2023 Advocacy Activities

Contents

• • U.S. Department of Energy
  • U.S. Department of Treasury
  • California Assembly and Senate
  • California Energy Commission
  • California Public Utilities Commission (CPUC)
  • City of Irvine
  • South Coast Air Quality Management District
  • State of California

U.S. Department of Energy

• The CHBC has offered a general letter of support for the California ARCHES hydrogen hub proposal that will be submitted to the U.S. Department of Energy on April 7.  Read the letter here >>

U.S. Department of Treasury

• CHBC signed onto a letter, in conjunction with over 50 companies and organizations, to the Department of the Treasury requesting that they not include additionality requirements in the guidance for the Section 45V Credit for the Production of Clean Hydrogen. Doing so would stifle the clean hydrogen market with unreasonable costs and delays, undermining the industry’s ability to scale up and decarbonize. Please see the link for the full letter.  Read the letter here >>
• CHBC submitted comments to the IRS in support of ARCHES on the Hydrogen Production Tax Credit as it relates to the ‘3 Pillars’.  Read the comments here >>

California Assembly and Senate

• CHBC supported including hydrogen in the 2023 IEPR and asks to include fuel cells and linear generators in system upgrades.  Please see the expanded summary and letter for details >>

California Energy Commission

• Joint comments from CHBC, GHC, and CHC were submitted to the CA Energy Commission’s Draft 2023 Integrated Energy Policy Report.  See comments here >>
• Comments to both the CEC’s Integrated Energy Policy Report (IEPR) and to CARB’s SB 1075 Kickoff Workshop were submitted.  See comments here >>
• 22-RENEW-01 “Demand Side Grid Support and Distributed Electricity Backup Assets Program”
  CHBC submitted comments to the California Energy Commission docket 22-RENEW-01 requesting that hydrogen be included as a behind-the-meter long-term storage option in Incentive Option 3 of the DSGS Program Guidelines, consistent with the legislative intent that has consistently been expressed in California.  The CHBC wrote in support of the following in response to the Demand Side Grid Support Program (DSGS) prompts: allowing eligible Load Reduction (LR) resources like fuel cells and linear generators to enroll directly with the CEC; providing DSGS for fuel cells and linear generators used in microgrids; and, adding telecommunications companies and critical facilities to the DSGS program. In response to the Distributed Electricity Backup Assets Program (DEBA) prompts the CHBC recommended the following: investments should focus on upgrading existing clean energy assets that are able to be paired with LR resources and new DEBA eligible assets should be allowed to also receive DSGS upon deployment.  Please see letter for details >>
• CHBC submitted comments to the California Energy Commission docket 22-EERD-03 on the Large-Scale Centralized Hydrogen Solicitation Concept as a part of the Clean Hydrogen Program. The main point was around the proposed technical limitation to electrolytic hydrogen. CHBC requested that thermochemical biomass conversion systems also be allowed. See the letter for more on that and other comments.  Read the letter here >>

California Public Utilities Commission

• CHBC submitted comments to the CA Public Utilities Commission regarding Draft Resolution G-3601 regarding the denial of the allocation of SoCalGas RD&D funds to certain categories of research based on the assertion that the showing on ratepayer benefits of these funding categories was insufficient.  Read the comments here >>
• CHBC submitted comments to CPUC to consider and include hydrogen as a part of their draft staff proposal for Zero-Emission Freight Infrastructure Planning (FIP).  Read comments here >>
• CPUC R.20-01-007 Staff Gas Infrastructure Decommissioning Proposal
  The CHBC responded to the CPUC’s gas decommissioning proposal by advocating for continued use of the existing natural gas pipeline to decarbonize our energy systems quicker by blending hydrogen. The CHBC highlighted the significant grid reliability risks through 2030 as our economy electrifies and our weather becomes more extreme. The CHBC noted the most energy-intensive, hard-to-electrify sectors should be lowest priority in the transition away from gas use. The CHBC recommended the CPUC coordinate with the CEC and the ARCHES network on the transition away from gas use.
• This letter is CHBC’s support of AB 678 (Alvarez) to expand the CPUC’s Renewable Gas Standard (RGS) to apply to all Core Transport Agents (CTAs).  This extends the RGA to all entities- including non-utility gas suppliers- procuring natural gas for California’s residential and small business customers. SB 678 improves existing law and promotes fairness and equity for customers in the decarbonization of the gas system.  Read the letter here >>

City of Irvine

• CHBC submitted a letter to the City of Irvine to support a hydrogen blending project that was being opposed by one of the Irvine City Council members. The topic was an agenda item on the April 25th City Council meeting, however was moved to a future meeting, where they expect presentations from both City Staff and UC Irvine, who is a lead in that project. Read the letter here >>

South Coast Air Quality Management District

• CHBC submitted comments to the South Coast AQMD Proposed Rule 1110.3 in support of permit streamlining for innovative technologies, including linear generators, in replacing diesel generators.  Read the comments here >>

State of California

• CHBC signed on to a coalition letter to Governor Newsom concerning the Low Carbon Fuel Standard. This was in response to a letter requesting arbitrary caps on fuels and represents 12 other associations, totaling 89 stakeholders, including CHBC. Such a response will emphasize our collective ongoing work toward achieving emission reduction goals. Read the letter here >>
• 21-ESR-01 “Draft Clean Energy Reliability Investment Plan Report”
  The CHBC submitted comments in support of the proposed areas of funding for strengthening the state’s Demand Response (DR) and Distributed Energy Resources (DER). The CHBC emphasized the need to scale microgrid-sized electrolyzers that can be paired with existing demand side resources and adding fuel cell electric vehicles (FCEV) to the bi-directional demand side resources. Further, the CHBC encouraged investment in fuel cells and linear generators, especially when co-located where load growth occurs, to assist in line losses, transformer losses, and other conversion/inversion losses. The CHBC identified the benefits of these technologies, including direct current charging and storage capabilities.