CHBC Submits Comments on 2018 IEPR Scoping Memo

On February 26, the California Hydrogen Business Council submitted comments to the California Energy Commission’s regarding the Draft Scoping Order for the 2018 IEPR Update. The CHBC’s comments outlined five specific recommendations for the CEC to consider, which were:

1. Assessment of the opportunity of sector couplingii to help decarbonize energy sectors and increase the ability of integrating higher amounts of renewable energy and reduce curtailment.
2. Discussion of the long-term perspective of natural gas accompanied by assessing the ability to displace natural gas and decarbonize the natural gas sector with electrolytic hydrogen and other zero and low carbon gas alternatives as replacement fuels. This will allow using existing assets like the natural gas system in a decarbonized energy future. This assessment should include pathways for zero carbon conversion of existing critical resources (e.g. essential peaker plants). In our view, a resilient California grid requires a combination of renewable electricity sources and gas produced with renewable energy sources to create a secure energy portfolio.
3. Assessment of the needs of seasonal storage needs that includes consideration of hydrogen as a zero carbon storage resource.
4. Consideration of hydrogen fuel cell technology options in the discussion of transportation energy/electrification, in terms of fuel and vehicles. We seek a greater discussion of hydrogen transportation, including projections for hydrogen fueling cost, FCEV purchase price, hydrogen fuel cell electric medium and heavy duty truck sales, and pathways to increase the volume of hydrogen –especially renewable hydrogen- production and distribution to meet demand. The CHBC especially recommends including in this consideration industry projections that infrastructure costs are lower for FCEVs than BEVs at high volume.
5. Inclusion of current cost data and of realistic use assumptions for electrolytic hydrogen in assessing the economic use case for this technology as a pathway to helping California reach its greenhouse gas emissions reduction targets. CHBC members provided data to the Commission and its consultant (E3) in 2017, which was not considered, and we welcome the opportunity to further educate the Commission with current and accurate information.

Read the complete comments here >>