CHBC Submits Comments to CPUC for R.13.02-008 Renewable Gas Standards Proceeding
July 27, 2018 – The California Hydrogen Business Council (CHBC) submitted comments to the California Public Utilities Commission (CPUC) for the R.13-02-008 Renewable Gas Standards Proceeding. The CHBC’s comments provided six recommendations for the proceeding to be more inclusive of hydrogen. The six recommendations were:
- Recommendation 1: The CHBC requests that all of the renewable gases in the chart below be addressed in this proceeding, in order to ensure non-discriminatory access to the
common carrier gas system, per the original February 2013 Scoping Memo and Ruling for this proceeding. - Recommendation 2: CHBC urges the Commission to adopt the definition in the table above for “renewable methane” in this proceeding and, in any event, to include methane derived
from combining renewable hydrogen with CO2 from climate neutral sources within the scope of the proceeding. - Recommendation 3: Per D.14-01-034, the Commission ought to add to the issues to be determined by the end of this phase of the proceeding lower and upper action levels for
hydrogen as a constituent of gas injected onto the common carrier system, and this should be based on a comprehensive and current evidentiary record. - Recommendation 4: We request that the Commission recognize that not including hydrogen in this proceeding is not aligned with several state policies.
- Recommendation 5: We request that the Commission recognize the urgency of establishing injection standards, among other actions, to remove regulatory barriers for numerous
companies that are investing resources and creating plans to bring economical, climate neutral hydrogen and its derivatives to California consumers. - Recommendation 6: In addition to establishing injection protocols by the end of this phase of the proceeding, the CHBC requests that the Commission address a broader set of issues
relevant to advancing renewable hydrogen and renewable methane in a parallel Track 2 of this proceeding and in a concurrent series of technical workshops.