in sizes ranging from light-duty vehicles up to
Class 8 tractor-trailer combination vehicles with gross vehicle weight (GVW) ratings3 of up to
80,000 lb. FCEVs use a fuel cell to power an electric motor and to drive other loads such as
accessories and parasitic loads—the pumps, compressors, and fans necessary for vehicle
operation. In the fuel cell most commonly found in vehicles, the polymer electrolyte membrane or
proton-exchange membrane (PEM) fuel cell, hydrogen stored on board combines with
atmospheric oxygen to provide electric power while giving off only heat and water.4 When
referring to fuel cells hereinafter, the report is understood to be talking about hydrogen-fueled
PEM.
The current rolling stock of MHDVs, especially the tractor-trailers with GVW rating of
80,000 lb., rely predominantly on diesel fuel.5 Increasingly, the federal government, states, and
private enterprise have been supporting the commercialization of MHDVs that use alternative
fuels and noncombustion powertrains, including those with fuel cells. Fuel cell-electric MHDVs
are currently limited to concept vehicles and small demonstrations and retail sales. Analyses and
demonstrations have shown that fuel cell-electric MHDVs in certain weight classes could have
vehicle performance attributes that offer a viable alternative to internal combustion enginevehicles.
FCEVs require fuel and an infrastructure to deliver that fuel to a convenient dispensing point.
Accomplishing this may require a change from the topology of today’s hydrogen transmission
1 U.S. Department of Energy (DOE), Alternative Fuels Data Center (AFDC), “Hydrogen Vehicles Registered in 2023,”
https://afdc.energy.gov/transatlas#/?fuel=HY&view=vehicle_count. “Light-duty vehicles” generally refers to cars but,
in some contexts, has a more rigorous definition.
2 Some sources refer to any non-passenger vehicle that is 8,500 pounds (lb.) or heavier as a “heavy-duty vehicle” for
simplicity. See, for example, 81 Federal Register 73484 (October 25, 2016).
3 The gross vehicle weight (GVW) ratings are specified by the manufacturers to be the loaded weight of a single
vehicle. These include the weight of the empty vehicle plus the weight of fluids, passengers, and cargo. 49 C.F.R.
§§523.2 and 571.3; 49 U.S.C. §32901; DOE, AFDC, Vehicle Weight Classes and Categories, https://afdc.energy.gov/
data/10380.
4 National Research Council and National Academy of Engineering, The Hydrogen Economy: Opportunities, Costs,
Barriers and R&D Needs (National Academies Press, 2004).
5 Diesel Technology Forum, “New Analysis Shows How Diesel, Natural Gas, Electric and Gasoline Power the Nation’s
Commercial Truck, Transit and School Bus Fleets,” press release, July 13, 2022, https://enginetechforum.org/pressreleases/posts/new-analysis-shows-how-diesel-natural-gas-electric-and-gasoline-power-the-nations.
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and delivery methods, which were built to deliver large amounts of hydrogen to small numbers of
industrial users. Widespread use of hydrogen faces challenges of scaling up for industrial
production, mobilizing capital, obtaining permits and regulatory approvals, and building or
retrofitting facilities to use or make hydrogen. In vehicle applications, recent fuel prices have
ranged from $16 per kilogram (/kg) in early 2022 to $35/kg in late 2024, dispensed at the
refueling station, whereas, to be competitive with incumbent technologies, the price of dispensed
hydrogen would need to be in the range of $4/kg to $5/kg.6
The report begins with an overview of the characteristics of MHDVs generally; the federal
programs focused on deployment of MHDVs; the technical requiements and status of fuel cellelectric MHDVs, including a comparison to battery-electric MHDVs and diesel MHDVs; and
vehicle cost. The report then turns to recent developments in programs aimed at deployment of
fuel cell-electric MHDVs and bills in the 118th Congress that addressed deployment. The report
concludes with issues Congress may consider.
Status and Characteristics of MHDVs
Variety and Configuration of MHDVs
MHDVs provide services essential to economic activity, including goods movement, passenger
mobility, refuse collection and hauling, cement mixing and delivery, and so forth. To be capable
of these tasks, MHDVs are built with a wide variety of chassis sizes and shapes, engines, weights
(from 10,000 lb. to 80,000 lb., counting cargo), and body types.7 Often, the original equipment
manufacturer (OEM or, sometimes, simply the “OE”) makes the chassis before an after-market
upfitter adds a modified body to meet the needs of the customer. For example, heavy-duty pickup
truck chassis can be upfit to become motor coaches or shuttle buses.8 The various missions of
MHDVs call for different vehicle attributes, and the existence of numerous MHDV chassis and
body combinations frustrate attempts at generalizing.
The discussion in this report focuses on two commonly used trucks that make up large fleets.
Small trucks for parcel delivery are in the Class 4 vehicle category—14,001 lb. to 16,000 lb.,
including cargo.9 At the other extreme are long-haul Class 8, articulated tractor-trailer
combination vehicles—a powered tractor connected to a non-powered multi-axle semi-trailer10—
some of which travel at cruise conditions (e.g., a constant speed of 55 mph or 65 mph) for several
hundred miles per day. Further information on the weight classes used for highway operation and
for fuel economy may be found at the Department of Energy’s (DOE’s) Alternative Fuels Data
Center.11
6 Daniel Weeks and Santiago Canel Soria, “California Hydrogen Pump Prices for Light-Duty Vehicles Reach New
Highs,” S&P Global, October 1, 2024. CRS converted the values given for dollars per gallon-gasoline-equivalent at 1for-1 to get dollars per kilogram-hydrogen. DOE, AFDC, Fuel Properties Comparison, https://afdc.energy.gov/fuels/
properties?fuels=HY&properties=energy_ratio.
7 49 C.F.R. §565.15 and 49 U.S.C. §32901(a)(7). The weights are GVW ratings and include the weight of fluids,
passengers, and cargo. DOE, AFDC, Vehicle Weight Classes and Categories, https://afdc.energy.gov/data/10380.
8 Ford Motor Company, Commercial Upfits, 2025, https://www.fordpro.com/en-us/upfit/.
9 See 49 C.F.R. §565.15 for the list of vehicle classes by GVW rating.
10 Semi-trailers are called that because their axle and wheel configuration does not allow them to roll unless hitched to a
tractor. Federal regulations generally allow semi-trailers on roads, and, as to length, require that regulations issued by
states cannot restrict the length to below 48 feet or the limit in effect on December 1, 1982, whichever is greater.
23 C.F.R. §658.13.
11 DOE, AFDC, Vehicle Weight Classes and Categories, https://afdc.energy.gov/data/10380.
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There were roughly 4 million trucks in fleets in 2021, counting Class 3, 4, and 5 vehicles and
government, rental and commercial concerns.12 The ownership of Class 7 and Class 8 tractors can
range from small independent operators to large for-hire and private or government fleets that
have several thousand or more tractors.13 There were roughly 154,000 Class 7 tractors and
2.5 million Class 8 tractors in use during 2021.14
Operations
Fuel Consumption and Range
Among MHDVs, the dominant consumer of energy is the Class 8 tractor, typically pulling 53-foot
semi-trailers to move goods. Together with the lighter Class 7 tractor, these are responsible for
three-quarters of diesel fuel consumption in on-road vehicles (a designation that includes cars).15
The remaining MHDV fuel is consumed by vehicles that in some cases can have substantial
power requirements for controlling cargo temperature, performing vocational activities such as
lifting a worker in a bucket to perform repair services, winching a stuck vehicle, mixing concrete,
and other functions. In some instances, the energy requirements necessitate installing an auxiliary
power unit (APU) on board the vehicle.16
Class 8 tractor-trailers travel varying distances in a day.17 Regional-haul Class 8 vehicles average
430 miles daily, according to one study that looked at eight cases.18 Long-haul Class 8 vehicles
are notionally those vehicles that travel point-to-point, for example, from a port complex to a
distribution center. Regional haul vehicles may also travel point-to-point, making the distinction
between regional and long haul somewhat artificial. Drayage trucks generally include on-road
vehicles of 26,000 lb. GVW rating and above whose activities include operating in or transiting
the boundary of a port or railyard for the purpose of moving containers or bulk cargo.19 A Class 8
drayage truck might travel 150 miles in a single day, according to Toyota.20
12 S. Davis and R. Boundy, Transportation Energy Data Book, Edition 40, Oak Ridge National Laboratory, ORNL-
5198, June 2022, p. 8-3, https://tedb.ornl.gov/wp-content/uploads/2022/03/TEDB_Ed_40.pdf#page=228. Fleets include
15 or more vehicles in operation or 5 or more vehicles purchased in a year.
13 Transport Topics, Top 100 Private Carriers: 2022, https://pages.ttnews.com/rs/905-BBW-876/images/
tt100Private22.pdf.
14 Davis and Boundy, Transportation Energy Data Book, Edition 40, p. 5-4.
15 Bureau of Transportation Statistics and U.S. Census Bureau, VIUS PUF Tabulation Tool, 2023-12, December 23,
2023, https://data.bts.gov/stories/s/VIUS-PUF-Draft/mc6b-y96m/.
16 An example is the APU on fire engines, which can be a diesel generator that substitutes as a power source in place of
the idling main engine. Pierce Manufacturing, “4 Operational Factors for Fire Truck Idle Reduction Technology:
Auxiliary Power Unit (APU),” blog post, January 12, 2021, https://www.piercemfg.com/pierce/blog/4-operationalfactors-for-fire-truck-idle-reduction-technology.
17 J. Kast et al., “Designing Hydrogen Fuel Cell Electric Trucks in a Diverse Medium and Heavy Duty Market,”
Research in Transportation Economics, vol. 70 (October 2018), pp. 139-147.
18 R. Mihelic et al., Making Sense of Heavy-Duty Hydrogen Fuel Cell Tractors, North American Council for Freight
Efficiency, December 16, 2020, p. 59, https://nacfe.org/wp-content/uploads/2020/12/NACFE-Guidance-on-HydrogenFuel-Cell-Tractors-FINAL-121620.pdf.
19 See, for example, California Air Resources Board (CARB), Advanced Clean Fleets Regulation Proposed Draft
Regulation Language: Drayage Truck Requirements, 17 CCR §95691 (draft), September 9, 2021, p. 4,
ww2.arb.ca.gov/sites/default/files/2021-08/210909acfdraftdrayage.pdf.
20 Andrew Krok, “UPS Will Start Using Toyota’s Zero-Emission Hydrogen Semi Trucks,” CNET, April 23, 2019,
https://www.cnet.com/roadshow/news/ups-toyota-project-portal-hydrogen-semi-trucks/.
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Corridors
The long-haul and regional-haul vehicles described above can be thought of as participants in
transportation corridors. Transportation corridors resist categorization but evolved from the
notion of economic corridors providing access to markets for agriculture or natural resource
extraction.21 Examples of present-day corridors include the 275-mile Texas East Central Corridor,
which includes I-45 and connects Galveston, Houston, and Dallas. Other corridors can be over
1,000 miles long, such as the multimodal Eastern Seaboard Corridor System (I-85/I-95), which
serves passengers and freight. In 1991, the Intermodal Surface Transportation Efficiency Act
(ISTEA; P.L. 102-240) noted the importance of regional interconnection while designating over
20 transportation corridors for integration into the National Highway System.
Another type, called alternative fuel corridors by the Federal Highway Administration (FHWA),
consists of charging and fueling infrastructure.22 Section 11401 of IIJA authorized grants for
charging and fueling infrastructure along designated “national alternative fueling corridors”
defined in the Fixing America’s Surface Transportation Act (FAST Act; P.L. 114-94). The FAST
Act required the Secretary of Transportation to designate such corridors to have refueling at
“strategic locations along major national highways to support changes in the transportation
sector” in support of various goals. Generally speaking, such corridors could be specified so that
vehicles traveling along them encounter one refueling station within a few miles of the highway
at a given interval (e.g., 150 miles in the case of hydrogen).23
Status of Hydrogen and MHDVs
As of June 2024, there were greater than 90,000 hydrogen FCEVs in use globally. Of these, the
majority were light-duty vehicles; slightly less than one-quarter—roughly 20,000—were trucks
and buses.24 Globally, trucks lag light-duty vehicles in adopting fuel cell-electric powertrains by
more than three to one, according to data from the International Energy Agency (IEA) of the
Organisation for Economic Co-operation and Development.25 One study estimated the
introduction of fuel cell-electric heavy-duty trucks to be roughly 10 years behind light-duty
vehicles.26
When issuing the Phase 2 rule for MHDV fuel consumption and GHG emissions, the National
Highway Traffic Safety Administration (NHTSA) and the U.S. Environmental Protection Agency
(EPA) noted the tendency for the “heavy-duty sector to significantly lag the light-duty sector in
the adoption of advanced technologies” due to greater manufacturing risk at the higher price
point, the premium placed on reliability, and the lower sales volumes relative to light-duty
21 Transportation Research Board, Quantifying the Impacts of Corridor Management (2024) (National Academies
Press, 2024), p. 93, http://nap.nationalacademies.org/27477.
22 Emily Biondi, Associate Administrator, Request for Nominations—Alternative Fuel Corridors (Round 8/2024),
Federal Highway Administration, June 14, 2024, p. 2, https://www.fhwa.dot.gov/environment/
alternative_fuel_corridors/nominations/2024_request_for_nominations_r8.pdf.
23 Biondi, Request for Nominations—AFCs, p. 3.
24 The trucks in these data include the MHDV-weight trucks of U.S. statistics and, in addition, include those vehicles
weighing at least 3.5 metric tons, or about 7,700 lb., but less than 10,000 lb. GVW. In effect, more vehicles were
counted. International Energy Agency (IEA), Global Hydrogen Review 2024, October 2024, p. 39, https://www.iea.org/
reports/global-hydrogen-review-2024.
25 IEA, Global Hydrogen Review 2024, October 2024, p. 39.
26 IEA, Energy Technology Perspectives 2020, Paris, 2021, p. 156. The study does not define light-duty vehicles, but in
the United States these are vehicles with GVWs less than 8,500 lb. See DOE, AFDC, Vehicle Weight Classes and
Categories, https://afdc.energy.gov/data/10380.
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vehicles.27 A DOE strategy for zero-emission freight corridors observed that the adoption of
FCEVs by freight operators was “on a different timeline than EVs [electric vehicles]” but could
be “assumed to grow as conditions improve.”28
Demonstrations and Beyond
DOE anticipates that widespread adoption of medium- and heavy-duty fuel cell-electric vehicles
would be preceded by success at demonstration scale.29 For example, DOE recently funded a
15-vehicle demonstration project of fuel cell-electric hybrid delivery vans, a medium-duty
vehicle.30 Other demonstration projects in the United States have focused on Class 8 combination
vehicles, discussed below. Overall, these demonstrations have shown that fuel cell-electric
MHDVs could offer a viable alternative to internal combustion engine-vehicles in certain MHDV
categories.
The Shore-to-Store project at the Port of Los Angeles completed its initial phase in February 2022
to demonstrate the shoreside movement (i.e., drayage) of off-loaded goods by zero-emission
vehicles (ZEVs). Vehicles providing drayage services can experience long idle times while
vehicles are waiting in queues, leading to tailpipe emissions; these emissions could be mitigated
through use of a noncombustion powertrain.31 Shell Oil Products US built and operated two
hydrogen refueling stations (HRS) as part of the Shore to Store project. Kenworth, a brand of the
truck manufacturer group PACCAR, provided 10 prototype vehicles—the hydrogen fuel cell
version of its T680, a Class 8 tractor. The vehicles used Toyota’s fuel cell-electric system.32 The
cargo capacity was 36,000 lb.33
A 2019 on-road demonstration, coordinated by the North American Council on Freight
Efficiency, collected on-road data on 10 fuel cell-electric Class 8 vehicles in regional haul
operation over a three-week period in October 2019.34
27 U.S. Environmental Protection Agency (EPA) and U.S. Department of Transportation (DOT), National Highway
Traffic Safety Administration (NHTSA), “Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and
Heavy-Duty Engines and Vehicles—Phase 2,” 81 Federal Register 73498 (October 25, 2016).
28 Joint Office of Energy and Transportation, National Zero-Emission Freight Corridor Strategy, DOE/EE-2816 2024,
September 2024, p. 13, https://driveelectric.gov/files/zef-corridor-strategy.pdf.
29 DOE, Pathways to Commercial Liftoff: Clean Hydrogen, March 2023, p. 60, https://liftoff.energy.gov/wp-content/
uploads/2023/03/20230320-Liftoff-Clean-H2-vPUB.pdf.
