Comments on the CPUC OIR for the Self-Generation Incentive Program and Related Issues

On June 29, the CHBC submitted comments to the CPUC regarding the Order Instituting Rulemaking Regarding Policies, Procedures and Rules for the Self-Generation Incentive Program and Related Issues. The CHBC comments outlined four areas for CPUC to consider in the OIR:
  1. Appreciation that the SGIP OIR includes consideration of program revisions to incorporate increased use of green electrolytic hydrogen fuel cells, in order to implement SB 1369.
  2. To be fully useful, this development needs to be accompanied by establishing regulatory frameworks at the PUC that encourage green electrolytic hydrogen production.
  3. The rulemaking should be expanded to also include fuel cells that use renewable hydrogen made from organic waste pathways.
  4. This rulemaking should be considered a beginning, not an endpoint to implementing SB 1369 because a broader and more long term regulatory framework is needed to realize the potential benefits of green electrolytic hydrogen, like long duration storage, power generation outside the scope of this rulemaking (e.g. thermal power plants, microgrids), and zero emissions transportation fuel.