Guidebook for Deploying Zero-Emission Transit Buses (2021)

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97 PHASE 6 ACCEPTANCE, VALIDATION, AND DEPLOYMENT 6.1 Overview In advance of your ZEBs arriving at your property, you will need to coordinate bus inspection, acceptance, and validation activities that will help ensure your buses meet contractual and performance requirements prior to deployment. This phase of deployment includes: During bus build, a resident inspector should perform on-site inspections, similar to the approach that you have taken with non- ZEB purchases. Inspectors should have specific knowledge of electric drive vehicles and high-voltage systems, potentially necessitating a specialized inspection company. ZEB experts can be contracted to perform inspections or educate in-house inspectors on the technology through assisted inspection. Once your buses are through production, pre- and post-delivery inspections will ensure buses meet your specifications and that no damage was done during delivery. After delivery, you will have a window for acceptance testing. Operator training will likely be taking place shortly after the buses are delivered (See Phase 7: Personnel Training and Development). Bus fueling infrastructure should be installed prior to delivery to effectively test the fueling of your buses. Validation testing, performed in conjunction with acceptance testing, will verify that actual bus performance meets expectations from your modeling efforts. Results will support strategic deployment of your buses, maximizing utilization under all conditions. Best practices for acceptance, validation, and deployment include: • Creating and executing a clear inspection plan supported by a well-defined technical specification. • Conducting acceptance and validation testing to ensure delivered buses perform as planned. • Refining your initial deployment strategy based on validation results. • Vehicle inspection, • Acceptance testing, • Validation testing, and • Deployment planning.

98 Guidebook for Deploying Zero-Emission Transit Buses 6.2 Key Stakeholder Considerations Project Managers • Select a vehicle inspector either from your transit agency’s staff or a third- party vendor that is familiar with electric drive vehicles and high-voltage system build practices. • Schedule a review on site at the OEM with your transit agency’s ZEB deployment team prior to the first vehicle being approved for shipment. • Coordinate with transit agency staff to develop an acceptance and validation testing plan. Some tests will require the participation of staff from the operations, maintenance, and facilities departments (e.g., road tests, testing the bus under various loads, identifying challenging locations in the service area). • Utilize the results of validation testing to update model assumptions for future deployment analyses. • Engage operations staff when developing a deployment plan. For your first deployment, consider starting vehicles on less challenging blocks to accommodate a learning curve for technology nuances. • Inform decision makers on the validated range in your service area at the conclusion of testing to set realistic expectations of vehicle performance. Operations, Maintenance, and Facilities • Ensure charging infrastructure has been installed prior to vehicle acceptance. • Coordinate training on conducting post-delivery inspections with the OEM in advance of bus arrival to ensure that you have the information needed to conduct a thorough inspection of new components. • Conduct post-delivery inspections and coordinate with the OEM to confirm that all repairs are completed prior to acceptance. • Coordinate with bus and fueling equipment OEMs to commission the buses with the chargers after the first bus arrives. • Identify possible service blocks for deployment and work with the project manager to develop a deployment plan. Procurement • Ensure your RFP requires specific knowledge of ZEBs and demonstration of qualifications, if utilizing a third-party vendor for inspection. External Stakeholders • Third-party vendors may be utilized to conduct vehicle inspections. Establish procedures for reporting the results of inspections. • Coordinate with local politicians for ribbon cutting ceremonies or other promotional events highlighting your deployment.

Acceptance, Validation, and Deployment 99 6.3 Vehicle Inspection The FTA requires resident inspectors for bus orders larger than 10 buses. Resident inspectors must conduct inspections at the OEM’s final assembly facility and must visually inspect and road test the vehicles. See FTA’s Post-Delivery Review Requirements for more information regarding federal resident inspection regulatory requirements. While it is good practice for your maintenance lead to participate in inspections, a qualified ZEB inspector is suggested as well. ZEB experts can either conduct the inspections on your behalf or educate your chosen inspectors on ZEB technology (Figure 6-1). 6.4 Bus Inspection Plan Include a bus inspection plan in your bus procurement documents to ensure that all components and assemblies meet your quality standards throughout the production process and that the buses comply with the design and technical specifications. Outline procedures for inspecting and testing materials, work in process, and completed articles in your inspection plan. You should have well-defined technical specifications for the vehicle, identifying all approved equals, that will drive the inspection plan and ensure all parties have a clear and concise understanding about what is expected. Your resident inspectors will provide regular reports of their findings, the buses’ progress through the manufacturing process, and corrective actions taken by the OEM to address any issues with quality. Transit agencies either contract inspection activities to a third-party or utilize in-house inspectors. 6.4.1 Configuration Audit For larger orders, there will be a pilot bus produced well in advance of the remaining buses in the order. This prototype or “first article” should be delivered far enough in advance of the remaining order so that any needed changes can be incorporated into the final bus design for the remaining buses. A configuration audit should be conducted at the manufacturing facility when the first article vehicle is almost finished. The audit criteria and process should be well defined in the contract as a milestone delivery with clear roles for all parties. The goal of the Federal requirements may change due to changes in law, regulation, other requirements, or guidance. Familiarize yourself with the most current inspection requirements prior to developing your inspection plan. Figure 6-1. ZEB vehicle inspector criteria.