30 DOE, Hydrogen and Fuel Cell Technologies Office, Hydrogen Fuel Cell Hybrid Electric Delivery Vans in
Disadvantaged Communities, DOE/EE-2742, https://www.energy.gov/eere/fuelcells/articles/hydrogen-fuel-cell-hybridelectric-delivery-vans-disadvantaged-communities#:~:text=Disadvantaged%20Communities,The%20Department%20of&text=The%20project%20will%20replace%2015,is%20both%20global%20and%20local.
31 Andrew J. DeCandis, Hydrogen Fuel-Cell Electric Hybrid Truck Demonstration: Final Technical Report, Gas
Technology Institute and Houston-Galveston Area Council, DE-EE0005978, https://www.osti.gov/servlets/purl/
1496037.
32 Kenworth, “Port of Los Angeles Rolls Out Hydrogen Fuel Cell Electric Freight Demonstration,” press release,
June 7, 2021, https://www.kenworth.com/about-us/news/port-of-los-angeles-rolls-out-hydrogen-fuel-cell-electricfreight-demonstration/; and Port of Los Angeles et al., The Port of Los Angeles Zero- and Near-Zero-Emission Freight
Facilities “Shore to Store” Project: Final Project Report, Grant Number: G17-ZNZE-10, Port of Los Angeles
Agreement no. 19-3639, May 10, 2023, p. 9, https://ww2.arb.ca.gov/sites/default/files/2023-05/POLAFinal%20Report.pdf.
33 C. Hunter et al., Spatial and Temporal Analysis of the Total Cost of Ownership for Class 8 Tractors and Class 4
Parcel Delivery Trucks, National Renewable Energy Laboratory (NREL), NREL/TP-5400-71796, September 2021,
p. 82, https://www.osti.gov/biblio/1821615.
34 Ballard Power Systems and North American Council for Freight Efficiency, Fuel Cell Electric Trucks: An Analysis
of Hybrid Vehicle Specifications for Regional Freight Transport, June 2020, p. 18, https://nacfe.org/wp-content/
uploads/2020/06/Informational_NACFE_BPS_Truck_White_Paper_Download.pdf.
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Prizes and Certifications for Technology Development and Deployment
Governments and civil society have competitively awarded prizes for technologies in development and
deployment. Prizes often confer both monetary benefits and nonmonetary benefits, such as recognition.35
Federally awarded prizes are viewed as advantageous by some, as these prizes shift the risk of success or failure to
the private entity; the federal government pays only for success.36
The federal government has awarded 100 such prizes annually; many of the prizes are focused on applied research
and technology development. An analysis by the Office of Science and Technology Policy (OSTP) found that the
majority of federally awarded prizes in FY2019 and FY2020 (177 total) were for research and development, proofof-concept, or prototypes.37 An example of this is the Lithium-Ion Battery Recycling Prize, awarded by DOE and
including three phases: concept, prototype, and demonstration.38 The OSTP analysis found that, government-wide,
roughly one-fourth of prizes awarded were for latter-stage development corresponding to scale-up or
commercialization.39 In FY2019 and FY2020, DOE awarded 12 prizes that were for scale-up or commercialization.
Civil society makes prize awards as well.
Prizes can have a measurable, quantifiable goal: the Bright Tomorrow Lighting Prize, or the L-Prize, was specified
in Section 655 of the Energy Independence and Security Act of 2007 (P.L. 110-140) to meet a list of specifications
related to power consumption (i.e., watts), luminous flux (a measure of brightness), durability, and so forth.40 The
L-Prize, awarded in 2011, was thus defined prospectively.41 In this respect, the L-Prize was similar to the Ansari
XPRIZE, which also established criteria prospectively, for the first privately funded vehicle to reach an altitude of
100 kilometers, coinciding with the Karman line—the demarcation altitude beyond which outer space begins.42
Some observers note that such prizes can induce technological change, citing the example of the British Longitude
Act of 1714, which offered a prize for a method of determining longitude while at sea.43
Other prizes can be awarded for fulfilling broad objectives, such as the Green Fleet Award for environmentally
responsible fleet operations, made by the National Association of Fleet Administrators—an example of an award
made by civil society.44 The City of Phoenix won the top prize in 2023.45 Such nonmonetary prizes aim for greater
public recognition.46
Still another type of award takes the form of certifications for an entity’s deployment of commercial technologies.
The Leadership in Energy and Environmental Design (LEED) certification is awarded by the U.S. Green Building
35 CRS Report R45271, Federal Prize Competitions, by Marcy E. Gallo.
36 CRS Report R45271, Federal Prize Competitions, by Marcy E. Gallo.
37 Office of Science and Technology Policy (OSTP), Implementation of Federal Prize and Citizen Science Authority:
Fiscal Years 2019-20, May 2022, p. A-8, https://bidenwhitehouse.archives.gov/wp-content/uploads/2022/05/05-2022Implementation-of-Federal-Prize-and-Citizen-Science-Authority.pdf.
38 OSTP, Implementation of Federal Prize, p. B-97; and DOE, EERE, Lithium-Ion Recycling Prize,
https://www.energy.gov/eere/lithium-ion-recycling-prize.
39 OSTP, Implementation of Federal Prize, p. A-8.
40 The full criteria are listed at 42 U.S.C. §17243(b). See also Sen. Jeff Bingaman, “The L-Prize: Recognizing
Innovations,” The Hill, September 29, 2009, https://thehill.com/homenews/186862-the-l-prize-recognizinginnovations/.
41 Light Directory, “DOE Announces Philips as First Winner of the L Prize Competition,” August 2, 2011,
https://www.lightdirectory.com/news-DOE-Announces-Philips-As-First-Winner-Of-The-L-Prize-Competition.htm.
42 The prize specified a vessel carrying three passengers and doing so twice within two weeks’ time. See XPRIZE
Foundation, “Launching a New Space Industry,” 2024, https://www.xprize.org/prizes/ansari; Tim Sharp,
“SpaceShipOne: The First Private Spacecraft,” Space.com, https://www.space.com/16769-spaceshipone-first-privatespacecraft.html, March 15, 2019; and Jonathan C. McDowell, “The Edge of Space: Revisiting the Karman Line,” Acta
Astronautica, vol. 151 (October 2018), pp. 668-677.
43 National Academies of Sciences, Engineering, and Medicine, The Role of Inducement Prizes: Proceedings of a
Workshop in Brief (2020) (National Academies Press, 2020), p. 1.
44 NAFA Fleet Management Association, “Green Fleet Awards,” https://www.nafa.org/awards/green-fleet-awards/.
45 City of Phoenix, “Phoenix Named Top Green Fleet of 2023,” September 5, 2023, https://www.phoenix.gov/
newsroom/public-works/2855.
46 Recognition prizes could also include a cash prize.
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Council for buildings that satisfy several normative criteria.47 The certification criteria take account of building
systems—such as heating, ventilation, and air conditioning—that are available commercially.
SmartWay is a certification for heavy-duty vehicle fleets that focuses on freight transportation efficiency (i.e.,
goods movement).48 SmartWay also maintains a list of verified technologies, which can include aerodynamic fittings
for trucks; these technologies are certified by third-party laboratories.49
DOE also supported concept vehicles in its SuperTruck program that could be viewed as early
demonstrations.50 Three of the OEM participants—Daimler Truck North America,
General Motors, and Ford Motor Co.—are developing Class 4 to Class 6 fuel cell-electric
vehicles operating in commercial fleets; one of the participants plans to demonstrate two Class 8
fuel cell-electric vehicles as well.
The numerous demonstrations discussed above are a precursor to the possible advent of
production vehicles. In the case of Shore to Store, the demonstration relied on prototypes.
Kenworth crafted these in an initial group of five, learned from this first phase, and then made
modifications to the vehicle for a second phase of five more vehicles.51 Building these 10 vehicles
was nonetheless different in size and scale from a production run.52
The progression from prototype to a marketable production vehicle, and the problems sometimes
encountered along the way, is sometimes called the “valley of death”53 or the market formation
stage.54 At this valley or stage, potential new technologies may struggle to compete with the
incumbent technology for a variety of reasons, including the advantage conferred on the
incumbent through economies of scale or the incumbent’s knowledge gleaned from experience.55
Reaching commercial success for a vehicle requires lowering the cost, achieving required
durability and reliability, satisfying customer attributes (such as noise, vibration, and harshness),
complying with regulatory requirements, and so forth.56 Achieving the desired economies of scale
would, in the view of some analysts, require moving to much larger numbers of vehicles than
those involved in demonstrations. MHDVs are not produced in large, million-vehicle production
runs of LDVs. DOE’s May 2024 Multi-Year Program Plan (MYPP) notes that the barriers to
large-scale adoption make up one of the three categories of challenges that remain after decades
of research, development, demonstration, and deployment activities.57 The federal government
47 For the current list of these criteria, see U.S. Green Building Council, “LEED Rating System,”
https://www.usgbc.org/leed.
48 EPA, “Learn About SmartWay,” November 9, 2023, https://www.epa.gov/smartway/learn-about-smartway.
49 EPA, “Learn About SmartWay Verified Technologies,” May 13, 2024, https://www.epa.gov/smartway/learn-aboutsmartway-verified-technologies.
50 Sunita Satyapal, “U.S. DOE Hydrogen Program Annual Merit Review (AMR) Plenary Remarks,” slide presentation,
June 5, 2023, p. 53, https://www.hydrogen.energy.gov/docs/hydrogenprogramlibraries/pdfs/review23/
plenary1_satyapal_2023_o.pdf.
51 Port of Los Angeles et al., “Shore to Store” Project, p. 9.
52 81 Federal Register 73493 (October 25, 2016), footnote 57.
53 IHS Markit and Energy Futures Initiative, Advancing the Landscape of Clean Energy Innovation, February 2019,
p. 37, https://efifoundation.org/reports/advancing-the-landscape-of-clean-energy-innovation/.
54 A. Grubler et al., “Policies for the Energy Technology Innovation System (ETIS),” in Global Energy Assessment:
Toward a Sustainable Future, ed. Thomas B. Johansson et al. (Cambridge University Press, 2012), p. 1676.
55 Grubler et al., “Policies for ETIS,” p. 1676.
56 National Research Council and National Academy of Engineering, The Hydrogen Economy: Opportunities, Costs,
Barriers and R&D Needs (National Academies Press, 2004), p. 26.
57 The other two challenges DOE identified are (1) reducing cost and improving performance and (2) de-risking and
scaling up technologies across the value chain. DOE, EERE, Hydrogen and Fuel Cell Technologies Office Multi-Year
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and civil society offer prizes and certifications for development and deployment successes (see
text box above).
Investment in fuel cell-electric MHDVs is a risk for the public and private sectors because it is
unknown if they will ever reach commercial scale. Currently the fueling infrastructure can
support limited types of operations such as the relatively self-contained ecosystem of a port,
although—as discussed in “Regional Clean Hydrogen Hubs”—some regions have plans to build
out refueling infrastructure to support long-haul operations. Fuel cell-electric MHDVs would, as
noted, compete on cost and performance with diesel trucks, a mature technology. Unlike diesel
trucks, fuel cell-electric vehicles do not have widely deployed technicians and training centers.
Infrastructure
The infrastructure for refueling hydrogen FCEVs is geographically limited and consistent with a
demonstration or an early deployment phase. The IEA assesses HRS to be at a high level of
technology readiness but acknowledges that the readiness level is short of widespread
deployment.58 As of January 30, 2025, California had 42 public retail HRS in operation for LDVs,
with a further 18 not currently in operation.59 DOE data showed 7 HRS that could service Class 3
through Class 8 vehicles in North America, with 3 of those capable of servicing Class 7 and
Class 8.60 According to DOE, all but 6 of the public HRS for LDVs in the United States are in
California.61 The California Energy Commission envisages at least 13 of the projected 175 lightduty retail HRS by 2027 will also be equipped to serve MHDVs.62 In 2023, the Wall Street
Journal reported that truck-maker Nikola was working with partners to develop a fueling network
for hydrogen trucks and was anticipating 50 HRS to be in place across the United States within
five years.63 The Alliance for Renewable Clean Hydrogen Energy Systems (ARCHES), one of the
Regional Clean Hydrogen Hubs, envisages 60 HRS for MHDVs as part of its hub.64
Within the United States, a network of trucks and pipelines currently transports one-third of the
10 million metric tons (Mt) of on-purpose hydrogen65 manufactured annually for large industrial
Program Plan, DOE/GO-102024-6266, May 2024, p. vii, https://www.energy.gov/sites/default/files/2024-05/hftomypp-2024.pdf.
58 IEA, ETP Clean Energy Technology Guide, October 22, 2024, https://www.iea.org/articles/etp-clean-energytechnology-guide.
59 Hydrogen Fuel Cell Partnership, FCEV Sales, FCEB, and Hydrogen Station Data, January 30, 2025,
https://h2fcp.org/by_the_numbers.
60 DOE, AFDC, Hydrogen Fueling Station Locations, interactive map, https://afdc.energy.gov/fuels/
hydrogen_locations.html#/find/nearest?fuel=HY.
61 DOE, AFDC, Hydrogen Fueling Station Locations, interactive map, https://afdc.energy.gov/fuels/
hydrogen_locations.html#/find/nearest?fuel=HY.
62 J. Berner et al., Joint Agency Staff Report on Assembly Bill 8: 2022 Annual Assessment of Time and Cost Needed to
Attain 100 Hydrogen Refueling Stations in California, California Energy Commission, CEC-600-2022-064,
December 22, 2022, p. 2, https://www.energy.ca.gov/publications/2022/joint-agency-staff-report-assembly-bill-8-2022annual-assessment-time-and-cost.
63 Paul Berger, “Hydrogen Fuel Is Gaining Traction with Truckers,” Wall Street Journal, November 15, 2023,
https://www.wsj.com/articles/hydrogen-fuel-is-gaining-traction-with-truckers-20fca3e3.
64 DOE, OCED, Regional Clean Hydrogen Hubs Program: California Hydrogen Hub (ARCHES), July 2024, p. 2.
65 Hydrogen is deemed on-purpose hydrogen when it is manufactured chiefly for the economic value of the hydrogen.
Most on-purpose hydrogen in the United States is produced for chemical and fuels manufacturing. Byproduct hydrogen
results while producing another chemical deemed to have primary value by a process that produces hydrogen
incidentally.
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customers.66 The infrastructure for hydrogen transmission in the United States is nonetheless
modest compared with that of natural gas or electricity. U.S. hydrogen pipelines operate mostly in
the Gulf of Mexico region and total 1,600 miles,67 compared with 300,000 miles of natural gas
transmission pipelines68 and nearly 160,000 miles of high-voltage electric transmission power
lines across the continental United States.69 Globally, most hydrogen pipelines are owned by
merchant hydrogen producers who sell their hydrogen to industry in bulk.70
Government Goals and Pledges
National and supranational strategy documents for hydrogen have asserted that hydrogen FCEVs
may be best suited for specific truck missions. A report prepared pursuant to the IIJA, DOE’s U.S.
National Clean Hydrogen Strategy and Roadmap, notes that hydrogen vehicles are useful in
applications “requiring long driving ranges, fast fueling, and large or heavy payloads.”71 The
Strategy and Roadmap envisages MHDVs as a way of decarbonizing an energy application that is
otherwise “difficult to electrify” by switching to a technology that delivers the same service with
electricity rather than fossil fuel.72 The U.S. National Blueprint for Energy and Emissions
Innovation in Transportation finds that long-haul heavy trucks have the most favorable long-term
potential for hydrogen in any mode of transportation.73 A European Union strategy document
notes the existence of “different requirements for light- and heavy-duty vehicles” and encourages
the use of “heavy-duty road vehicles” for long-haul applications.74 France lists “heavy-duty
mobility” as one of its three priorities in its national hydrogen strategy and observes that
“hydrogen meets the needs for high engine power and long range, particularly for captive fleets
traveling long distances.”75 The IEA expects that light-commercial vehicles76 will transition from
66 D-Y Lee et al., Life-Cycle Greenhouse Gas Emissions of By-Product Hydrogen from Chlor-Alkali Plants, Argonne
National Laboratory (ANL), ANL/ESD-17/27, December 2017, p. 1. The estimate of one-third assumes only onpurpose hydrogen is accounted for and that the approximately 3.3 million metric tons (Mt) of byproduct hydrogen from
oil refineries is not used in the denominator of the calculation.
67 Over 90%, by mile of pipeline, is in Texas and Louisiana, with 10 other states having under 35 miles each. DOE,
Hydrogen and Fuel Cell Technologies Office, “Hydrogen Pipelines,” https://www.energy.gov/eere/fuelcells/hydrogenpipelines; Hydrogen Tools, Hydrogen Pipelines, September 2016, Excel spreadsheet downloadable at
https://h2tools.org/hyarc/hydrogen-data/hydrogen-pipelines.
