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2022 Advocacy Activities

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U.S. Department of Energy

  • On February 14, CHBC submitted comments to the U.S. Department of Energy responding to questions related to the development of a Hydrogen Industry Roadmap as required by the Bipartisan Infrastructure Law. Read CHBC’s comments here >>

California Governor’s Office

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California Assembly and Senate

  • On August 4, CHBC submitted comments to the CEC on the Pre-Solicitation Workshop, Zero and Near-Zero-Carbon Fuel Production and Supply Funding Concepts. The CHBC expressed its encouragement by the possibility of continued funding for hydrogen fuel production projects and discussed the topics of “Which solicitation options presented for consideration are preferred and why?” and “Should the solicitation be technology neutral and why?”. Read CHBC’s comments here >>
  • On June 24, the CHBC submitted a letter of support for SB 733 (Hueso). CHBC commented that SB 733 promotes the commercialization of renewable hydrogen in the energy sector by directing the CPUC to consider renewable hydrogen procurement targets for gas corporations. To meet California’s 2040 emissions targets identified in SB 32 (Pavley, 2016)—a target California is projected to miss by 20 percent–the state must utilize existing resources and technology across the economy. Read the letter here >>
  • On May 11, the California Hydrogen Business Council is pleased to support SB 1291. SB 1291 will assist California and hydrogen station developers grow the hydrogen fueling network by adding hydrogen fueling stations to the existing expedited permit siting procedures that battery electric vehicle chargers (EV chargers) enjoy. This bill ensures that, like EV chargers, hydrogen fueling station application use permits cannot be denied unless there is a written finding that the proposed station would have a specific, adverse impact on the public health or safety. The result of adding hydrogen fueling stations to these procedures will accelerate the pace in which permits are processed and ensure the applications address the health and safety standards necessary to protect the public. Read the letter here >>
  • On April 13, the California Hydrogen Business Council submitted a letter of support for SB 1329 – Hydrogen Fueling Infrastructure (Newman). SB 1329 will provide an ongoing allocation of at least $30 million annually from the Clean Transportation Program over the next decade to build out a statewide, publicly available FCEV hydrogen fueling network. No less than 60% of the funding will be put towards installations that completely or partially benefit disadvantaged communities. This will be in alignment with the Air Resources Board’s 2021 peer-reviewed analysis showing that an investment of an additional $300 million will bring the state’s light- and medium-duty hydrogen fueling network to self-sufficiency. Read the letter here >>
  • In March 24, CHBC submitted a letter in opposition of AB 2562 (Bennett) unless amended. AB 2562 aims to bring parity among the zero-emission transportation technologies—battery electric vehicles (BEVs) and fuel cell electric vehicles (FCEVs)–and supporting infrastructure but fails to do so as written. The CHBC appreciates Assemblymember Bennett’s desire to include FCEVs and the supporting hydrogen fueling infrastructure equally in the administration of the Clean Transportation Program funds; however, directing the California Energy Commission (CEC) to prioritize funding stations at ports, stations that serve medium and heavy-duty trucks, and stations that are located along freight corridors reduces the amount of hydrogen fueling stations available to light-duty vehicles and leads to
    missed decarbonization and air quality targets. Read the letter here >>

California Public Utilities Commission

  • On January 14, CHBC provided Opening Comments on the Proposed Decision (PD) of ALJ Fitch adopting 2021 Preferred System Plan stating that while adopting a “renewable hydrogen” definition is a positive step, a “renewable hydrogen” definition that causes confusion and disagreement among the parties who are responsible for producing the fuel will lead to delayed adaptation and the real risk of not reaching our decarbonization targets. The CHBC stated that it will participate in the ongoing discussion of how to define “renewable hydrogen,” but we urge the CPUC to refrain from adopting a definition of “renewable hydrogen” for the purposes of this IRP procurement. Read CHBC’s Comments >>
  • On April 5, CHBC submitted comments on SoCalGas’s Angeles Link application to the CPUC. Read CHBC’s Comments here >>

California Energy Commission (CEC)