100 Guidebook for Deploying Zero-Emission Transit Buses configuration audit is to verify that the vehicle meets the contract requirements, reflecting any change orders, and to reveal any items requiring correction prior to first article inspection. 6.4.2 First Article Inspection The first article inspection should be conducted when the first bus is complete, and all issues from the configuration audit are addressed. When complete, the first article inspection provides a verified compliant configuration so that a notice to proceed (NTP) can be issued for the rest of the order. 6.4.3 Pre-Delivery Inspection Your on-site inspector will conduct a final review of the completed bus before the OEM can release the bus to be shipped to your property. Transit agencies may elect to have the staff managing the ZEB procurement along with a ZEB bus expert visit the OEM prior to article completion to review the manufacturing processes and ensure that the bus meets quality standards and specifications. 6.4.4 Post-Delivery Inspection Once the bus arrives at your facility, your transit agency needs to conduct a post-delivery inspection (PDI) of each article. If zero-emission technology is new to your transit agency, ask the bus OEM to provide training to your maintenance staff in conducting PDIs for the new bus components. Coordinate with the OEM to ensure all items identified in the PDI are addressed to your satisfaction prior to acceptance. 6.5 Acceptance and Validation Testing After your buses are delivered and your fueling infrastructure is installed, you will want to test the performance and functionality to ensure that all contractual requirements for bus operations have been meet (acceptance testing) and that actual performance is in line with expected performance (validation testing). Acceptance and validation testing may reveal unanticipated issues with the buses. Work closely with the OEM to ensure issues are addressed prior to bus acceptance. For smaller orders, transit agencies may combine the configuration audit, first article inspection, and pre-delivery inspection in the same visit, but all inspections should be completed before shipment. Note that ZEBs may arrive at your facility with fewer miles than conventionally fueled vehicles, since ZEBs will not typically be driven from the manufacturing plant to your facility. Therefore, ZEBs may have less driving time to identify potential issues before arriving on-site.

Acceptance, Validation, and Deployment 101 Ensure that the acceptance criteria outlined in your contract require the fueling infrastructure to be installed prior to bus acceptance and commissioned in conjunction with bus acceptance . Bus procurement contracts have a set period of time for a transit agency to test and accept buses. Since many operators are unfamiliar with the technology, ZEB acceptance periods may need to be longer than standard to allow adequate time for training and acceptance. Be sure your contract is clear that the acceptance testing period should not begin upon bus delivery if fueling equipment has not been installed (See Section 2.5.2: Acceptance Criteria). The goal of validation testing is to collect actual bus and fueling infrastructure performance data to validate any assumptions that you made in your route and charge modeling efforts (See Section 2.3: Bus Performance Evaluation). Evaluating this data will allow you to confirm that your assumptions are valid or to adjust expectations with respect to range and bus performance. In general, the results of your validation testing will not be considered criteria for acceptance or non-acceptance of a bus. However, this will inform bus deployment plans, identify potential risks and assist with future planning of ZEB expansion. By validating and updating your ZEB route and charging models, you create a tool that helps plan for end-of-life battery capacity and future ZEB route options. Use the results of validation tests to update the model to ensure that the buses will perform as needed. If your bus is performing significantly differently from the model results, you may need to troubleshoot with the OEM to determine where the discrepancy exists. 6.5.3 Suggested Tests In advance of your buses being delivered to your transit agency, develop a plan that will outline and schedule all acceptance and validation tests that you will conduct. Refer to your technical specifications and ensure that your tests allow you to confirm the bus meets all contractual requirements. The acceptance period should be used to test the full operation and functionality of each bus. Ensure that you test all conditions that your bus may expect to encounter during revenue service. In addition to your existing bus acceptance procedures (e.g., inspections, bus wash, IT system configuration), you should consider conducting the following tests: Depending on how your contract is written, the results of some of these tests may not be considered acceptance criteria. However, the results should help refine your simulation model, improving its accuracy for future deployments. They will also be useful for identifying any needed adjustments to your deployment plan. 6.5.1 Acceptance Testing Goals 6.5.2 Validation Testing Goals