68 DOT, Pipeline and Hazardous Materials Safety Administration, Annual Report Mileage for Natural Gas
Transmission and Gathering Systems, May 2, 2022.
69 Energy Information Administration, “U.S. Electric System Is Made Up of Interconnections and Balancing
Authorities,” Today in Energy, July 20, 2016, https://www.eia.gov/todayinenergy/detail.php?id=27152.
70 IEA, Global Hydrogen Review 2021, October 2021, p. 44, https://www.iea.org/reports/global-hydrogen-review-2021.
71 DOE, U.S. National Clean Hydrogen Strategy and Roadmap, June 2023, p. 32, https://www.hydrogen.energy.gov/
library/roadmaps-vision/clean-hydrogen-strategy-roadmap. Prepared pursuant to Section 40314 of the Infrastructure
Investment and Jobs Act (IIJA; P.L. 117-58).
72 DOE, Hydrogen Strategy and Roadmap, p. 29.
73 DOE et al., The U.S. National Blueprint for Energy and Emissions Innovation in Transportation, DOE/EE-2674,
January 2023, p. 5.
74 European Commission, A Hydrogen Strategy for a Climate-Neutral Europe, COM(2020) 301, July 8, 2020,
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0301&from=EN.
75 Government of the French Republic, National Strategy for the Development of Decarbonised and Renewable
Hydrogen in France, September 2020, p. 10, https://www.bdi.fr/wp-content/uploads/2020/03/PressKitProvisionalDraftNational-strategy-for-the-development-of-decarbonised-and-renewable-hydrogen-in-France.pdf.
76 Following the European definition, these include vehicles with mass below 3.5 metric tons (roughly 7,700 lb.),
including cargo. IEA, Energy Technology Perspectives 2020, 2021, p. 256, https://www.iea.org/reports/energytechnology-perspectives-2020.
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battery-electric to fuel cell-electric as the requirements for such vehicles lead to longer ranges and
hours of service in the future.77
As of September 2022, 17 countries had enacted purchase price subsidies for “heavy-duty fuel
cell vehicles.”78 Globally, most policies that affect demand for hydrogen fuel and technology
focus on transportation. In many instances, these policies include hydrogen within a basket of
fuels as part of zero-emission goals.79
Federal Programs on Energy Use and Purchase of
MHDVs
Fuel Consumption Regulations
Origin
The Energy Independence and Security Act of 2007 (EISA; P.L. 110-140), Section 102(b)
(42 U.S.C. §32902 (b)), requires the Secretary of Transportation to set fuel economy standards for
“commercial” MHDVs and work trucks that will achieve the “maximum feasible improvement”
in fuel efficiency and that are “appropriate, cost-effective, and technologically feasible.”80
Section 103(b) of EISA defines commercial MHDVs to be on-highway vehicles with a GVW
rating of 10,000 lb. or more.
NHTSA’s fuel consumption standards for MHDVs are expressed in units of gallons per 1,000 tonmiles, a unit that takes account of the movement of tons of payload, reasoning this was the
purpose of some but not all MHDVs.81 For example, the NHTSA regulations set standards for the
Class 8 tractor vehicle family in model years 2024 to 2026 to be in the range of roughly 6.5 to
8 gallons per 1,000 ton-miles, depending on the configuration or subfamily (e.g., low-, mid-, or
high-roof cab; day cab or sleeper cab).82 NHTSA issued the regulations for Phase 1 of the
program in 2011 and for Phase 2 in 2016.83
77 IEA, Energy Technology Perspectives 2020, p. 155.
78 IEA, Global Hydrogen Review 2022, September 2022, p. 190, https://www.iea.org/reports/global-hydrogen-review-
2022. Heavy-duty trucks in the European scheme are those vehicles having GVW over 15 metric tons. IEA, Global
Hydrogen Review 2022, p. 43.
79 IEA, Global Hydrogen Review 2022, p. 189.
80 A work truck is any vehicle between 8,500 and 10,000 lb. GVW rating that is not a medium-duty passenger vehicle
(i.e., not designed primarily to carry passengers). An example of a work truck is a pickup truck, meaning a vehicle with
a sufficiently long cargo bed in that weight range.
81 For engines, the unit of fuel consumption is gallons per 100 horsepower-hours, a unit of energy.
82 See Table 11, “Truck Tractor Fuel Consumption Standards,” at 49 C.F.R. §535.5.
83 EPA and DOT, NHTSA, “Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and
Heavy-Duty Engines and Vehicles,” 76 Federal Register 57106 (September 15, 2011); and EPA and DOT, NHTSA,
“Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—
Phase 2,” 81 Federal Register 73478 (October 25, 2016).
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Direct Compliance
NHTSA’s regulations do not apply to individual trucks but rather to specific sets of a
manufacturer’s vehicles in a given model year. Class 8 tractors, for example, comprise a vehicle
family (i.e., a set) for determining compliance.84
Fuel Consumption Credits
A manufacturer may offset deficits in one or more vehicles in a vehicle set with fuel consumption
credits. With this compliance flexibility mechanism, the manufacturer generates credits when
vehicles in a set outperform the standard. EPA and NHTSA have stated that the credit program
“allows manufacturers to certify engines or vehicles that do not perform up to the standard and
offset them with engines or vehicles that perform better than the standard.”85
The mathematical formula for determining credits results in positive credits when a vehicle
exceeds the requirements of the standard; the size of the credits is proportional to the difference
between the standard and the vehicle performance. These credits may be averaged, banked, or
traded (ABT). The vehicle family complies when the sum of all ABT credits equals zero or a
positive number.86 Class 8 or heavy heavy-duty vehicles (see 40 C.F.R. §1037.140(5)) comprise a
distinct set under the regulations.87
Advanced Technology Vehicles and the Impact on Compliance
The NHTSA regulations include various incentives that, when utilized, make the mathematics
surrounding compliance more favorable. For example, the Phase 2 standard has provisions for
advanced technology vehicles, such as battery-electric and fuel cell-electric Class 8 tractors.
Advanced technology vehicles can add to the quantitative outperformance in two ways. First, for
calculation purposes, battery-electric and fuel cell-electric Class 8 tractors are deemed as not
consuming any fuel, so they substantially outperform the fuel consumption standards and
generate positive credits.88 Second, a fuel cell-electric vehicle would count as 5.5 vehicles for
purposes of determining compliance and would increase the credit by the same factor of 5.5.89
The presence of fuel cell-electric vehicles in a manufacturer’s fleet in sufficient numbers could
thus substantially aid with compliance. Manufacturers could view this as an incentive to include
greater numbers of fuel cell-electric MHDVs in a given model year’s production.
84 49 C.F.R. §535.10(c)(2). See also the definition of “vehicle family” and “vehicle subfamily” at 49 C.F.R. §535.4.
85 EPA, Office of Transportation and Air Quality, Fact Sheet: EPA and NHTSA Adopt Standards to Reduce
Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles for Model Year 2018
and Beyond, EPA-420-F-16-044, August 2016, https://www.nhtsa.gov/document/fact-sheet-epa-and-nhtsa-proposestandards-reduce-greenhouse-gas-emissions-and-improve.
86 49 C.F.R. §535.7(a). The compliance calculation varies according to the vehicle family and, for example, pickup
trucks and vans (Classes 2b and 3) utilize a work-factor-based target. 81 Federal Register 73740 (October 25, 2016).
Engines are also classified into distinct averaging sets.
87
81 Federal Register 73993 (October 25, 2016).
88 The fuel consumption standards may be found in Table 11 at 49 C.F.R. §535.5.
89 49 C.F.R. §535.7(f)(1)(ii).
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Federal Excise Tax
Types of Federal Excise Tax that Apply to Trucks
Federal excise taxes (FETs) apply to specific goods, services, and activities, including purchase
and use of trucks. An FET of 12% applies to the sale of trucks with a GVW over 33,000 lb.
Trucks with GVW of 55,000 lb. or above also pay an annual use tax.90 These excise taxes are one
source of support for the Highway Trust Fund, though the vast majority of support—85% to
90%—derives from motor fuel taxes.91
Exemptions to the Federal Excise Tax on Equipment
Certain idling reduction devices, which reduce fuel consumption while the vehicle is stationary,
may be exempted from the FET on truck sales (26 U.S.C. §4053(9)). The Energy Improvement
and Extension Act of 2008 (P.L. 110-343, Division B), Section 206, excluded “idling reduction
devices” and advanced insulation from the FET.92 A device must be found eligible by EPA, in
consultation with DOE and the Department of Transportation (DOT).93 APUs, which appear on
vehicles needing continuous electric power for refrigeration or other functionality, are generally
classified as an idling reduction technology. EPA currently exempts a number of commercially
available APUs; exempted APUs are generally reciprocating engines that run off of a propane
tank or diesel fuel.94 Two bills introduced in the 118th Congress—S. 694, the Modern, Clean, and
Safe Trucks Act of 2023, and the companion bill, H.R. 1440—would have done away with the
truck purchase FET entirely.
Vehicle Requirements: Range and Cargo Capacity
Overview
The discussion in this section applies to Class 8 tractor-trailer combination vehicles—a powered
tractor connected to a non-powered multi-axle trailer—and smaller straight trucks (typically
Class 4) that deliver goods. See Figure 1. The Class 8 vehicles are expected to deliver those
goods to a destination that could be several hundred miles distant. The advent of battery-electric,
fuel cell-electric, and other alternative powertrains has caused analysts to consider whether these
vehicles can replace the incumbent technology, the internal combustion engine powertrain.
Though there is no one factor that determines the success of a new vehicle powertrain, for this
specific application analysts have attempted to isolate a set of factors that could lead to success.
Almost all of the vehicles considered in the simulations described below were able to haul typical
cargo loads and perform adequately according to several performance indicators. The empty
90 DOT, FHWA, Office of Highway Policy Information, “Heavy Vehicle Use Tax,” June 23, 2020,
https://www.fhwa.dot.gov/policyinformation/hvut/mod1/whatishvut.cfm.
91 CRS Report R46938, Federal Excise Taxes: Background and General Analysis, by Anthony A. Cilluffo; and CRS
Report R47022, Federal Highway Programs: In Brief, by Robert S. Kirk.
92 26 U.S.C. §4053(9).
93 EPA, “Learn About Federal Excise Tax Exemption,” May 18, 2024, https://www.epa.gov/verified-diesel-tech/learnabout-federal-excise-tax-exemption#:~:text=
The%20truck%20excise%20tax%2C%20which,and%20remitted%20by%20the%20seller.
94 EPA, “List of Idling Reduction Technologies (IRTs) That Are Eligible for the Federal Excise Tax Exemption,”
May 17, 2024, https://www.epa.gov/verified-diesel-tech/list-idling-reduction-technologies-irts-are-eligible-federalexcise-tax.
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weights of the vehicles vary, mostly due to differences in powertrains and energy storage, and the
following discussion illuminates how cargo weight and driving range involve trade-offs.
The analyses described in this section consider the powertrain performance and the cargo capacity
of simulated vehicles, including fuel cell-electric MHDVs. The results of these simulations
suggest that the performance of the fuel cell powertrain could support the operating range and
cargo requirements of truck operators. Similar to the demonstrations discussed above in “Status
of Hydrogen and MHDVs,” the simulations support a finding that fuel cell-electric MHDVs in
certain weight classes could perform sufficiently well and offer a viable alternative to internal
combustion engine-vehicles.
Figure 1. Examples of Class 4 and Class 8 Vehicles
Source: U.S. Department of Energy, Alternative Fuels Data Center, Types of Vehicles by Weight Class, June 2012,
https://afdc.energy.gov/data/10381.
Notes: Class 4 trucks (left) include a city delivery truck and a walk-in truck. The Class 8 truck (right) is a tractor
capable of pulling a 53-foot semi-trailer.
Performance Requirements
Comparing vehicles with different types of powertrains that fulfill the same mission requires the
analyst or product development team to specify the performance requirements and other vehicle
attributes. Generally speaking, the engine will need to provide sufficient torque over a range of
engine speeds to move the vehicle through its duty cycle. Diesel, fuel cell-electric, and batteryelectric trucks will not perform identically and, for example, at the same engine speed may not be
able to summon as much torque or may consume fuel at a faster or slower rate.95
The performance requirements are selective and stylized and do not challenge the powertrain to
run at all operating points that might be encountered during real-world conditions.96 Performance
requirements can include sufficient cruise speed, minimum acceleration times from 0 mph to
30 mph and 0 mph to 60 mph, and maximum continuous speeds in both flat topographies and on
grade (i.e., the speed a vehicle maintains at a given slope, typically 6% rise-over-run).97 Such
performance characteristics may be expressed in maps or graphic plots of the key performance
attributes of the powertrain as they vary over the duty cycle of the vehicle.98 These maps or plots
offer insight into the overall performance and fuel consumption rate of an engine or vehicle.99
95 The measure of engine speed is the angular velocity of the crankshaft, similar to revolutions per minute (RPMs) but
greater by a factor of 2π. Power is the mathematical product of engine speed and torque.
96 The operating points would, in one conception, be a plot of fuel-speed-load, that is, a graphic representation of the
engine fuel consumption, engine speed, and torque at a set of operating points.
97 For an illustration of how the performance requirements might relate to the operation and performance of the engine,
see Figure 5 in J. Marcinkoski et al., “Driving an Industry: Medium and Heavy Duty Fuel Cell Electric Truck
Component Sizing,” World Electric Vehicle Journal, vol. 8, no. 1 (March 25, 2016), pp. 78-89, https://doi.org/10.3390/
wevj8010078.
98 See, for example, Figure 5 in J. Marcinkoski et al., “Driving an Industry: Medium and Heavy Duty Fuel Cell Electric
Truck Component Sizing,” World Electric Vehicle Journal, vol. 8, no. 1 (March 25, 2016), pp. 78-89, https://doi.org/
10.3390/wevj8010078.
99 Strictly speaking, the fuel component of the fuel-speed-load characteristics applies only to diesel or gasoline engines.
(continued...)
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Crucially, the fuel consumption rate, in concert with the tank size, will determine the vehicle
range.
The performance requirements, in addition to characterizing the kinetics of the vehicle, provide a
goal or target to be met during the component design and sizing exercise.100 Designers could
choose one particular motor size and continuous power rating for the simulation run and observe
whether the performance requirements are satisfied. If not, the simulation would be iterated at a
higher power rating and so on until the requirements are met and a solution achieved.101
The powertrain must respond to the torque request the driver makes when pressing the accelerator
pedal and must satisfy the demand for mechanical power.102 This demand, generally speaking, is
influenced by the types of activities the vehicle performs. Small trucks for parcel delivery, often
Class 4, will have frequent start-stop movements and overall urban driving characteristics. Longhaul Class 8 tractor-trailer combination vehicles might travel at cruise conditions (e.g., a constant
speed of 55 mph or 65 mph) for several hundred miles per day. When accelerating, the torque
requirement will be higher than at constant speeds, defining a further performance requirement.103
Cargo Requirements
Today’s long-haul vehicles can support payloads at the legal maximum for on-highway
movements with sufficient fuel and satisfactory engine performance to support daily operating
ranges and duty cycles. The ability to haul the same payload as today’s vehicles is one of the key
requirements any MHDV based on alternative powertrains would need to satisfy.
Class 8 combination vehicles are rated at up to 80,000 lb. GVW (combined) and, if fully laden,
could have payloads as high as 50,000 lb. or greater depending on the weight of the tractor plus
empty trailer.104 Often, in practice, the available cargo volume in the trailer will fill up, or “cube
out,” before the maximum weight can be reached. One estimate based on the operations of a large
fleet found that this occurs 80% of the time.105 The payloads discussed below reflect this, and the
GVW of the test vehicles simulated in the analyses are mostly below 80,000 lb.
The 80,000 lb. de facto limit derives from federal law, which, with certain exceptions, restricts
GVW on the Interstate Highway System to no more than 80,000 lb. or the maximum weight
allowable under prevailing state law or regulation in effect as of July 1, 1956, whichever is
greater (23 U.S.C. §127(a)(2)). Federal law sets a maximum single axle weight of 20,000 lb. and
a maximum tandem (double) axle weight of 34,000 lb. and requires that maximum axle weights
be calculated using the bridge gross weight formula (23 U.S.C. §127(a)(2); 23 C.F.R. §658.5).