  • On June 12, the California Hydrogen Business Council submitted comments by responding to the Commissioner Workshop on the Role of Hydrogen in California’s Clean Energy Future. The CHBC expressed encouragement by the focused workshop on hydrogen’s role in California’s clean energy future and noted hydrogen is a solution that is being deployed today across the global economy. The CHBC’s comments addressed topics covered in the Workshop: 1. Forecasts of Hydrogen Opportunities in Economywide Decarbonization, 2. Current Use of Hydrogen & Near-term Opportunities to Expand Use for MDV/HDV/Off-Road/Marine Applications, and 3. Emerging Projects & Opportunities for Hydrogen in Economywide Decarbonization. Read the comments here >>
  • On May 13, the California Hydrogen Business Council (CHBC) provided comments to the CEC’s 21-TRAN-03 Draft Zero-Emission Vehicle Infrastructure Plan. The CHBC stated that it appreciated the opportunity to respond to the workshop and publication on the Draft Zero-Emission Vehicle Infrastructure Plan (“ZEV Plan”). However, the CHBC finds the ZEV Plan falls short of meeting California’s ZEV, decarbonization, and air quality goals due to the lack of investment in the hydrogen fueling network. Fuel cell electric vehicles (FCEVs) are crucial to California’s ZEV fleet and widespread adoption will not happen without sufficient hydrogen fueling infrastructure. Read the comments here >>
  • On January 31, the California Hydrogen Business Council (CHBC) submitted comments on the CEC Proposed Natural Gas and Research and Development Workshop (“Gas R&D Workshop”), discussing the proposed energy-related gas research initiatives for fiscal year 2022-2023. CHBC asked the CEC to capitalize on existing resources like research previously done by other countries transitioning their gas grids to hydrogen. The CEC should plan an immediate response to the climate crisis by incorporating existing gas grid infrastructure into the decarbonization plan, and the CEC should offer more detailed questions to gather more informed responses on a topic as critical as gas grid research and development. Read CHBC’s Comments here >>
  • On January 28, the CHBC submitted comments on the Draft 2021 Integrated Energy Policy Report (Draft IEPR), Volume III: Decarbonizing the State’s Gas System. CHBC stated that hydrogen’s inclusion in the Draft IEPR is encouraging because hydrogen will be critical to decarbonizing California’s gas grid, as it will serve as a replacement for the state’s existing use of fossil fuels to power the gas grid. However, in the Draft IEPR, hydrogen is limited in its definition and application to help the state achieve a decarbonized gas grid. Therefore, the CHBC proposed a number of amendments be made to the Draft IEPR, including using Carbon Intensity rather than labels of colors for hydrogen production, inclusion of federal targets and funding, recognition of lack of funding for FCEV infrastructure, and long duration storage capabilities of hydrogen. Read the comments here >>

California Air Resources Board (CARB)

  • California Air Resources Board (CARB) LCFS Update Program Submission: Filed Dec. 21
    On December 21, the CHBC submitted a joint letter–with CHC and various member companies—to CARB on the Low Carbon Fuel Standard (LCFS) Program updates. The comments noted support for the CATS model presented in the CARB staff proposal but requested an open-source approach to modeling that allows for a fuller review of the model as compared to modeling only three scenarios. The comments also recommended CARB staff reconsider restricting biomethane crediting to only California, as it would slow the thriving biomethane industry in which the LCFS has garnered success. Finally, the comments emphasized support for an extension of 2.5% light-duty credits and 2.5% heavy-duty infrastructure credits, as it would ramp up deployment of fuel cell electric vehicles across weight classes.
  • On June 24, the CHBC along with members, other hydrogen industry representatives and unions, thanked the California Air Resources Board (CARB) for the time and effort taken to develop the Draft 2022 Scoping Plan (Scoping Plan or Proposed Scenario). The stated that this Scoping Plan is the first to look toward a carbon-neutral future and examines the various technological pathways needed to achieve this monumental goal by 2045 and that the utilization of a wide variety of hydrogen production pathways and end uses, as described in the Proposed Scenario, will help to maximize emissions reductions, cost-effectiveness, and lead to a carbon-neutral future that is resilient, reliable, and self-sustaining. To achieve California’s goals, we must revolutionize our energy systems while improving the lives and livelihoods of all Californians. Transitioning to an energy system and economy supported by hydrogen will enhance the future of California while achieving climate and air quality goals. Read the comment letter here >>
  • On January 12, the CHBC commented on the California Air Resources Board (CARB) “Potential Future Changes to the LCFS Program” workshop (“Workshop”) that was held December 7, 2021. The CHBC applauds the efforts of CARB in the administration of the Low Carbon Fuel Standard (LCFS) program. CHBC stated that the LCFS program has been incredibly successful in decreasing the greenhouse gas emissions (GHG) of California’s transportation fuels by awarding credits to low-carbon fuels such as hydrogen. The  CFS credits awarded on a carbon intensity score basis sent market signals to hydrogen producers and hydrogen fueling station developers to kickstart the deployment of the hydrogen refueling system that now supports the growing number of California’s fuel cell electric vehicle (FCEV) drivers. With California’s swift transition to zero-emission vehicles within the next decade, it is imperative the LCFS program continues to support the use and production of low-carbon fuels such as hydrogen. Read the comments here >>

South Coast Air Quality Management District (SCAQMD)

  • On July 5, the CHBC submitted comments to the Draft 2022 Air Quality Management Plan. Summarily, the comments address how fuel cell systems and fuel cell electric vehicles (FCEVs) should be the preferred resources for electric generation and air pollutant reduction in the stationary and mobile source categories. Read the comments here >>