102 Guidebook for Deploying Zero-Emission Transit Buses • Operating Range: Test the total range of the bus under various conditions, such as in different traffic patterns, on different routes, with different HVAC and auxiliary loads, or weighted sandbags or water barrels. For BEBs, record the total range when operating the bus over the usable SOC. For FCEBs, record the total range to an empty tank. If you included range requirements in your technical specifications, be clear under what conditions that range is being measured. Are those range requirements to be met under any specific conditions while in transit service? If your technical specifications are put together properly, then they will account for how the bus range will be impacted by ambient temperature, traffic conditions, battery age, and the driver. • Maneuverability: Drive the bus on “challenging” locations in the service area (e.g., steep grades, hill starts, difficult turns, hard acceleration). Record top speeds, time to accelerate, and any difficulties or unexpected behaviors that drivers experience. • Performance at a “Low” SOC: Determine how performance changes when operating the bus at a low SOC. Operating the bus at a low SOC is not recommended while in regular service, as this impacts battery life, but it should be tested at delivery. Evaluate how performance changes at a low SOC and when warning notifications appear on the dashboard. Ask the OEM what would be considered a “low” SOC for your buses (usually below 20%). For FCEBs, test performance at challenging locations in your service area where sustained higher power outputs could potentially drain the battery. This may be accomplished by performing a hill climb after sustained high speeds. • Performance Under Load: Testing should confirm that the bus shows acceptable performance under various conditions. Conduct all testing at various weights (e.g., curb weight, gross vehicle weight rating) and with high- and low-temperature HVAC loads. Varying conditions may impact energy efficiency, which can be used to plan for bus range on hot and cold days that will require more energy from the battery to make up for increased HVAC load. • Charger Compatibility: Plug in each bus to each charger to ensure that all the buses charge successfully at the expected rate. Coordinate with the bus and charger OEMs to address any performance issues with the chargers. Total bus range will decrease over time as the battery degrades. Consider this capacity loss when planning for revenue service deployment.

Acceptance, Validation, and Deployment 103 6.6 Initial Deployment Strategy ZEB technology will apply additional constraints to your service planning compared to conventionally fueled buses. An initial deployment plan should appropriately minimize the costs to your transit agency to accommodate the constraints, optimize the bus utilization in your service area, and include decision-support tools for dispatch to determine if your ZEBs will be capable of completing planned service. Ensure that you complete sufficient planning to maximize bus use throughout its service life considering: • Battery capacity degradation: For BEBs, most battery warranties specify that expected end of life capacity is 70% to 80% of the nameplate capacity over 6 or 12 years. Ensure that the battery capacity is sufficient so that your bus will be able to complete non-trivial blocks in your service area at the end of its service life. • Seasonal variation in energy consumption: Energy consumption will vary seasonally; HVAC systems will use more energy in particularly warm or cold climates. The impact of HVAC systems in colder climates is more apparent in BEBs, as FCEBs can utilize waste heat from the fuel cell, and has been seen through observations to heat the cabin in temperatures as low as 20°F. • Public visibility: Some transit agencies have a specific route or routes in mind for ZEB deployment. These routes may get high ridership or visibility and are a useful tool in advertising that your transit agency is utilizing zero-emission technology. • Pollution reduction in underserved communities: ZEBs deployed in underserved or disadvantaged communities can provide focused environmental benefits due to the lack of harmful GHG emissions. Address Title VI, Title IX, and FTA Environmental Justice regulations in planning for smaller initial deployments to ensure that benefits are distributed around the service area. If zero-emission technology is new to your transit agency, deploying ZEBs on less challenging routes or blocks during the initial deployment allows your drivers and operations staff to get comfortable with the technology and its capabilities, and to further understand sensitivities to different temperatures, loading capacities, routes, or traffic conditions. Your agency may be the first to pilot new technology due to the nature of the market, therefore you should anticipate Avoid unanticipated costs of driver overtime by establishing a plan for road testing activities and ensuring that your acceptance testing window is adequate to complete all necessary tests. Conducting acceptance testing in revenue service deployment can help offset labor costs, if allowed in your contract.

104 Guidebook for Deploying Zero-Emission Transit Buses stumbling blocks. Plan for adequate testing of the new features and document lessons learned for future users. Ensure your ZEB technology can perform on existing routes. Changing routes or blocks to accommodate your ZEB technology may be required as ZEBs compose a larger percentage of your fleet, but a cost/benefit analysis should always be conducted prior to implementing route changes. Establish a plan to periodically evaluate the performance of your ZEBs and adjust your deployment strategy as needed (See Section 9.3: Data Collection and Reporting). 6.7 Additional Resources • Post-Delivery Review Requirements, Federal Transit Administration • Federal Agency-Specific Environmental Justice Information, Department of Justice An agency introducing electric buses alongside route changes inadvertently created local opposition to ZEBs. Don’t make electric buses an excuse for route changes (Aber, 2016).