(The Class 8 vehicles discussed in this section have five single axles: one single axle and two
tandem axles.) States must allow “reasonable access” to the Interstate Highway System, meaning
For a study that developed comparable maps across the three types of powertrains, see A. Burke and H. Zhao, “Fuel
Economy Analysis of Medium/Heavy-Duty Trucks – 2015-2050,” paper presented at the EVS30 International Battery,
Hybrid and Fuel Cell Electric Vehicle Symposium, Stuttgart, Germany, October 2017, https://steps.ucdavis.edu/wpcontent/uploads/2017/05/BURKE-ZHAO-EVS30-MDHD-Fuel-Economy-Analysis_ver1.pdf.
100 The operating parameters would need to be suitably chosen as well.
101 See, for example, J. Marcinkoski et al., “Driving an Industry,” p. 4 et seq.
102 L. Guzzella and C. H. Onder, Introduction to Modeling and Control of Internal Combustion Engine Systems, 2nd ed.
(Springer-Verlag, 2010), p. 192.
103 L. Guzzella and C. H. Onder, Introduction to Modeling and Control of Internal Combustion Engine Systems, 2nd ed.
(Springer-Verlag, 2010).
104 DOE, Vehicle Technologies Office, Fact #621: Gross Vehicle Weight vs. Empty Vehicle Weight, May 3, 2010,
https://www.energy.gov/eere/vehicles/fact-621-may-3-2010-gross-vehicle-weight-vs-empty-vehicle-weight.
105 R. Mihelic et al., Hydrogen Fuel Cell Tractors, p. 103.
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that roads where states set weight limits generally conform to the federal limits just noted. (See
Section 412 of the Surface Transportation Assistance Act of 1982 [STAA; P.L. 97-424].)
Three Studies of Class 8 Combination Vehicles
This section discusses three simulations of Class 8 tractor-trailers. CRS selected the studies in the
following discussion because they make a comparison across three powertrains—diesel, batteryelectric, and fuel cell-electric—and apply a consistent analytical framework within each study.
Two of the studies consider the performance requirements of the vehicle, devise a virtual set of
components to satisfy those requirements, and assemble a virtual vehicle. The results of the
simulations illuminate how vehicles have different weights, and thus different cargo-carrying
abilities and fuel economies, and how these attributes vary with choice of powertrain. The third
study also employs a commercial modeling platform to quantify the vehicle hydrogen
consumption and compares this with diesel and battery-electric vehicle energy use.
A number of factors cause the results of the three studies to be not completely comparable. The
performance requirements placed on each simulated vehicle were fairly consistent among studies,
but were not identical. The method for determining the optimal component size and the models
used to conduct the simulations varied. Further, each study embodies different judgments about
how much improvement in technology might occur in the future. Readers interested in the details
of the individual powertrains may consult the respective studies.
Argonne National Laboratory
A modeling exercise by Argonne National Laboratory (ANL) uses a vehicle simulation
computational platform, Autonomie, and considers over 20 types of MHDVs.106 Holding the
range constant at 500 miles, the study simulates two types of combination Class 8 vehicles—
long-haul and regional-haul—using three different powertrains: diesel, battery-electric, and fuel
cell-electric.107 The results of the long-haul simulation are shown in Figure 2. The study includes
vehicles with performance requirements (discussed above in “Overview”) and vehicle attributes
comparable to today’s vehicles and customer expectations. The ranges are somewhat idealized as
they lead to fuel exhaustion. The study includes two technology cases—high and low—assuming
different levels of technological progress over time. For example, both the peak efficiency and the
power density of the fuel cell are superior in the high-technology case.
The study finds that, for a test cargo weighing 38,000 lb., all vehicles with all three powertrains
perform according to the performance requirements. As shown in Figure 2, the combined GVW
is less than the maximum of 80,000 lb., in all except the low-technology battery-electric vehicles,
implying that the vehicles could carry some additional cargo weight, labeled “unused cargo
weight.” The unused cargo weight is 10,000 lb. less for the battery-electric vehicle versus the
diesel. This lesser cargo capacity for alternative powertrains versus conventional (i.e., diesel) is
sometimes known as lost payload. The results of the ANL study further show that the fuel cell106 ANL, “Quantify the Impact of U.S. Department of Energy R&D on Vehicle Energy Consumption and Cost from
Light- to Heavy-Duty Classes,” October 2023, https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-dbenefits/.
107 Ehsan Sabri Islam et al., A Comprehensive Simulation Study to Evaluate Future Vehicle Energy and Cost Reduction
Potential, ANL, ANL/ESD-22/6, October 2022, p. 68, https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-rd-benefits/ (scroll down to locate “previous reports and analysis”). Performance and cargo requirements (p. 53) include
0-30 mph acceleration time; 0-60 mph acceleration time; sustainable maximum speed at 6% grade; driving range
between refueling/recharging; cargo mass; maximum cruising speed; start/launch capability on grade; and maximum
sustainable grade at highway cruising speed.
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electric truck is closer in curb weight to diesel and thus the lost payload is substantially smaller
than for a battery-electric.
Figure 2. Argonne National Laboratory Simulation of Three Powertrains in a Class 8
Long-Haul Tractor-Trailer Vehicle in High- and Low-Technology Cases
Source: Argonne National Laboratory, “Quantify the Impact of U.S. Department of Energy R&D on Vehicle
Energy Consumption and Cost from Light- to Heavy-Duty Classes,” analysis for medium- and heavy-duty
vehicles, October 2023, https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-d-benefits/; dataset for
medium- and heavy-duty vehicles (MHDVs) available at https://anl.app.box.com/s/
oy04bje3ltc21rz5py4bq1ed4s4bn0vo.
Notes: Vehicles are year 2025. The high- and low-technology cases should be interpreted as ranges. Validation
of the vehicle mpg and cargo capacity may take a few years of on-road testing. Vehicle weight (blue bars) includes
cargo weight; mpg = miles per gallon. The empty curb weight of the combined vehicle is the portion of the blue
bar above the amber “test cargo weight” line. All three vehicle powertrain types have the same cargo weight in
the simulation, but in some instances could take on a greater amount of additional cargo without exceeding the
combined vehicle weight rating; this leftover capacity is denoted in the figure as “unused cargo weight.” The
FAST Act increased the allowable weight by 2,000 pounds for battery-electric MHDVs; the “FAST Act
supplement.” The supplement is partly obscured by the vehicle weight in the case of the low-technology batteryelectric vehicle.
The study does not explicitly consider the FAST Act (P.L. 114-94), which added 2,000 lb. to the
limit on the GVW for battery-electric or compressed natural gas-combustion powertrains and
reduces lost payload, if any, by the same amount. Such vehicles could, in principle, have a
maximum gross combined vehicle weight (GCVW) of no more than 82,000 lb. on the Interstate
Highway System, or reasonable access thereto. Figure 2 illustrates the allowance for the batteryelectric powertrain by adding a cross-hatched rectangle, labeled as “FAST Act supplement.” For
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the low-technology battery vehicle, the 2,000 lb. allowance is necessary to accommodate the full
test payload: the weight of the empty vehicle plus test payload exceeds 80,000 lb.
Figure 2 also plots fuel economy, in miles per gallon (mpg) diesel equivalent, as diamonds to be
read off along the right-hand vertical axis. The battery-electric powertrain is the most fuel
efficient of the three, when considering only the energy use of the vehicle, owing to the
convenience of electricity being both (1) the fuel that is stored on board the vehicle and (2) the
fuel required by the inherently more efficient electric motor.108 In contrast, a fuel cell would first
need to convert the hydrogen stored on board the vehicle, at an efficiency of 45% to 60%, into the
electricity needed to turn the motor.109 The two powertrains (fuel cell-electric and battery-electric
vehicles) thereafter convert electricity to mechanical power at 90%.110 Other powertrains convert
between different forms of energy with lesser efficiencies. Diesel engines, for example, convert
the onboard diesel fuel into the shaft work performed by the engine and do so with 25% to 45%
brake thermal efficiencies—the efficiency measuring the mechanical energy at the crankshaft
compared with the fuel energy. None of these metrics consider the energy and emissions
associated with extracting and refining the primary resource and—in the case of battery-electric
vehicles—converting the primary resource to another form of energy. For the battery-electric
vehicle, energy emissions could be substantially undercounted, as the primary energy resource
must be converted to electricity. For further discussion, see CRS Report R46420, Environmental
Effects of Battery Electric and Internal Combustion Engine Vehicles, by Richard K. Lattanzio and
Corrie E. Clark.
National Renewable Energy Laboratory (NREL)
A modeling exercise by the National Renewable Energy Laboratory (NREL) uses a vehicle
simulation computational platform, the Future Automotive Systems Technology Simulator
(FASTSim) model.111 The outputs are vehicle performance and cost. NREL uses FASTSim to
build vehicle models “to translate component- and vehicle-level goals into vehicle performance
(miles per gallon [mpg]) and cost” for Class 8 long-haul vehicle applications and for other types
of vehicles. FASTSim uses input data on powertrain performance, such as peak engine
efficiencies and component power densities, and calculates onboard fuel and energy storage
requirements. The study takes account of key performance requirements, such as time to
accelerate from 0 mph to 60 mph and range (miles) on one tank, as discussed above in the
“Overview” section. The study runs simulations at a cargo weight of 36,000 lb.112
The NREL study finds, as does the ANL study (above), that battery-electric combined vehicles
weigh the most but nonetheless satisfy the performance requirements and carry the test cargo
108 The calculation of the fuel economy of the battery-electric vehicle does not include the energy needed to generate
the electricity in the first place, or the fuel economy would be lower. The same is true to a lesser degree of the fuel
economy of diesel and gasoline engines in the ANL study, which also does not include the energy to extract and refine
the petroleum before the fuel is on board the vehicle.
109 A. Ferrara et al., “Energy Management of Heavy-Duty Fuel Cell Electric Vehicles: Model Predictive Control for
Fuel Consumption and Lifetime Optimization,” paper presented at the 21st IFAC Conference, Berlin, July 2020,
pp. 14205-14210, https://www.sciencedirect.com/science/article/pii/S2405896320314233.
110 Renault Group, “The Energy Efficiency of an Electric Car Motor,” Energy and Motorization, March 9, 2021,
https://www.renaultgroup.com/en/news-on-air/news/the-energy-efficiency-of-an-electric-car-motor/.
111 E. Brooker et al., FASTSim: A Model to Estimate Vehicle Efficiency, Cost and Performance, NREL, NREL/CP5400-63623/SAE Technical Paper 2015-01-0973, April 14, 2015, https://www.nrel.gov/docs/fy15osti/63623.pdf.
112 A. Brooker et al., Vehicle Technologies and Hydrogen and Fuel Cell Technologies Research and Development
Programs Benefits Assessment Report for 2020, NREL, NREL/TP-5400-79617, August 2021, https://www.nrel.gov/
docs/fy21osti/79617.pdf.
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weight. Figure 3 includes plots of loaded vehicle mass, cargo mass, and regulatory limits and
allowances.
The NREL study considers two different technology cases: “conservative,” which NREL
describes as “business as usual,” and “aggressive,” which NREL describes as a high rate of
technology progress.113 The fuel economy was slightly higher and the empty vehicle weight
slightly lower in the aggressive case.
Figure 3. NREL Vehicle Simulation of Three Powertrains in a Class 8 Long-Haul
Tractor-Trailer Vehicle in Aggressive and Conservative Technology Cases
Source: National Renewable Energy Laboratory (NREL), using data from A. Brooker et al., Vehicle Technologies
and Hydrogen and Fuel Cell Technologies Research and Development Programs Benefits Assessment Report for 2020,
NREL/TP-5400-79617, 2021, https://www.nrel.gov/docs/fy21osti/79617.pdf; dataset available via automatic
download at https://www.nrel.gov/transportation/assets/docs/tda-mdhd-attributes-2022-09-03-v5.xlsx.
Notes: Vehicles are year 2025; range is 800 kilometers (~500 miles); mpg = miles per gallon. NREL sizes the
components for full legal weight and runs its simulations at the test cargo weight shown. Vehicle weight (blue
bars) includes cargo weight. The empty curb weight of the combined vehicle is the portion of the blue bar above
the amber “test cargo weight” line. All three vehicle powertrain types have the same cargo weight in the
simulation, but two of them—the diesel and fuel cell-electric vehicles—could take on still more capacity without
exceeding the combined vehicle weight rating; this leftover capacity is denoted as “unused cargo weight” in the
right-most bar, and it also applies to the others with underutilized capacity. The FAST Act supplement increased
the allowable weight by 2,000 pounds for battery-electric medium- and heavy-duty vehicles (MHDVs).
113 From “Overview” tab of dataset that downloads automatically from https://www.nrel.gov/transportation/assets/docs/
tda-mdhd-attributes-2022-09-03-v5.xlsx.
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International Council on Clean Transportation
The International Council on Clean Transportation (ICCT) analyzes how overall vehicle weight
can vary, again across three vehicle powertrain types. The analysis holds cargo weight constant,
except where doing so would exceed applicable limits. The analysis is part of a study of options
for regulating MHDVs in the EU.114 As a consequence of the study’s focus on the EU, the test
payload and maximum vehicle mass reflect EU limits, which are each roughly 10% higher than in
the United States. Generally, large trucks in the EU cannot exceed 40 metric tons (~88,000 lb.).
The study considers multiple ranges. Figure 4 shows the results at 800 kilometers (~500 miles),
for comparability with the other studies discussed above, and includes plots of loaded vehicle
mass, cargo mass, and regulatory limits and allowances. (For comparison, CALSTART maintains
a database with the range of currently available fuel cell-electric MHDVs.115) Two of the three
powertrains are able to haul the test payload in the current case, while the battery-electric vehicle
is not able to.
ICCT applies the applicable EU allowance for the ZEVs. Regulations in the EU allow up to an
additional 2,000 kg for zero-emission vehicles, which are defined in the EU as vehicles that do
not have an internal combustion engine or that emit less than 1 gram of carbon dioxide per
kilowatt-hour (kWh).116 For comparison, the FAST Act supplement in the United States is
roughly half as large, or roughly 900 kg. The allowance reflects how much heavier the zeroemission componentry would be relative to that of a diesel; the allowance does not automatically
step up to 2,000 kg. For the fuel cell-electric vehicle configured by ICCT, this extra mass is 782
kg in the current case and 178 kg in the future case. The ICCT future case includes increased peak
fuel cell efficiency, decreased aerodynamic drag and vehicle weight, lighter battery packs, and
other improvements; the future case represents the study authors’ judgments about improvements
possible by 2030.
114 H. Basma and F. Rodríguez, Fuel Cell Electric Tractor-Trailers: Technology Overview and Fuel Economy,
International Council on Clean Transportation, Working Paper 2022-23, July 18, 2022, pp. 24, 32, https://theicct.org/
wp-content/uploads/2022/07/fuel-cell-tractor-trailer-tech-fuel-1-jul22.pdf.
115 CALSTART, Drive to Zero’s Zero-Emission Technology Inventory (ZETI) Tool Version 9.0,
https://globaldrivetozero.org/tools/zero-emission-technology-inventory/.
116 European Commission, “Regulation (EU) 2019/1242 of the European Parliament and of the Council of 20 June
2019 Setting CO2 Emission Performance Standards for New Heavy-Duty Vehicles and Amending Regulations (EC) No
595/2009 and (EU) 2018/956 of the European Parliament and of the Council and Council Directive 96/53/EC,” Official
Journal of the European Union, vol. 62, July 25, 2019, pp. L 198/202-240, https://eur-lex.europa.eu/eli/reg/2019/1242/
oj#d1e1921-202-1.
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Figure 4. ICCT Simulation of Three Powertrains in a Class 8 Long-Haul Combination
Tractor-Trailer in Current and Future Cases
Source: H. Basma and F. Rodríguez, Fuel Cell-Electric Tractor-Trailers: Technology Overview and Fuel Economy,
International Council on Clean Transportation, Working Paper 2022-23, July 18, 2022, pp. 29, 32,
https://theicct.org/publication/fuel-cell-tractor-trailer-tech-fuel-jul22/.
Notes: “Current” year, while not given, is presumably the year of publication (2022). “Future” year is 2030;
range is 800 kilometers (~500 miles). Vehicle mass (blue bars) includes cargo mass. White diamonds indicate fuel
consumption rate (right axis); mpg = miles per gallon.
(*) The European Union (EU) allows up to an additional 2 metric tons (2,000 kilograms, or roughly 4,400 lb.) for
zero-emission vehicles. For the battery-electric vehicle in current technology, the modeled vehicle uses the EU
allowance but is not able to pull the entire test mass of 19,300 kilograms (~42,500 lb.). The future batteryelectric case and the current and future fuel cell-electric cases can use the EU allowance, depicted in blue with
hatched pattern.
