HomePolicy Issues2024 Advocacy Activities

2024 Advocacy Activities

Contents

U.S. Department of Treasury

  • On August 2, the CHBC filed comments to the U.S. Department of the Treasury on the draft Section 48E Clean Electricity Investment Credit guidance.  Our comments include the following points of advocacy:
    1) The proposed classification of fuel cells as combustion and gasification facilities is technically incorrect and this categorization should be changed. Fuel cells neither employ combustion, nor do they employ gasification.
    2) As proposed, this rulemaking goes far beyond legislative intent and does not meet the intent of the Biden-Harris administration’s goal to develop a 100% clean electricity grid using hydrogen and fuel cells, nor the Hydrogen Hubs program. The proposed guidance for 48E does not reflect a reasonable interpretation of the underlying statute.
    3) The rulemaking should use the emissions profile of the facility to assess if it meets the required carbon intensity standard, rather than applying a subjective emissions profile to the hydrogen that is used to operate the facility.
    4) The final regulation should also clarify that the assessment of greenhouse gas emissions from fuel cell systems should be equivalent to the assessment of other non-combustion and gasification facilities.  Read CHBC’s comments here >>
  • The CHBC filed comments to the U.S. Department of the Treasury on the draft Section 45V Credit for Production of Clean Hydrogen. Additional comments were submitted by the Western Governors, ARCHES, the State of California, a joint letter from the seven Hydrogen Hubs, and many others who, like CHBC, are voicing the concern and opposition to the proposed rulemaking highlighting how, if adopted, the three pillars are counter to meeting California and the U.S. decarbonization goals.  Read CHBC’s comments here >>

California Air Resources Board

  • The CHBC has submitted joint comments to the California Air Resources Board on the hydrogen sections of the second 15-day changes to the Low Carbon Fuel Standard. Comments focus on maintenance of a reasonable carbon intensity standard decline, and adequate support and investment signals for hydrogen refueling infrastructure.  Read CHBC’s comments here >>
  • On August 27, the CHBC submitted comments with other industry groups to the California Air Resources Board (CARB) on the proposed 15-day updates to the Low Carbon Fuel Standard (LCFS). The comments consider that the proposed 15-day changes deviate from the prior proposal that needed only minor adjustments to achieve the goals of the LCFS and support implementation of other CARB policies. Comments stress the need for a technology-neutral performance standard, rather than the newly proposed imposition of a more stringent and separate renewable content standard for hydrogen compared to other zero-emission fuels. This approach diminishes the benefits of diverse hydrogen production pathways and is inconsistent with the broad range of technologies endorsed by the U.S. National Clean Hydrogen Strategy and Roadmap, which are necessary to meet hydrogen production targets and job creation goals through 2050. An additional 15-day comment period is requested in the comments.  Read CHBC’s comments here >>
  • CHBC, CHC, and GHC submitted a joint letter to CARB for consideration as they deliberate the proposed updates to the Low Carbon Fuel Standard (LCFS).  Read the comments here >>

California Assembly and Senate

  • CHBC submitted a letter of support for SB 1418 (Archuleta) for local governments to expand their existing expedited and transparent permitting process for zero emission vehicle infrastructure to include hydrogen fueling infrastructure.  Read the full letter here >>
  • The CHBC, with the California Hydrogen Coalition, signed onto a coalition letter in support of AB 2514 (Aguiar-Curry) which will accelerate progress in reducing methane emissions and meet the requirements of SB 1383 (Lara, 2016), the State’s Short-Lived Climate Super Pollutant legislation.  Read the full letter here >>

California Energy Commission

  • The CHBC filed comments to remind the CEC that fuel cells that run on hydrogen are still eligible for California’s Renewable Portfolio Standard. The CEC had released initial guidelines for notice and comment that interpreted incorrectly that last year’s AB 1921 (Papan), a bill whose intent was to put linear generators on the same level in the code as fuel cells, had the effect of eliminating fuel cells running on hydrogen from RPS eligibility.  Read the comments here >>
  • The CHBC has submitted comments on the revised staff draft of the Clean Transportation Program Investment Plan to the California Energy Commission.  The comments ask for 1) equitable allocation of available funding to medium- and heavy-duty hydrogen refueling infrastructure, commensurate with market demand, and 2) reinvestment of previously allocated funds from the canceled Shell agreement into the hydrogen infrastructure funding category.  Read the comments here >>
  • The CHBC has submitted comments to the California Energy Commission on the 2024-2025 draft Clean Transportation Program Investment Plan regarding the proper grouping of refueling capabilities at stations, the reallocation of cancelled, unexpired funds, and the needed market signals for adequate infrastructure planning in the coming years.  Download the comments here >>

California Public Utilities Commission

  • CHBC submitted comments on the Order Instituting Rulemaking for the Long Term Gas Planning proceeding at the CPUC on December 16 (R.24-09-012).  Our comments highlighted:
    1) The purpose of the Rulemaking is decarbonization broadly, which is not limited to electrification.
    2) The Rulemaking should recognize that not all decarbonization strategies are equally beneficial and should prioritize transition strategies that advance the most cost-effective decarbonization measures.
    3) The Rulemaking should consider the role of decarbonized gas in ensuring energy reliability across sectors, including for hard-to-electrify end uses and dispatchable electricity, as well as the value of resource diversity to avoid price spikes and market disruptions.

    CHBC looks forward to participating in this proceeding as it goes forward.  Read the full comments here >>

  • On July 30, the CHBC has submitted a response to the California Public Utilities Commission on the Joint Motion to Dismiss the Joint Amended Application of Southern California Gas Company, San Diego Gas & Electric Company, Pacific Gas and Electric Company, and Southwest Gas Corporation to Establish Hydrogen Blending Demonstration Projects (A.22-09-006).  The response opposes the Motion and supports the Joint Utilities’ Application to demonstrate live hydrogen blending projects and establish a safe threshold for blending hydrogen, progressing the clean energy transition in the state of California toward deeper decarbonization.  Read the full comments here >>
  • The CHBC filed comments to the CPUC on the Order Instituting Rulemaking to Establish Energization Timelines (R.24-01-018). The comments requested CPUC to expand the scope of the Rulemaking to include hydrogen refueling stations.  Read the full comments here >>
  • The CHBC filed response comments to A.22-09-006 in support of the Utilities Joint Amended Application to Establish Hydrogen Blending Demonstration Projects.  Read the comments here >>
  • The CHBC signed onto opening comments, with Pilot Travel Centers and Clean Energy, to the CPUC on the Assigned Commissioner’s Scoping Memo and Ruling in the proceedings to Establish Energization Timelines.  Read the comments here >>
  • The CHBC signed onto a letter, along with the California Hydrogen coalition (CHC) and the Green Hydrogen Coalition (GHC), to the California Air Resources Board (CARB) regarding updates to the Low Carbon Fuel Standard (LCFS).  This letter was in response to the workshop held on April 10th.
    Read the comments here >>
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