The road to scale, within Regulatory Compliance

Mt. Hood US Highway 26

The Problem

Federal DOT regulations tend to treat all vehicle batteries and fuel the same. Even very safe, non-volatile battery chemistries like LFP (Lithium Iron Nano-phosphate) and LTO (Lithium Titanium-oxide) batteries are treated like explosive fuel. This poses an obstacle to our Nomadic mobile charging™️ vehicles that would require large amounts of batteries positioned in cargo space. Under the current view of the Federal Laws governing transportation, all classes of lithium batteries that occupy the cargo space (as opposed to conventional fuel tank space) could constitute hazardous materials transportation, and using batteries in the cargo space to power the drivetrain of the vehicle could put us at risk of noncompliance. Due to the vague definitions and lack of Lithium battery class distinction in current US Federal and State Laws –labeling our vehicles with warnings of risk of fire or explosion, while prescribed by law, would be factually incorrect. This has the negative effect of forecasting unreasonable doubt upon the public, and obfuscating the truthful fact that our chosen battery chemistries are among the safest in the world.

Engineering Solutions

Batteries: Enclosures and Disconnects

Large battery banks in the cargo space of the Nomadic mobile charging™️ vehicle can be contained in purposeful enclosures designed to accord with current regulations for transport with proper ISO / DOT / HAZMAT labeling and construction guidelines. Under current law, while in transit battery banks may be treated like hazardous cargo. In use, the storage battery array remains disconnected from the drivetrain of the vehicle. The vehicle is powered in transit by a smaller traction battery pack that generally occupies the same space normally used for the location of a fuel tank, thus complying with conventional vehicle regulations. To transfer charge of the main battery bank in the cargo space to customers, the vehicle would stop and perform an "unloading" operation by connecting the batteries in the cargo space via a high-voltage contactor (an electro-mechanical switch) to the charge controllers to allow consumers access to the charge energy. At this time, the vehicle also extends it's own range by charging it's own traction pack from the cargo space batteries while not in motion.
The drawbacks of this approach:

  1. The primary battery bank is unable to be utilized for energy transfer to the vehicle traction motors while in motion, adding unnecessary complexity and cost to the system.
  2. The primary battery banks will still constitute cargo and would therefore be treated as hazardous materials which would come with extra restrictions, procedures, and expenses.

Methanol fuel cells

A transitional solution is to use Methanol as a liquid energy storage medium along with fuel cells like those produced by SerEnergy in Denmark. The energy density of methanol exceeds that of any current battery technologies by an order of ≥ 10x. The use of methanol presents the opportunity for our network to extend services into a wider rural area surrounding metropolitan centers while storing all the required energy in a traditional liquid fuel tank. The distribution of dense energy then becomes feasible with little or zero added infrastructure, as the current liquid fuel distribution chain is matured and fully scaled, world-wide. This strategy is already implemented by companies like Bo Hydrogen Technology in Eastern China with a successful deployment track record of over 4 years and counting. This technology embodies a very suitable stopgap technology while regulations change and battery technologies improve. Methanol fuel cells produce only a single gaseous emission, CO2. Green Methanol can be produced by a number of sustainable methods regionally. A common method utilized by industry in Iceland is sequestering industrial CO2 emissions, and hydrogen from renewable sources of electricity (hydro, geothermal, wind and solar). A method that would find support among timber producing communities of the Pacific Northwest is distillation of biological feed stocks such as waste wood, paper or hemp pulp. Methanol acquired via these methods is a carbon neutral biofuel. Emissions and residual carbon footprint will be offset by green initiatives like reforestation efforts.


Supercapacitor technology in general does not require the same reactive chemicals as batteries and would serve as a means of storing direct electrical energy without the same regulatory obstacles of lithium batteries As per 49 CFR 173.21(c) in the U.S. hazardous materials regulations. Like a battery bank, these devices need to be housed securely within an enclosure with a mechanistic high-voltage disconnect as described above where we covered batteries. But unlike the pure battery solution, it is acceptable to connect the Supercapacitors directly to the vehicle traction systems while in motion. Supercapacitors in general have less energy density than lithium batteries but would work very well when combined with fuel cell technology in a hybrid platform. Supercapacitors also weigh less in general which could keep the design and operating cost of the Nomadic charge™️ service network lower.

Lobby for changes to regulations

We are in a unique position to influence the regulations surrounding the categorization of Lithium Battery chemistries and how these regulations relate to electric vehicle charging. Not all batteries are created equal, it's like comparing apples to oranges. However in the current eyes of Federal Law, this is not the case. Batteries are treated as equally hazardous even though this is based on falsities and simply not the case. We seek to help regulators gain understanding, and re-structure laws to accommodate the abundance of safe non-hazardous lithium batteries available for energy transport. Wide spread electric vehicle adoption hinges on necessitated vast improvements to the current energy distribution model(s). Extending accessibly to charge infrastructure is integral in the rapid scaling of electric mobility in the United States. This has been voiced as a very real concern that we have heard from members of the Federal Committee on Energy and Natural Resources, including statements from our own Oregon Senator Ron Wyden(D). If state regulations are rapidly adapted to current battery technology, we may be able to service local areas with specific vehicles and avoid certain interstate transit regulations. If Federal regulations follow, we would have full access. The downside is that these regulatory changes take an undetermined amount of time to enact as well as diverting much needed funds and attention away from the research, development and deployment of new power systems.

Solutions time-line

These solutions shall be implemented in concert over a strategically estimated period of 3 years. Initially in year one a Supercapacitor Nomadic charge™️ service prototype will be rolled out to large city centers and surrounding metropolitan areas. This will be followed within year two by the development of a hybrid fuel cell / supercapacitor service vehicle platform that could reach much larger suburban and rural areas as well as improving coverage in established metropolitan markets. As we grow in year three we will devote more work energy and investment towards regulations change as well as battery technology improvement. At that time Supercapacitors could be upgraded to new safe solid-state battery systems with higher energy densities, and the dependence on the methanol fuel cells could be reduced or phased out in order to achieve a lower resistance path to reach our vision of a pure Zero Emissions future.

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