The test payload is 19,300 kg (~42,500 lb.); in all except current technology battery-electric
vehicles, the vehicle has capacity for additional payload. At 1,000 kilometers (~620 miles; not
shown in the figure), ICCT notes that battery-electric combination vehicles experience 40% lost
payload due to the large battery required (1,884 kWh). This lost payload, however, decreases to
9% in a future case with improvements in truck chassis, trailer, and powertrain.117
For comparison, CRS looked at additional studies that considered the relationship between cargo
weight and vehicle weight. A study by Oak Ridge National Laboratory in 2019, on batteryelectric trucks, considers various cargo masses and finds that for ranges above 200 miles, the size
of the battery would lead to lost payload, similar to Figure 4 for the “current” battery-electric
117 Basma and Rodríguez, Fuel Cell Electric Tractor-Trailers, p. 24.
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case.118 A field study by Ballard Power Systems, a fuel cell manufacturer, and the North American
Council on Freight Efficiency collects on-road data on 10 fuel cell-electric Class 8 vehicles in
regional-haul operation and finds the average consumption is 9.14 mpg-diesel equivalent, again
similar to the ICCT study’s results, falling in between the current and future cases in Figure 4 for
fuel cell-electric trucks.119
Industry Benchmark on Vehicle Range: The Experience of Nikola
Nikola, a maker of battery-electric and fuel cell-electric trucks, has made available its comparison
of hauling capacity of the three powertrains considered in the studies discussed immediately
above. In a March 2020 shareholder presentation, Nikola Motor Corporation, as it was then
styled, offered a “general technology comparison” focused on the vehicle attributes of range and
weight.120 Nikola Motor Corporation conceived of two platforms—a shorter-haul battery-electric
Class 8 tractor and a longer-haul fuel cell-electric Class 8 tractor—as complementary, with
battery-electric trucks better suited to shorter hauls and the so-called last mile of delivery. Details
are in Table 1. In July 2023, Nikola announced production of its Class 8 tractor with fuel cell
powertrain and 500-mile range and produced 42 Class 8 tractors in 2023.121 Nikola announced it
had sold 200 Class 8 tractors in the third quarter of 2024.122 In the first quarter of 2025, Nikola
announced it had voluntarily filed for Chapter 11 bankruptcy.123 Kenworth, Volvo, and Hyundai
Motor have announced plans for production of hydrogen MHDVs.124
118 DOE, EERE, Medium- and Heavy-Duty Vehicle Electrification: An Assessment of Technology and Knowledge
Gaps, ORNL/SPR-2020/7, December 2019, p. 29, https://info.ornl.gov/sites/publications/Files/Pub136575.pdf.
119 The study reports 7.8 kg hydrogen consumed per 100 kilometers. CRS converts this to mpg-diesel equivalent using
the lower heating value of hydrogen of 33.3 kWh, and 37.99 kWh per diesel gallon equivalent. The notion of fuel
equivalencies considers the respective quantities of two different fuels with the same energy content, with the latter
defined within the specific calculation. Ballard Power Systems and North American Council for Freight Efficiency,
Fuel Cell Electric Trucks: An Analysis of Hybrid Vehicle Specifications for Regional Freight Transport, June 2020,
p. 18, https://nacfe.org/wp-content/uploads/2020/06/Informational_NACFE_BPS_Truck_White_Paper_Download.pdf.
120 Nikola Motor Corporation, “Investing in a Cleaner Future,” presentation, March 2020, https://www.sec.gov/
Archives/edgar/data/1731289/000110465920033164/tm2012695d1_ex99-1.htm.
121 Keiron Greenhalgh, “Nikola Begins Production of Hydrogen Fuel Cell Class 8 Truck,” Transport Topics, August 2,
2023, https://www.ttnews.com/articles/nikola-hydrogen-truck; and Jennifer Gangi, “Hydrogen Driving Trucking and
Transit on Path to Zero Emissions,” ACT News, April 17, 2024, https://www.act-news.com/news/hydrogen-drivingtrucking-and-transit-on-path-to-zero-emissions/.
122 Nikola, “Nikola Records Sales of 88 Hydrogen-Powered Class 8 Trucks for North American Customers in Q3 2024;
200 Total Sold This Year,” press release, October 2, 2024, https://www.nikolamotor.com/nikola-records-sales-of-88hydrogen-powered-class-8-trucks-for-north-american-customers-in-q3-2024-200-total-sold-this-year.
123 Nikola, “Nikola Initiates Comprehensive Voluntary Chapter 11 Sale Process,” press release, February 19, 2025,
https://www.nikolamotor.com/nikola-initiates-comprehensive-voluntary-chapter-11-sale-process.
124 Volvo Truck, “Fuel Cell Trucks—When and Why Do We Need Them?,” press release, January 10, 2023,
https://www.volvotrucks.com/en-en/news-stories/stories/2022/nov/when-and-why-fuel-cell-truck.html; Hyundai Motor
Company, “Hyundai Motor Drives Sustainable Clean Logistics in U.S. with Vision for Hydrogen Society,” press
release, May 22, 2024, https://ecv.hyundai.com/global/en/newsroom/press-releases/hyundai-motor-drives-sustainableclean-logistics-in-us-with-vision-for-hydrogen-society-BL00200522; and Kenworth, “Kenworth Announces T680
Hydrogen Fuel Cell Commercialization Plans,” press release, May 2, 2023, https://www.kenworth.com/about-us/news/
kenworth-announces-t680-hydrogen-fuel-cell-commercialization-plans/.
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Table 1. Nikola Motor Corporation’s Estimated Ranges and Weights
for Class 8 Tractor-Trailers
(estimates of hauling capacity include weights of trailer plus cargo)
Power Source
Range
Estimated Hauling Capacitya
Diesel
500-750 mi.
~61,000-63,000 lb.
Battery-electric
100-300 mi.
~53,000-55,000 lb.
Fuel cell-electric
500-750 mi.
~56,000-58,000 lb.
Source: Nikola Motor Corporation, “Investing in a Cleaner Future,” presentation, March 2020,
https://www.sec.gov/Archives/edgar/data/1731289/000110465920033164/tm2012695d1_ex99-1.htm.
Notes: In the Nikola presentation, vehicle weight plus “hauling capacity” (i.e., cargo weight) sum to 80,000 lb.;
lb. = pounds; mi. = miles. The firm is now styled as Nikola or Nikola Corporation.
a. Includes weight of trailer. The empty weight of a semi-trailer varies but different sources notionally fix the
weight at 10,000 lb. and 13,500 lb., for example. Dustin Hawley, “How Much Does a Semi Truck Weigh?,”
J.D. Power, February 4, 2021, https://www.jdpower.com/cars/shopping-guides/how-much-does-a-semi-truckweigh; C. Hunter et al., Spatial and Temporal Analysis of the Total Cost of Ownership for Class 8 Tractors and
Class 4 Parcel Delivery Trucks, National Renewable Energy Laboratory, NREL/TP-5400-71796,
September 2021, p. 82, https://www.osti.gov/biblio/1821615.
Trade-Offs Involving Parcel Delivery Vehicles (Class 4)
Lighter vehicles, such as Class 4, make deliveries to homes and businesses and, generally
speaking, handle the last mile of the supply chain. A 2024 model result of MHDVs by ANL
considers conventional, battery-electric, and fuel cell-electric (including hybrid) powertrains in
Class 4 delivery vehicles. The results show that the Class 4 vehicle in all three powertrains could
meet the performance requirements (discussed above in “Overview”) while transporting a load of
1,650 kg (~3,640 lb.) a distance of 150 miles. The fuel economy (miles per gallon or miles per
gallon diesel equivalent) of the vehicles varies across powertrains, with the alternative
powertrains (battery-electric and fuel cell-electric) being more efficient at converting the
chemical energy into miles traveled.
The ANL analysis considers two technology cases: a low-technology case, in which there is no
DOE-sponsored research program, and a high-technology, “program success” case, in which
DOE programs reach technical targets. For the program success case (high-technology), the study
assumes the vehicle will achieve DOE’s year-2050 goals across a number of vehicle
characteristics (e.g., drag coefficient, or CdA) and powertrain components (e.g., fuel cell peak
efficiency). ANL uses these goals and a set of performance requirements to develop technical
specifications for the completed vehicle.125 Calibrated to these specifications, ANL uses
Autonomie, the vehicle simulation computational platform, and determines the size (e.g., power
rating) of the powertrain components and the vehicle’s energy use.126 Figure 5 plots the weight
and the fuel economy of the loaded vehicle in the simulation. Among conventional powertrains,
the study considers both diesel engines and gasoline engines (i.e., spark-ignited, Otto cycle
125 In the companion report, ANL notes that manufacturers do not typically make the performance requirements
available, so ANL uses the advertised power ratios, gear ratios, etc. to derive a compatible set of such requirements for
use in the study. Ehsan Sabri Islam et al., Detailed Simulation Study to Evaluate Future Transportation
Decarbonization Potential, ANL, Contract ANL/TAPS-23/3, October 2023, p. 43, https://vms.taps.anl.gov/researchhighlights/vehicle-technologies/u-s-doe-vto-hfto-r-d-benefits/.
126 The study calculates the requirements at the maximum GVW rating for Class 4 vehicles, or 16,000 lb.
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engines). In Figure 5, fuel economy is plotted as diamonds and the values read off along the
right-hand vertical axis.
Figure 5. Simulation of Three Powertrains in a Class 4 Delivery Vehicle
Source: Argonne National Laboratory, U.S. DOE VTO/HFTO R&D Benefits, January 2024,
https://vms.taps.anl.gov/research-highlights/vehicle-technologies/u-s-doe-vto-hfto-r-d-benefits/. Dataset for
medium- and heavy-duty vehicles downloadable at https://anl.box.com/s/oy04bje3ltc21rz5py4bq1ed4s4bn0vo.
Notes: Vehicles are year 2025. The high- and low-technology cases should be interpreted as ranges. Validation
of the vehicle mpg and cargo capacity may take a few years of on-road testing. Vehicle weight (blue bars) includes
cargo weight; mpg = miles per gallon. The empty curb weight of the combined vehicle is the portion of the blue
bar above the amber “test cargo weight” line.
Vehicle Cost
Various studies have compared the purchase cost of the Class 8 vehicle across the different types
of powertrains including diesel, battery-electric, and fuel cell-electric. Generally speaking,
battery-electric trucks and fuel cell-electric trucks still cost more to purchase than comparable
diesel trucks. A 2022 analysis by ICCT estimates that a battery-electric Class 8 day cab vehicle,
which has no sleeping compartment, costs two to three times as much as a comparable diesel
vehicle, and a comparable fuel cell-electric vehicle costs three to four times as much as a diesel,
prior to financial incentives.127 By 2030, the costs of battery-electric and fuel cell-electric trucks
127 Claire Buysse, “How Much Does an Electric Semi Really Cost?” International Council on Clean Transportation
(ICCT) blog, February 24, 2022, https://theicct.org/cost-electric-semi-feb22/. See especially figure, “Purchase Price of
a Class 8 Day Cab by Powertrain.”
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(Class 8 day cabs) are projected to converge, with both vehicles costing 150% to 170% the cost of
a comparable diesel, prior to financial incentives. For comparability, the studies of Class 8
vehicles discussed below will also be for day cabs.
The modeling exercise by ANL128 cited in Figure 2, which also considers vehicle cost, finds that
for a 2025 Class 8 day cab in regional-haul operation, the battery-electric truck costs 150% to
230% the cost of a diesel, while the fuel cell-electric truck costs 140% to 190% the cost of a
diesel. By 2030, the costs of battery-electric and fuel cell-electric trucks (Class 8 day cabs) are
projected to converge, with both vehicles costing roughly 120% to 170% the cost of a diesel,
prior to any financial incentives.129
A study by NREL finds that, for Class 8 long-haul combination vehicles with day cab, the
battery-electric version has an estimated manufacturer’s suggested retail price (MSRP) that is
roughly twice the diesel’s MSRP, while the fuel cell-electric has an MSRP that is roughly 1.5
times higher—both in 2025, the first year for which results for all three powertrains were
presented—prior to any financial incentives. For the 2030 scenario, involving technical progress,
the battery-electric vehicle MSRP reduces to roughly the same, 1.3 to 1.5 times the diesel MSRP,
and the fuel cell-electric MSRP reduces to 1.2 to 1.4 times the diesel MSRP.130 The study notes
the possibility of the 45W tax credit but does not apply it.131 The tax credit is discussed further in
“Commercial Clean Vehicles: Internal Revenue Code Section 45W,” below.
For Class 4 parcel delivery vehicles, the NREL study finds that the MSRP is higher for fuel cellelectric Class 4 trucks versus diesel by roughly a factor of two in the 2018 scenario; by the 2025
scenario, the fuel cell-electric MSRP is 1.33 times that of the diesel. The battery-electric truck
MSRP is 1.84 times the diesel MSRP in the 2018 scenario and in the 2025 scenario has improved
to being slightly less than diesel, or 0.91 times diesel.132 The study by ANL finds that the MSRP
of the fuel cell-electric vehicle would be 1.20 to 1.29 times that of the diesel and 1.12 to 1.23
times that of the gasoline engine, depending on the technology case (low or high). For the batteryelectric vehicle, the study finds that the MSRP would be 1.27 to 1.79 times that of the diesel and
1.19 to 1.27 times that of the gasoline engine, depending on the technology case (low or high).
Recent Developments
Financial Assistance Programs on Deployment of Hydrogen Trucks
Legislation enacted in the last several years has greatly increased the amount of funding and other
financial incentives available toward deployment of FCEVs. Deployment support can focus on
demonstration or early commercial phases and include activities such as transporting and
dispensing hydrogen fuel; vehicle manufacturing; vehicle purchase, such as by fleets; and final
128 ANL, “Quantify the Impact of U.S. Department of Energy R&D on Vehicle Energy Consumption and Cost from
Light- to Heavy-Duty Classes,” October 2023, https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-dbenefits/.
129 ANL, “Quantify the Impact of U.S. Department of Energy R&D on Vehicle Energy Consumption and Cost from
Light- to Heavy-Duty Classes,” dataset for medium- and heavy-duty vehicles downloadable at “vehicle results” link at
https://vms.taps.anl.gov/research-highlights/vehicle-technologies/u-s-doe-vto-hfto-r-d-benefits/ or at
https://anl.box.com/s/oy04bje3ltc21rz5py4bq1ed4s4bn0vo.
130 Hunter et al., Spatial and Temporal Analysis, p. 34.
131 ANL, “Quantify the Impact of U.S. Department of Energy R&D on Vehicle Energy Consumption and Cost from
Light- to Heavy-Duty Classes,” October 2023, https://vms.taps.anl.gov/research-highlights/u-s-doe-vto-hfto-r-dbenefits/.
132 Hunter et al., Spatial and Temporal Analysis, p. 36.
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Hydrogen-Fueled Medium- and Heavy-Duty Vehicles
use of hydrogen for energy services by truck fleets (e.g., port operations, goods movement). The
conceptual boundary between research and development (R&D) versus deployment is not always
certain and, for example, activities based on developing new manufacturing lines or concept
vehicles such as SuperTruck, discussed below, may be difficult to classify definitively as one or
the other.133
The IIJA and P.L. 117-169, known as the Inflation Reduction Act of 2022 (IRA), are two
supplemental appropriations bills that include support for deployment of FCEVs in very large
projects, such as Regional Clean Hydrogen Hubs, but also smaller awards made to specific
hydrogen MHDV projects. Annual appropriations continue to focus principally on R&D and
precompetitive activities.134 This section focuses primarily on deployment activities that are
funded from the supplemental appropriations bills owing to their size, scope, and scale.
Recent developments carry or have carried implications for spending on the programs discussed
in this section. These include, but are not limited to, the issuance of the executive order
“Unleashing American Energy,”135 DOE’s reported plans to review all post-election awards
(which would include four of the seven Regional Clean Hydrogen Hubs),136 and an Office of
Management and Budget (OMB) memorandum137 (later rescinded)138 pausing obligation and
disbursement of federal financial assistance. According to news report in March 2025, DOE was
considering whether to discontinue funding for some of the hydrogen hubs.139
Charging and Fueling Infrastructure (CFI): Grants and Tax Credits
Section 11401 of the IIJA authorized grants for charging and fueling infrastructure along
“designated alternative fuel corridors,” as the latter are defined in the FAST Act (P.L. 114-94);
corridors are discussed above in “Status and Characteristics of MHDVs.” Grantees may use the
funds for a variety of alternative fuel infrastructure, including battery recharging or hydrogen
fueling. The IIJA (§11101(b)(1)(C)) provided a total of approximately $2.5 billion for FY2022 to
FY2026 from the Highway Trust Fund140 for this program.141 Two bills in the 119th Congress, S.
651 and H.R. 1513, would end the program.
The program is being implemented by FHWA. Of the $623 million awarded in the first round of
funding, over 80% went toward electric vehicle charging, with the remaining $98 million going
133 See, for example, DOE’s recent announcement of an award of $4.5 million to Boston Materials: DOE, “DOE
Awards over $11 Million Through MAKE IT Prize to Boost Domestic Clean Energy Manufacturing Development and
Opens New $32 Million Round of the Prize,” press release, December 12, 2024, https://www.energy.gov/
technologytransitions/articles/doe-awards-over-11-million-through-make-it-prize-boost-domestic.
134 DOE, Office of the Chief Financial Officer, FY 2025 Congressional Justification: Volume 2, DOE/CF-0203,
March 2024, p. 304, https://www.energy.gov/sites/default/files/2024-03/doe-fy-2025-budget-vol-2-v4.pdf.
135 Executive Order 14154, “Unleashing American Energy,” 90 Federal Register 8353 (January 29, 2025).
136 Peter Behr, “DOE Project Funding Needs Trump Lieutenants’ Blessing,” E&E News, February 12, 2025,
https://www.eenews.net/articles/doe-project-funding-needs-trump-lieutenants-blessing/.
137 Office of Management and Budget (OMB), “Temporary Pause of Agency Grant, Loan, and Other Financial
Assistance,” Memorandum for Heads of Executive Departments and Agencies, M-25-13, January 27, 2025.
138 OMB, “Rescission of M-25-13,” Memorandum for Heads of Executive Departments and Agencies, M-25-14,
January 29, 2025, https://www.cfo.gov/assets/files/M-25-14%20Final.pdf.
139 “US Weighs Funding Cuts to Four of Seven Hydrogen Hubs,” Reuters, March 26, 2025.
140 For a description of the Highway Trust Fund, see CRS Report R47022, Federal Highway Programs: In Brief, by
Robert S. Kirk.
141 CRS Report R47034, Energy and Minerals Provisions in the Infrastructure Investment and Jobs Act (P.L. 117-58),
coordinated by Brent D. Yacobucci. See “Division A—Surface Transportation,” prepared by Melissa N. Diaz.
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toward hydrogen or combination hydrogen and electric vehicle refueling projects.142 FHWA
announced awards totaling $521.2 million on August 27, 2024, as a continuation of the first round
of funding. Of these, one project on hydrogen refueling for MHDVs was to receive $102.4
million.143 For the second round of funding, FHWA announced $635.7 million in awards on
January 8, 2025, including $80.63 million for projects on hydrogen or hydrogen and electric
vehicle charging.144 H.R. 1052 in the 119th Congress would rescind certain unobligated balances.
Alternative Fuel Refueling Property Credit: Internal Revenue Code Section 30C
Section 13404 of the IRA amends Section 30C of the Internal Revenue Code (IRC) to provide an
Alternative Fuel Refueling Property Credit. IRC 30C provides a tax credit up to 30% of the cost
of alternative fuel refueling property, up to $100,000.
Clean Heavy-Duty Vehicles Program
Section 60101 of the IRA, “Clean Heavy-Duty Vehicles,” amends the Clean Air Act (42 U.S.C.
§§7401-7671) and provides $1 billion to be used for replacement of non-zero-emission vehicles
with zero-emission vehicles (ZEVs). Section 60101 defines a ZEV as a vehicle that does not
create emissions of criteria pollutants or greenhouse gases from its exhaust.145 As such, the
definition includes fuel cell-electric vehicles. Monies from the Clean Heavy-Duty Vehicles
Program, in the form of grants and/or rebates, may be used to cover the incremental cost of
replacing the current stock of vehicles with ZEVs.
The IRA also authorizes the use of funds for refueling and maintenance infrastructure, workforce
development and training, and other activities supporting adoption of ZEVs. EPA is the
implementing agency and opened the notice of funding opportunity (NOFO) on April 24, 2024,
with applications due July 25, 2024.146 EPA had not announced funding awards from this NOFO
as of February 28, 2025.
Reduction of Truck Emissions at Port Facilities Grant Program
Section 11101(b)(1)(F) of the IIJA authorizes a program “to carry out the reduction of truck
emissions at port facilities” and provides $50 million per year, FY2022 to FY2025, from the
Highway Trust Fund. In addition, Division J of the IIJA appropriates $30 million annually over
the period FY2022 to FY2026.147 On April 24, 2024, the Biden Administration announced $148
million in grants for 16 projects, much of it aimed at refueling infrastructure and reducing
142 FHWA, “CFI Round 1B Grant Award Recipients,” press release, August 26, 2024, https://www.fhwa.dot.gov/
environment/cfi/grant_recipients/round_1b/.
143 FHWA, “Investing in America: Number of Publicly Available Electric Vehicle Chargers Has Doubled Since Start of
Biden-Harris Administration,” press release, August 27, 2024, https://highways.dot.gov/newsroom/investing-americanumber-publicly-available-electric-vehicle-chargers-has-doubled-start.
144 FHWA, “CFI Round 2 Grant Award Recipients,” press release, January 8, 2025, https://www.fhwa.dot.gov/
environment/cfi/grant_recipients/round_2/.
145 Criteria air pollutants are regulated under Section 108(a) of the Clean Air Act and include some of the air emissions
commonly associated with power plants and vehicles such as oxides of nitrogen (NOx) and particulate matter (PM).
146 EPA, “Clean Heavy-Duty Vehicles Program,” July 20, 2023, https://www.epa.gov/inflation-reduction-act/cleanheavy-duty-vehicle-program.
147 FHWA, “Infrastructure Investment and Jobs Act Fact Sheets: Reduction of Truck Emissions at Port Facilities,”
January 31, 2025, https://www.fhwa.dot.gov/bipartisan-infrastructure-law/rtep.cfm.
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pollution from idling.148 One project grant, $25.1 million awarded to the Port Authority of
Houston, included funding for a portable hydrogen fueling station.149 Many of the awards were
not related to hydrogen but were made for projects on electric charging infrastructure and
replacement of diesel vehicles with battery-electric vehicles.
Clean Ports Program
EPA’s Clean Ports Program is funded through IRA Section 60102, with the goal of reducing air
pollution at ports through grants.150 EPA issued a NOFO of up to $2.8 billion for the ZeroEmission Technology Deployment Competition grants for zero-emission port equipment and
infrastructure.151 Eligible entities include, but are not limited to, owners and operators of cargohandling equipment and drayage trucks who apply in partnership with air pollution control
agencies or port authorities or other agencies with authority at ports.152 On October 29, 2024, EPA
announced the selection of 30 grants totaling $2.8 billion.153 Of these, three projects worth a total
of $471 million support charging and refueling infrastructure, material handling equipment,
drayage trucks, and locomotives for either hydrogen-fueled vehicles or both hydrogen-fueled and
electric vehicles.154
Port Infrastructure Development Program
Division J of the IIJA funded the Port Infrastructure Development Program (46 U.S.C. §54301),
which is authorized to improve the safety, efficiency, and reliability of ports in four areas. In one
area, environmental and emissions mitigation measures, the authorizing statute calls for “electric
vehicle charging or hydrogen refueling infrastructure for drayage and medium or heavy-duty
trucks and locomotives that service the port and related grid upgrades” (46 U.S.C.
§54301(a)(3)(A)(ii)(IV)(hh)). The awards announced by DOT following the FY2022, FY2023,
and FY2024 solicitations do not, however, explicitly include hydrogen.155 The IIJA appropriated a
total of $2.25 billion from FY2022 through FY2026. The program received additional money
from annual appropriations: $234.31 million in FY2022, $212.20 million in FY2023, and $120.46
million in FY2024; $50 million of FY2024 monies may be used for discretionary grants.156
148 FHWA, “Biden-Harris Administration Announces Nearly $150 Million in Grants to Help Reduce Truck Air
Pollution Near America’s Ports,” press release, April 24, 2024, https://highways.dot.gov/newsroom/grants-help-reducetruck-air-pollution-ports.
149 Port Houston, “Port Houston Awarded $25 Million Grant,” January 17, 2025, https://porthouston.com/wp-content/
uploads/2025/01/Port-Houston-Receives-25-Million-Grant_-Final-Jan-17-2025-1.pdf.
150 EPA, “Request for Information – Transportation Programs,” November 4, 2022, https://www.regulations.gov/
document/EPA-HQ-OAR-2022-0874-0002.
151 EPA, “Clean Ports Program: Notices of Funding Opportunities,” May 23, 2024, https://www.epa.gov/portsinitiative/cleanports#notices.
152 EPA, Clean Ports Program ‘Fast Facts’, April 2024, https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P101A2VI.pdf.
153 EPA, “Biden-Harris Administration Announces Selections for Nearly $3 Billion of Investments in Clean Ports as
Part of Investing in America Agenda,” press release, October 29, 2024, https://www.epa.gov/newsreleases/bidenharris-administration-announces-selections-nearly-3-billion-investments-clean.
154 EPA, “Clean Ports Program Selections,” December 10, 2024, https://www.epa.gov/ports-initiative/clean-portsprogram-selections.
155 DOT, Maritime Administration, “Port Infrastructure Development Program,” November 15, 2024,
https://www.maritime.dot.gov/PIDPgrants.
156 See P.L. 117-103, P.L. 117-328, P.L. 118-42, and Notice of Funding Opportunity for the Maritime Administration’s
Port Infrastructure Development Program (PIDP) Under the Infrastructure Investment and Jobs Act (“Bipartisan
Infrastructure Law”) and Consolidated Appropriations Act, 2024, March 8, 2024, https://www.maritime.dot.gov/sites/
marad.dot.gov/files/2024-05/Final%20FY24%20PIDP%20Amended%20NOFO%2004252024.pdf.
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Regional Clean Hydrogen Hubs
The IIJA authorized and funded an $8 billion program on Regional Clean Hydrogen Hubs
(Section 40315 and Division J, Title III, of IIJA)—networks of hydrogen producers, consumers,
and infrastructure in a common geography. DOE has committed up to $7 billion to seven
consortiums (“selectees”) and obligated a small portion of that amount.157 DOE selected a
consortium for a Demand-Side Support Initiative valued at up to $1 billion as part of the
program.158
Two of the hubs—the California Hydrogen Hub (ARCHES) and the Pacific Northwest Hydrogen
Association (PNWH2)—plan to link their activities on fuel cell trucks to develop a West Coast
freight network.159 ARCHES envisages 5,000 or more fuel cell-electric trucks, Class 6 through
Class 8, and 60 HRS for MHDVs as part of the project.160 PNWH2 envisages up to 10 HRS to be
built in a node in Ferndale, WA, and additional HRS along the I-5, I-90, and I-84 corridors and in
a node in Durkee, OR.161
Advanced Technology Vehicle Manufacturing (ATVM) Loan Program
The IIJA (§40401(b)) enlarged the scope of the Advanced Technology Vehicle Manufacturing
(ATVM) Loan Program (42 U.S.C. §17013) so that the proceeds of direct loans could be used for
manufacturing facilities for qualifying MHDVs.162 The Consolidated Appropriations Act, 2023
(P.L. 117-328), Division D, Section 308, repealed the restrictions that would have otherwise
prevented the use of prior appropriations for MHDVs.163 The program assists OEs in meeting fuel
economy standards and encourages domestic production of more fuel-efficient vehicles.
Domestic Manufacturing Conversion Grants
Section 50143 of the IRA created the Domestic Manufacturing Conversion Grants and
appropriated $2 billion to provide grants for domestic production of FCEVs and other types of
electric- and hybrid-electric-drive vehicles. DOE issued a Funding Opportunity Announcement
on August 31, 2023.164 DOE announced the awards on July 11, 2024.165 Of the facilities that
157 The White House, “Biden-Harris Administration Announces $7 Billion for America’s First Clean Hydrogen Hubs,
Driving Clean Manufacturing and Delivering New Economic Opportunities Nationwide,” press release, October 13,
2023, https://bidenwhitehouse.archives.gov/briefing-room/statements-releases/2023/10/13/biden-harris-administrationannounces-regional-clean-hydrogen-hubs-to-drive-clean-manufacturing-and-jobs/. Amount of obligations was
determined by CRS using data pulled from USASPENDING.gov as of March 5, 2025.
158 DOE, OCED, “DOE Selects Consortium to Bridge Early Demand for Clean Hydrogen, Providing Market Certainty
and Unlocking Private Sector Investment,” press release, January 17, 2024, https://www.energy.gov/oced/articles/doeselects-consortium-bridge-early-demand-clean-hydrogen-providing-market-certainty.
159 DOE, OCED, Regional Clean Hydrogen Hubs Program: California Hydrogen Hub (ARCHES), July 2024, p. 3.
160 DOE, OCED, Regional Clean Hydrogen Hubs Program: California Hydrogen Hub (ARCHES), July 2024, p. 2.
161 DOE, OCED, Regional Clean Hydrogen Hubs Program: Pacific Northwest Hydrogen Hub (PNWH2), pp. 4-5.
162 Until then, the program had focused on the production of efficient passenger vehicles.
163 The restrictions had been put in place by IIJA §40401(a)(2).
164 DOE, Office of Manufacturing Energy and Supply Chains, Domestic Manufacturing Conversion Grants,
https://www.energy.gov/mesc/domestic-manufacturing-conversion-grants. For due dates and requirements, see DOE,
Inflation Reduction Act (IRA) Domestic Manufacturing Conversion Grants, DE-FOA-0003106, August 31, 2023,
https://infrastructure-exchange.energy.gov/Default.aspx#FoaIdf9eb1c8a-9922-46b6-993e-78972d823cb2.
165 DOE, “Biden-Harris Administration Announces Nearly $2 Billion to Support American Auto Workers, Convert
Facilities for Electric Vehicles,” press release, July 11, 2024, https://www.energy.gov/mesc/domestic-manufacturingconversion-grant-program.
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received the grants, those owned by Volvo Technology of America, LLC, plan to do work on fuel
cell-electric vehicles.166
Commercial Clean Vehicles: Internal Revenue Code Section 45W167
Section 13403 of the IRA creates a new tax credit at Section 45W of the Internal Revenue Code
(IRC 45W) for qualified commercial clean vehicles placed in service by the taxpayer during the
year. The credit is the lesser of (1) 30% of the purchase price168 or (2) the incremental cost of the
vehicle relative to a comparable conventional vehicle. Credit amounts cannot exceed $40,000 for
vehicles not less than 14,000 lb., which, generally speaking, corresponds to Class 4 through
Class 8 vehicles.169 Eligible vehicles would need to operate on a fuel cell and be certified to
meet or exceed certain emissions standards, be made by a qualified manufacturer
(IRC §30D(d)(1)(C)),170 and meet other requirements.
On November 2, 2022, the Department of the Treasury opened a one-month comment period on
the implementation of the IRC 45W credit.171 The IRS has since issued Notice 2023-09 that
provides a safe harbor determination for the incremental costs relative to the $7,500 cap for
calendar year 2023.172 The Congressional Budget Office estimates that IRC 45W would reduce
federal revenues by $3.583 billion from FY2023 through FY2031.173
Not included in this discussion is IRC 30D, which applies to vehicles having GVW ratings less
than 14,000 lb. and has other restrictions.
Summary and Framework
This section summarizes the programs discussed above and, in Table 2, presents a framework for
considering the impact on deployment of truck FCEVs. The table lists the programs and
summarizes them according to the form of financial assistance each provides and the focus of the
program. For each program, Table 2 indicates which aspect of deployment would be affected.
Generally speaking, the assignment to the categories indicates the type of business that would be
the direct beneficiary of the financial assistance, but other categories might benefit indirectly.
Thus, the categories are not mutually exclusive. The table shows that fleet operations may be the
target of few of the studied programs.
166 DOE, “Biden-Harris Administration Announces Nearly $2 Billion to Support American Auto Workers, Convert
Facilities for Electric Vehicles.”
167 See also CRS Report R47202, Tax Provisions in the Inflation Reduction Act of 2022 (H.R. 5376), coordinated by
Molly F. Sherlock.
168 This arm of the tax credit would be 15% of the vehicle’s cost if gasoline or diesel.
169 For vehicles with GVW ratings less than 14,000 lb., the cap is $7,500.
170 The IRS elaborated an index of qualified manufacturers. See IRS, “Qualified Manufacturers for Clean Vehicle
Credits,” March 21, 2025, https://www.irs.gov/credits-deductions/manufacturers-for-qualified-commercial-cleanvehicle-credit.
171 Department of the Treasury and IRS, Request for Comments on Section 45W Credit for Qualified Commercial Clean
Vehicles, Notice 2022-56, November 2, 2022, https://www.irs.gov/pub/irs-drop/n-22-56.pdf; Department of the
Treasury and IRS, “IRS Seeks Comments on Upcoming Energy Guidance,” news release, November 3, 2022,
https://www.irs.gov/newsroom/irs-seeks-comments-on-upcoming-energy-guidance.
172 IRS, “Treasury, IRS Issue Guidance on the Incremental Cost for the Commercial Clean Vehicle Credit,” news
release, December 5, 2023, https://www.irs.gov/newsroom/treasury-irs-issue-guidance-on-the-incremental-cost-for-thecommercial-clean-vehicle-credit.
173 Congressional Budget Office, Estimated Budgetary Effects of H.R. 5376, the Inflation Reduction Act of 2022,
August 5, 2022, p. 11, https://www.cbo.gov/publication/58366.
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Table 2. Framework for Analysis of Programs That Could Apply to Hydrogen Truck Deployment
(covers the types of deployment activities discussed in the report)
Name and Authorization
Form of
Assistance
Purpose and Activities
Fueling
Infrastructure
Vehicle
Mfg.
Vehicle
Purchase
Operations:
Ports
Charging and Fueling Infrastructure;
IIJA §11401; FAST Act
Grantsb
CFI along alternative fuel
corridorsc
X
Alt. Fuel Refueling Property Credit;
IRA §13404
Tax credit
(IRC §30C)
30% cost of CFI up to $100K
X
Clean Heavy-Duty Vehicles;
IRA §60101
Grants
Buy down incremental cost of
ZEVs; CFI
X
Truck Emissions at Port Facilities;
IIJA §11402
Grantsd
Truck emissions at port
facilities
X
X
Clean Ports Program; IRA §60102
Grants
CFI; cargo handling and
drayage
X
X
Port Infrastructure Development;
NDAA 2010e
Grants
Cargo handling and drayage
vehicles
Regional Clean Hydrogen Hubs;
IIJA §40314
Cooperative
agreements
Regional Clean Hydrogen Hubs
ATVM Loan Program;
IIJA §40401(b); EISA
Direct loans
For facilities to manufacture
MHDVs
X
Domestic Mfg. Conversion Grants;
IRA §50143
Grants
For conversion of facilities to
make ZEVs
X
Commercial Clean Vehicles;
IRA §13403
Tax credit
(IRC §45W)
Vehicle purchase credit up to
$40K if ≥14,000 lb. GVW
ratingf
Operations:
Fleetsa
X
X
X
X
X
X
X
X
X
Source: CRS analysis.
Notes: Alt. = alternative; ATVM = Advanced Technology Vehicle Manufacturing (42 U.S.C. §17013); CFI = charging and fueling infrastructure; grant programs can include
both electric vehicle and hydrogen infrastructure; EISA = Energy Independence and Security Act of 2007, P.L. 110-140; FAST Act = Fixing America’s Surface
Transportation Act, P.L. 114-94; GVW = gross vehicle weight; IIJA = Infrastructure Investment and Jobs Act, P.L. 117-58; IRA = P.L. 117-169, known as the
Inflation Reduction Act of 2022; IRC = Internal Revenue Code, Title 26 U.S.C.; Mfg. = manufacturing; MHDV = medium- and heavy-duty vehicles (≥10,000 lb. GVW rating);
NDAA 2010 = National Defense Authorization Act for Fiscal Year 2010, P.L. 111-84; ZEVs = zero-emission vehicles, that is, vehicles that do not directly create
criteria pollutants or greenhouse gases.
CRS-30
a.
b.
c.
d.
e.
f.
CRS-31
Includes regional- and long-haul fleets. See description in the section “Operations.”
Authorized to be appropriated from the Highway Trust Fund per IIJA §11101(b)(1)(C). For further information on spending from the Highway Trust Fund, see CRS
Report R47022, Federal Highway Programs: In Brief, by Robert S. Kirk, and CRS Report R46938, Federal Excise Taxes: Background and General Analysis, by Anthony A.
Cilluffo.
The FAST Act authorized “national alternative fueling corridors” (23 U.S.C. §151). The Federal Highway Administration refers to these as “alternative fuel
corridors.”
Authorized to be appropriated from the Highway Trust Fund per IIJA §11101(b)(1)(F).
Port Infrastructure Development Program, 46 U.S.C. §54301, first authorized in P.L. 111-84. Appropriation per Division J of the IIJA and in annual appropriations:
P.L. 117-103, P.L. 117-328, and P.L. 118-42.
IRC §45W also applies to vehicles <14,000 lb. GVW rating, which are not within the scope of this report and which have a lower cap.
Hydrogen-Fueled Medium- and Heavy-Duty Vehicles
California Programs on Truck Portfolios and Fleets
As noted above, in the section “Status of Hydrogen and MHDVs,” almost all public-facing
hydrogen refueling infrastructure is located in California. California has issued regulations that
apply to ZEVs generally and would affect fuel cell-electric MHDVs and also battery-electric
MHDVs.
Advanced Clean Fleets Regulation
In April 2023, the California Air Resources Board (CARB) adopted the Advanced Clean Fleets
Regulation to require certain fleet owners to purchase ZEVs.174 CARB applied for a waiver of the
Clean Air Act’s prohibition against states setting vehicle and engine emissions standards on
July 12, 2024.175 CARB withdrew the request on January 13, 2025.176 If it had been granted a
waiver, the regulation would have applied to vehicles with GVW ratings from 8,501 lb. up to
80,000 lb.177 Any new acquisitions by fleets of such vehicles would have been required to follow
a portfolio standard that gradually phased out conventional powertrains.178
Advanced Clean Trucks Regulation
California’s Advanced Clean Trucks Regulation moved forward after April 2023, when EPA
issued a waiver of the Clean Air Act’s prohibition against states setting vehicle and engine
emissions standards.179 The Advanced Clean Trucks Regulation requires manufacturers of
vehicles that are based on combustion engines to sell a percentage of zero-emission MHDVs and
Class 2b vehicles (i.e., vehicles with GVW ratings just below that of MHDVs).180 This
requirement applies to manufacturers who certify they are compliant with regulations on tailpipe
emissions from chassis cab181 or complete MHDVs. The percentage of California sales required
of these manufacturers will increase over time depending on the type and class of truck.
174 Eric Miller, “California OKs Advanced Clean Fleets Regulation: Truckers Criticize Rule as Unworkable,”
Transport Topics, April 28, 2023, https://www.ttnews.com/articles/california-clean-fleets-rule.
175 89 Federal Register 57151 (July 12, 2024).
176 Letter from Steven S. Cliff, Executive Officer, CARB, to Jane Nishida, Acting Administrator, U.S. EPA,
January 13, 2025, https://www.epa.gov/system/files/documents/2025-01/ca-acf-carb-withdrawal-ltr-2025-1-13.pdf.
177 CARB, Advanced Clean Fleets Regulation Summary, May 17, 2023, https://ww2.arb.ca.gov/resources/fact-sheets/
advanced-clean-fleets-regulation-overview.
178 CARB, Advanced Clean Fleets Regulation Summary.
179 EPA, “California State Motor Vehicle and Engine Pollution Control Standards; Heavy-Duty Vehicle and Engine
Emission Warranty and Maintenance Provisions; Advanced Clean Trucks; Zero Emission Airport Shuttle; ZeroEmission Power Train Certification; Waiver of Preemption; Notice of Decision,” 88 Federal Register 20688
(April 6, 2023). Generally speaking, states are prohibited from adopting or enforcing standards for emissions from new
motor vehicles and vehicle engines (42 U.S.C. §7534(a)). Certain states may, subject to a waiver by the Administrator
of EPA, set their own standards if the state determines such standards to be at least as protective of public health and
welfare as federal standards (42 U.S.C. §7543(b)). The Administrator may waive the prohibition only if the states had
issued standards prior to March 30, 1966. Other states may nonetheless issue standards identical to California’s
(42 U.S.C. §7507).
180 CARB, Advanced Clean Trucks Fact Sheet: Accelerating Zero-Emission Truck Markets, August 20, 2021,
https://ww2.arb.ca.gov/resources/fact-sheets/advanced-clean-trucks-fact-sheet.
181 A chassis cab is a truck without a complete body that may be upfit to a variety of commercial configurations. See,
for example, Ford Motor Company, “2022 Ford Super Duty® Chassis Cab,” 2023, https://www.ford.com/commercialtrucks/chassis-cab/, accessed January 10, 2023.
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Legislation Introduced in the 118th Congress
A number of bills introduced in the 118th Congress would have addressed the use of fuel cellelectric MHDVs.
The Hydrogen for Ports Act of 2023, S. 647, would have authorized a grant program for, among
other purposes, “the purchase, installation, planning, design, or construction of, as appropriate ...
fuel cell drayage or long-haul trucks that—(i) use an eligible fuel; and (ii) are for use at ports.” S.
647 was referred to the Committee on Commerce, Science, and Transportation. In the House,
H.R. 6872 had a similar provision as in S. 647 to provide grants for “fuel cell trucks.” H.R. 6872
was referred to the Committee on Energy and Commerce and the Committee on Transportation
and Infrastructure.
The Hydrogen for Trucks Act of 2023, S. 648, would have established a demonstration program
that included elements aimed toward parallel market adoption of refueling infrastructure and the
vehicles themselves. S. 648 was referred to the Committee on Commerce, Science, and
Transportation. In the House, H.R. 6871, the Hydrogen for Trucks Act, was referred to the House
Committee on Science, Space, and Technology. Both S. 648 and H.R. 6871 had a provision for
grants to assist “in funding capital projects to purchase heavy-duty fuel cell vehicles and related
equipment, including hydrogen fueling stations.”
H.R. 3447 would have authorized “a hydrogen powered vehicle to exceed certain weight limits on
the Interstate Highway System.” The bill was reported by the Committee on Transportation and
Infrastructure (H.Rept. 118-217) on September 26, 2023. The bill would have modified 27 U.S.C.
§127, “Vehicle weight limitations-Interstate System,” to raise the maximum allowable weight of
fuel cell-electric trucks to be 82,000 lb., on a par with vehicles using natural gas-fueled
combustion engines and battery-electric powertrain.
The Vehicle Innovation Act of 2023, H.R. 4542, would have, among other purposes, authorized a
program on materials and manufacturing processes of advanced vehicle technologies. The bill
included research, development, and demonstration on advanced energy technologies for MHDVs
in commercial, vocational, and transit applications, specifically on fuel cells, hydrogen fueling
infrastructure, and refueling equipment design and concepts. The bill further required DOE to
provide financial assistance for integration of numerous vehicle technologies on medium- and
heavy-duty platforms and trailers. The bill was referred to the House Committee on Science,
Space, and Technology and to the House Committee on Energy and Commerce and to the latter’s
Subcommittee on Energy, Climate, and Grid Security. An identical bill in the Senate, S. 1099, was
referred to the Committee on Energy and Natural Resources.
The Hydrogen Infrastructure Finance and Innovation Act, H.R. 7200, would have established a
pilot program and provided grants or loans for a range of hydrogen transportation, storage, and
delivery activities, including refueling. The act would have also expanded the scope of the Title
XVII loan guarantees authorized by the Energy Policy Act of 2005 so that the eligible categories
included not just hydrogen fuel but also hydrogen technologies in the transportation sector.182 The
bill was referred to the Committee on Energy and Commerce, the Committee on Transportation
and Infrastructure, and the Committee on Science, Space, and Technology.183 An identical bill in
the Senate, S. 649, was referred to the Committee on Energy and Natural Resources.
182 For further information on the loan program, see CRS Insight IN11432, Department of Energy Loan Programs:
Title XVII Innovative Technology Loan Guarantees, by Phillip Brown et al.
183 The bill was subsequently referred to the Subcommittee on Railroads, Pipelines, and Hazardous Materials and the
(continued...)
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Summary and Framework for Consideration
This section summarizes the bills discussed above and, in Table 3, presents a framework for
considering their impact on deployment. The table lists the bills and summarizes them according
to the form of financial or other assistance each would have provided and the focus of the
program. For each program, Table 3 indicates which aspect of deployment would have been
affected. Generally speaking, the assignment to the categories indicates the type of business that
would have been the direct beneficiary of the financial assistance, but other categories might
benefit indirectly. Thus, the categories are not mutually exclusive.
Subcommittee on Highways and Transit of the Committee on Transportation and Infrastructure and to the
Subcommittee on Energy, Climate, and Grid Security of the Committee on Energy and Commerce.
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Table 3. Bills in the 118th Congress That Addressed Deployment of Hydrogen MHDVs
Bill
Form of
Assistance
Purpose and Activities
Hydrogen for Ports Act of
2023, S. 647; and Hydrogen for
Ports Act, H.R. 6872
Grants
Purchase of fuel cell-powered
equipment and hydrogen refueling
equipment
Hydrogen for Trucks Act of
2023, S. 648; and Hydrogen for
Trucks Act, H.R. 6871
Grants
Purchase of fuel cell-electric heavy
trucks and related equipment,
including refueling equipment
H.R. 3447 [untitled]
Regulatory change
Add 2,000 lb. to weight limit
Vehicle Innovation Act of 2023,
H.R. 4542; and Vehicle
Innovation Act, S. 1099
Grants
Development of vehicle
technologies; participants from
multiple sectors; off-road
equipment
Hydrogen Infrastructure
Finance and Innovation Act,
H.R. 7200; and S. 649 [identical
title]
Grants and loans
Loans for purchase of hydrogen
transportation and delivery
infrastructure
Source: CRS analysis of bills.
Notes: MHDVs = medium- and heavy-duty vehicles; mfg. = manufacturing; lb. = pounds.
a. The bill emphasizes research and development (i.e., predeployment).
CRS-35
Fueling
Infrastructure
Vehicle
Mfg.
X
Vehicle
Purchase
Operations:
Ports
X
X
Operations:
Fleets
X
X
Xa
X
X
Hydrogen-Fueled Medium- and Heavy-Duty Vehicles
Considerations for Congress
This section describes a number of potential issues for consideration by Congress. First is a series
of options for consideration by Congress if it decides that support for the deployment of fuel cellelectric MHDVs is warranted. Principally, the policy options for Congress given below would
address the infrastructure for transporting and dispensing hydrogen, vehicle manufacturing,
vehicle purchase by fleets, and the final use of hydrogen for energy services in truck fleets (e.g.,
port operations, goods movement). Then this section describes possible oversight activities
related to current hydrogen and fuel cell-electric MHDV programs.
Risks of Government Support for Hydrogen-Fueled Trucks
In providing financial assistance, government assumes the risk that it might support a failed
enterprise—the failure of fuel cell-electric trucks to achieve market share. Further, even if
technologically successful, the government-supported technology may be overtaken or obviated
by other developments or changes in market conditions, as was the case with synthetic fuels in
the 1970s and 1980s.184 Small owner-operators who buy trucks secondhand at lower prices will
likely not purchase new fuel cell-electric MHDVs at full price and thus not be a beneficiary of the
government support. Critics of hydrogen also point to the availability of electric vehicles, and
these two alternative powertrains (fuel cell-electric and battery-electric) will be competing for the
same market in a zero-sum fashion: the more one powertrain captures the benefits, the less the
other will.
Streamlining Federal Programs
In S.Rept. 118-72, which the joint explanatory statement to the Consolidated Appropriations Act,
2024 (P.L. 118-42) incorporated by reference, the Senate Appropriations Committee took note of
the number of coordination mechanisms—including crosscuts and “Earthshots,” such as the
Hydrogen Shot program—and directed DOE to simplify and consolidate these into one function.
Such consolidation could result in a harmonization of goals between hydrogen hubs and hydrogen
corridors, for example. One option for congressional oversight could be to require a management
study of consolidating these coordination mechanisms, either by DOE, an outside organization
such as the National Academy of Public Administration following the Federal Advisory
Committee Act, Section 15 (P.L. 105-153), or a similar external entity.185
Addressing Deployment of Fuel Cell-Electric Trucks
Fleet Operations
Prizes
Congress could offer a monetary prize to makers of medium- and heavy-duty fuel cell-electric
vehicles structured around criteria on the movement of freight. Such criteria could include the
range and cargo size (mass). For example, the prize might be awarded for a vehicle made in a
184 National Research Council, The Government Role in Civilian Technology: Building a New Alliance (National
Academy Press, 1992), p. 59.
185 Congress gave a similar direction on p. 212 of H.Rept. 115-929, which accompanied P.L. 115-244, the Energy and
Water, Legislative Branch, and Military Construction and Veterans Affairs Appropriations Act, 2019.
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production run of at least 10 substantially equivalent vehicles or tractors that could haul a cargo
of 30,000 lb. a certain distance without refueling.
Another possibility would be to apply the prize to a fleet of trucks; for example, the prize could
be awarded to a fleet that, in the aggregate, moved a certain number of ton-miles of cargo in
revenue operations using fuel cell-electric vehicles. To increase recognition, Congress could host
the award of the prize as was done in 2011 for the Bright Tomorrow Lighting Prize (L-Prize).186
Corridors
Congress could authorize and fund a program drawn on the Highway Trust Fund for hydrogen
truck corridors and require that this program harmonize with the Regional Clean Hydrogen Hubs.
This program could be an extension of the Charging and Fueling Infrastructure Grant Program
authorized by the IIJA (23 U.S.C. §151(f)). Through the Alternative Fuel Corridor Grants
(“corridor grants”), Congress could integrate hydrogen corridors with the Regional Clean
Hydrogen Hubs. In establishing program requirements, Congress could, for example, direct
FHWA to require that the corridor have at least one terminus in a Regional Clean Hydrogen Hub.
Congress could direct FHWA to make awards according to some of the following criteria:
•
•
•
•
•
geographic diversity;
vehicle diversity (Class 4, Class 8, and other);
mission diversity (drayage, regional haul, long haul);
anticipated heavy-duty vehicle traffic, commensurate with the number of
refueling stations; and
employment and service workforce (training, access).
Weight Limits
Currently, fuel cell MHDVs must comply with the same weight limits as conventional vehicles.
Although Section 1410 of the FAST Act (P.L. 114-94) provided an additional 2,000 lb. of
allowable weight for two types of vehicles with alternative fuels and powertrains—batteryelectric and compressed natural gas-combustion vehicles—there is no current federal allowance
for fuel cell-electric vehicles.187 Congress could consider adding an additional weight allowance
for fuel cell-electric MHDVs, as in H.R. 3447 (where they are termed “hydrogen fuel cell
vehicles”) in the 118th Congress.
The benefits for fuel cell adoption include making fuel cell-electric trucks more competitive with
conventional vehicles. Especially in applications in which trucks move goods, any reduction in
cargo capacity can make a vehicle less competitive. The additional 2,000 lb. would compensate
for the higher tractor weight of a fuel cell-electric truck relative to a diesel. Some analysts argue
that greater weight would improve fuel consumption and safety by reducing the number of overall
186 Sen. Jeff Bingaman and Sen. Lisa Murkowski hosted the announcement of the winner of the L-Prize in 2011. Light
Directory, “DOE Announces Philips as First Winner of the L Prize Competition,” press release, August 2, 2011,
https://m.lightdirectory.com/news-DOE-Announces-Philips-As-First-Winner-Of-The-L-Prize-Competition.htm.
187 23 U.S.C. §127(s).
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Hydrogen-Fueled Medium- and Heavy-Duty Vehicles
trips.188 Potential drawbacks include incremental damage to road surfaces incurred at higher
weights.189
Fuel Consumption Standards
The presence of fuel cell-electric vehicles in a manufacturer’s sales allows for favorable treatment
in the NHTSA fuel consumption regulations. Were a manufacturer to produce sufficient numbers
of such vehicles, they would have an easier time achieving compliance with NHTSA fuel
consumption regulations. This creates an incentive to sell such vehicles. In the regulations, fuel
cell-electric vehicles benefit from an advanced vehicle technology credit that makes each such
vehicle, already highly advantageous to compliance, have the effect of 5.5 vehicles in a feature
known as multipliers.190 In effect, the advanced vehicle technology credits offset any
underperforming combustion powertrain vehicles. Congress could enact the current system of
credit multipliers, due to expire after model year 2027.191
Advantages and Disadvantages
An advantage of having the credits resulting from the credit multiplier past model year 2027 is
that it would provide a continued incentive for market uptake of fuel cell-electric trucks, and it
has since combined with other incentives for deployment of hydrogen trucks discussed above in
“Financial Assistance Programs on Deployment of Hydrogen Trucks.” At the time this system of
credits was last proposed, in 2016, EPA said that “adoption rates for these advanced technologies
in heavy-duty vehicles are essentially nonexistent today and seem unlikely to grow significantly
within the next decade without additional incentives.”192 NHTSA deemed this a method to
encourage manufacturers to “generate a viable business case” for such vehicles.193 The CARB,
commenting on NHTSA’s proposed rule for MHDVs, stated that credits would help in
accelerating the deployment of “zero-emission trucks.”194 More generally, stable incentives send a
consistent policy signal about government expectations for innovation. The effect of incentives
can include retaining knowledge essential to technology innovation and reducing the uncertainty
faced by private-sector investors.195
188 J. Woodrooffe, “Opportunity Cost for Society Related to U.S. Truck Size and Weight Regulation,” Journal of the
Transportation Research Board, vol. 2547 (January 1, 2016), pp. 25-31.
189 A 2016 report by FHWA estimates that raising the weight limit to 88,000 lb. might incur an additional 0.4% to 0.7%
in pavement lifecycle costs and a one-time investment in bridges of $0.4 billion. FHWA, Comprehensive Truck Size:
Report to Congress, April 2016, https://ops.fhwa.dot.gov/freight/sw/map21tswstudy/ctsw/CTSLWS Report to
Congress FINAL.pdf.
190 One fuel cell vehicle counts as 5.5 vehicles in the current program (49 C.F.R. 535.7(f)(1)(ii)), but the value of the
multiplier effectively decreases to one after model year 2027. 81 Federal Register 73498 (October 25, 2016); and DOT,
NHTSA, “Corporate Average Fuel Economy Standards for Passenger Cars and Light Trucks for Model Years 2027 and
Beyond and Fuel Efficiency Standards for Heavy-Duty Pickup Trucks and Vans for Model Years 2030 and Beyond,”
89 Federal Register 52924 (June 24, 2024).
191 After 2027, the multipliers effectively revert to unity (i.e., become equal to one). 81 Federal Register 73498
(October 25, 2016); and EPA, “Greenhouse Gas Emissions Standards for Heavy-Duty Vehicles—Phase 3,” 88 Federal
Register 26013 (April 27, 2023).
192 81 Federal Register 73498 (October 25, 2016).
193 81 Federal Register 73498 (October 25, 2016).
194 Letter from Mary D. Nichols, Chair, Air Resources Board (California), to Gina McCarthy, EPA Administrator, and
Mark R. Rosekind, NHTSA Administrator, October 1, 2015, p. 71, https://ww2.arb.ca.gov/sites/default/files/classic//
msprog/onroad/caphase2ghg/comments/carb_phase_2_comments.pdf.
195 M. Jaccard et al., “Policies for Energy System Transformations: Objectives and Instruments,” in Global Energy
(continued...)
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A disadvantage is that increasing the number of fuel cell vehicles would allow a manufacturer’s
conventional vehicles to have higher fuel consumption. CARB estimated that a 3% uptake of the
advanced vehicle technology credits (with multiplier) for model year 2027 and later would reduce
the benefits of the regulations overall by 3% in 2050.196
Federal Excise Tax
Currently there is a 12% federal excise tax (FET) on the sale of trucks. Additionally, certain
trucks with GVW ratings of 55,000 lb. pay an annual use tax.197 These excise taxes are one source
of support for the Highway Trust Fund, though the vast majority of support—85% to 90%—
derives from motor fuel taxes.198
Congress could add technologies to the list of exemptions from the FET. For example, Congress
could exempt the purchase of an APU operating on hydrogen from the FET. The APU appears on
vehicles needing continuous refrigeration, such as on long-haul Class 8 vehicles. Congress has
already exempted certain idling technologies, sometimes called “start-stop” technologies, from
the FET.199 Generally speaking, only aftermarket devices are eligible.
Another approach to modifying the excise tax might be to exclude the incremental cost of the
powertrain. The incremental cost of the fuel cell powertrain would be determined relative to a
vehicle with a conventional powertrain. Carrying out such an exemption would necessitate a
method to calculate the incremental cost that would be exempted. As discussed above in the
section “Commercial Clean Vehicles: Internal Revenue Code Section 45W,” the IRS has such a
method for calculating the incremental cost already in place.
An advantage of excluding the purchase price of the truck and aftermarket equipment from the
FET is to increase adoption of fuel cell-electric MHDVs versus trucks sold with conventional
powertrains.200 A disadvantage of an exemption is that it would reduce the amount of money paid
into the Highway Trust Fund, which is the source of funds used to construct highways and to
build out charging and refueling infrastructure for battery-electric vehicles and fuel cell-electric
vehicles.
Loan Programs
Congress could evaluate whether the scope of eligible projects under the Title XVII loan
programs, authorized by Section 1703 of the Energy Policy Act of 2005 (42 U.S.C. §16513),
could be expanded to include hydrogen vehicles as a category eligible to receive loan guarantees.
Assessment: Toward a Sustainable Future, ed. Thomas B. Johansson et al. (Cambridge University Press, 2012),
p. 1580.
196 Nic Lutsey, Integrating Electric Vehicles Within U.S. and European Efficiency Regulations, International Council
on Clean Transportation, Working Paper 2017-07, June 22, 2017, p. 4, https://theicct.org/sites/default/files/
publications/Integrating-EVs-US-EU_ICCT_Working-Paper_22062017_vF.pdf; and Letter from Mary D. Nichols,
Chair, Air Resources Board (California), to Gina McCarthy, EPA Administrator, and Mark R. Rosekind, NHTSA
Administrator, October 1, 2015, p. 71, https://ww2.arb.ca.gov/sites/default/files/classic//msprog/onroad/caphase2ghg/
comments/carb_phase_2_comments.pdf.
197 DOT, FHWA, Office of Highway Policy Information, “Heavy Vehicle Use Tax,” June 23, 2020,
https://www.fhwa.dot.gov/policyinformation/hvut/mod1/whatishvut.cfm.
198 CRS Report R46938, Federal Excise Taxes: Background and General Analysis, by Anthony A. Cilluffo; and CRS
Report R47022, Federal Highway Programs: In Brief, by Robert S. Kirk.
199 The Energy Improvement and Extension Act of 2008 (P.L. 110-343, Division B), Section 206, excluded “idling
reduction devices” and advanced insulation from the FET.
200 Kevin Jones, “Can EV Enthusiasm Spark FET Repeal?” FleetOwner, March 10, 2023.
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Currently, Title XVII applies to hydrogen fuel. In the 118th Congress, the Hydrogen Infrastructure
Finance and Innovation Act, H.R. 7200 and S. 649, would have expanded the scope of the Title
XVII loan guarantees to include hydrogen technologies in the transportation sector, among other
end uses.201
Summary of Options and Framework
This section summarizes options for consideration by Congress and applies the framework given
in the section “Recent Developments,” above. Table 4 summarizes the program options,
including the form of assistance and a brief description. For each program, Table 4 also indicates
which aspect of deployment would be addressed.
201 For further information on the loan program, see CRS Insight IN11432, Department of Energy Loan Programs:
Title XVII Innovative Technology Loan Guarantees, by Phillip Brown et al.
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Table 4. Options Congress Could Consider for Deployment of Fuel Cell-Electric MHDVs
(options may require new authorizing statute or amendment to existing statute)
Possible Authorizationa
Form of
Assistance
Purpose and Activities
Fueling
Infrastructure
Vehicle
Mfg.
Vehicle
Purchase
Operations:
Ports
Operations:
Fleetsb
None at present
Prize
Award to first fleet to move a
specified quantity (ton-miles) of
goods
X
23 U.S.C. §151
Highway Trust Fund
grants
Fund operations along
alternative fuel corridors
X
23 U.S.C. §127(s)
Regulatory relief
Add 2,000 lb. to weight limit
(H.R. 3447, 118th Congress)
X
42 U.S.C. §32902(b)
Regulatory credits
Maintain vehicle technology
credit toward fuel consumption
compliance
X
26 U.S.C. §4053
Excise tax relief
Exempt fuel cell APUs from
federal excise tax
X
Title XVII,c 42 U.S.C. §16513
Loan guarantees
Make FCEVs eligible (H.R. 7200,
118th Congress)
X
Source: CRS analysis.
Notes: MHDV = medium- and heavy-duty vehicle; lb. = pounds; mfg. = manufacturing; APU = auxiliary power unit; FCEV = fuel cell-electric vehicle; ton-miles = the
mathematical product of the cargo weight and the distance moved.
a. Where given, citations are broad indicators of where there is an existing authorization in a similar or adjacent program that could be amended.
b. Includes regional- and long-haul fleets. See description in the section “Operations.”
c. Title XVII of the Energy Policy Act of 2005 (P.L. 109-58), 42 U.S.C. §§16511-16517.
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Oversight
Congress may conduct hearings or fact-finding activities on the effectiveness and efficiency of
several programs.
Success of Early Deployment
Congress may monitor the build-out of refueling infrastructure and consider whether federal
financial incentives would correct any shortfalls or, conversely, if the number of FCEVs is
commensurate with the number of HRS. In 2022, the California Energy Commission estimated it
had built almost four times as much dispensing capacity as it needed for light-duty FCEVs in the
state.202 Congress could further consider whether the IRC 45W tax incentive is driving the
purchase of too few or too many hydrogen-fueled MHDVs relative to the number of HRS.
Congress could also consider the role of IRC 30C, the Alternative Fuel Refueling Property Credit,
in achieving the appropriate balance between the number of vehicles and refueling capacity.
Congress could also consider the number and size of hydrogen refueling infrastructure projects
selected in IIJA Section 11401 grants. For example, of the $613 million of awards announced
January 17, 2024, $89 million was for projects for hydrogen refueling or a combination of
hydrogen refueling and electric charging for MHDVs.203
The Role of MHDVs in Regional Clean Hydrogen Hubs
In the IIJA, Section 40314, Congress gave several criteria for the selection of the hydrogen hubs.
The end-use diversity criterion specifies at least one hub be based on the transportation sector.204
Congressional oversight activities could examine how and to what extent DOE has awarded grant
monies to any hubs that have a transportation focus or have been identified by DOE as having a
transportation focus, and Congress could examine the extent to which the grant recipients are
including fuel cell-electric MHDVs. The California Hydrogen Hub, being developed by
ARCHES, envisages 5,000 or more fuel cell-electric trucks, Classes 6 through 8, and 60 HRS
stations for MHDVs.205
Grants and Contracts
The agencies are implementing a number of additional spending programs related to hydrogen
trucks; many of these programs have several hundred million dollars appropriated to them.
Agencies have set goals for when they will open solicitations and make the awards. These
include, but are not limited to, the Clean Heavy-Duty Vehicles Program ($1 billion, IRA); the
Reduction of Truck Emissions at Port Facilities Grant Program ($400 million, IIJA); and the Port
Infrastructure Development Program ($2.25 billion, IIJA, and over $500 million from annual
202 J. Berner et al., Joint Agency Staff Report on Assembly Bill 8: 2022 Annual Assessment of Time and Cost Needed to
Attain 100 Hydrogen Refueling Stations in California, California Energy Commission, CEC-600-2022-064,
December 22, 2022, p. 39, https://www.energy.ca.gov/publications/2022/joint-agency-staff-report-assembly-bill-82022-annual-assessment-time-and-cost.
203 FHWA, “Biden-Harris Administration Announces $623 Million in Grants to Continue Building Out Electric
Vehicle Charging Network,” press release, January 11, 2024, https://highways.dot.gov/newsroom/biden-harrisadministration-announces-623-million-grants-continue-building-out-electric.
204 The end-use diversity criterion also required at least one hub to be based on each of the following: electric power
generation; industrial sector; and commercial and residential heating.
205 DOE, OCED, Regional Clean Hydrogen Hubs Program: California Hydrogen Hub (ARCHES), July 2024.
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appropriations from FY2022 through FY2024).206 Congress may monitor awards, obligations, and
outlays.
Author Information
Martin C. Offutt
Analyst in Energy Policy
Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and
under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in
its entirety without permission from CRS. However, as a CRS Report may include copyrighted images or
material from a third party, you may need to obtain the permission of the copyright holder if you wish to
copy or otherwise use copyrighted material.
206 Includes $234.31 million in FY2022, $212.20 million in FY2023, and $120.46 million in FY2024; $50 million of
FY2024 monies may be used for discretionary grants.
Congressional Research Service
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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.