2025 Advocacy Activities
Contents
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- California Air Resources Board
- California Assembly and Senate
- California Energy Commission
- California Public Utilities Commission
- U.S. Congress
California Air Resources Board
- On April 21, CHBC commented on the latest 15-day package of modifications to the Low Carbon Fuel Standard. The modifications included including eligibility for hydrogen combined with CCS and an elimination of a cap on credits for Hydrogen Refueling Infrastructure. CHBC applauds both of these changes. CHBC also opposed having a derating factor for LD, MD and HD HRI investments and a requirement that HD-HRI stations be within five miles of an FHA Alternative Fuel Corridor. These requirements remain in the proposed regulation. – Read CHBC’s comments here >>
- CHBC submitted comments on March 25 on the technical analysis presented at the February 25 SB 1075 Workshop at CARB by the consultancy E3. CHBC highlighted the positives in the presentation, including its broad range of pathways for hydrogen production and evaluation of blending and dedicated hydrogen pipelines as solutions. CHBC also pointed out areas the presentation needs more analysis, including in its assumptions for water, land, infrastructure and permitting changes needed to meet goals for renewable electrolytic hydrogen production. – Read CHBC’s comments here >>
California Assembly and Senate
- CHBC led a coalition including environmental groups Coalition for Clean Air and Union of Concerned Scientists to call for $500 million to replenish the Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP) through settlement funding, return of unused vouchers, and new expenditures from the Greenhouse Gas Reduction Fund. This is CHBC’s top budget ask for 2025. – Read the coalition letter here >>
- CHBC joined a broad coalition to call for the legislature to allocate at least $200 million annually to CalRecycle for circular economy projects that convert organic landfill waste to beneficial products like bioenergy, hydrogen, biochar and compost. – Read the coalition letter here >>
- CHBC joined a broad coalition of organizations on May 16 opposed to SB 348 (Hurtado), which would significantly amend the state’s Low Carbon Fuel Standard. CHBC agrees the legislature should not change this rule which took over three years to develop in its latest form. – Read the opposition letter here >>
- CHBC submitted a letter of support on May 5 for SB 419 (Caballero) to the Senate Revenue and Taxation Committee. This bill exempts hydrogen fuel from the sales and use tax in California. – Read the support letter here >>
- CHBC signed onto a coalition letter amended on April 22, in opposition to SB 682. This bill is a broad and vaguely-written attempt to give the Department of Toxic Substances Control further power to regulate many applications of PFAS. The bill was heard in Senate Health Committee on April 30, 2025. – Read the coalition’s opposition letter here >>
- CHBC submitted comments on April 23 on SB 57. The bill would authorize the CPUC to set zero-carbon targets for any distributed generation project over 50 MW – CHBC is opposed as this is inconsistent with our position on low-carbon solutions and out of step with SB 100. – Read CHBC’s comments on SB 57 here >>
- CHBC submitted comments on April 14 on SB 71. CHBC supports this permanent CEQA exemption for transit projects, which would include hydrogen refueling infrastructure. – Read CHBC’s comments on SB 71 here >>
- On April 7, a letter was submitted in opposition to SB 682. SB 682 would make broad, sweeping and complex new regulatory program at the Department of Toxic Substances Control (DTSC) to regulate all commercial and consumer products that may contain, as well as any industrial manufacturing processes that may use perfluoroalkyl and polyfluoroalkyl (PFAS) substances. CHBC joined dozens of business groups in opposing this bill. – Read the letter here >>
- CHBC submitted comments on SB 2 on March 11 and SB 348 on March 27. CHBC joins large coalitions which oppose these attempts to revise the Low Carbon Fuel Standard, a CARB regulation that passed with significant business support last November.
– Read CHBC’s comments on SB 2 here >>
– Read CHBC’s comments on SB 348 here >> - CHBC submitted comments on March 28 on AB 35. CHBC supports this effort to exempt from CEQA the transportation of hydrogen, but asks that the exemption apply to all low-carbon intensity forms of hydrogen. – Read CHBC’s comments on AB 35 here >>
California Energy Commission
- February 28, 2025 CHBC recently commented on the Joint Workshop on Concepts for the CFI West Coast Truck Charging and Fueling Corridor Project. We encourage the CEC to plan for significantly more stations, and larger ones, than the plan the CEC shared in the workshop. Increased capacity can provide the infrastructure needed to support hydrogen fuel cell and H2ICE trucks. – Read CHBC’s comments here >>
- The CHBC submitted comments to the California Energy Commission (CEC) on February 7, 2025 on the Draft Zero-Emission Vehicle Infrastructure Plan. The CHBC requested alignment with the CEC Clean Transportation Program Investment Plan and to include eligibility of hydrogen infrastructure in the medium- and heavy-duty category. The CHBC also advocated for the $15 million allocation to the hydrogen category to be considered a floor, not a ceiling, and allocate funds commensurate with market demand, and to align light- and medium-duty infrastructure plans as a shared category, consistent with CARB plans. – Read CHBC’s comments here >>
California Public Utilities Commission
- On March 14, CHBC filed comments to respond to the interim actions questions posed by Commissioner Douglas in the Long-Term Gas Proceeding. Our comments:
1. Direct the Commission to not eliminate gaseous solutions as a decarbonization strategy;
2. Call on the Commission to act on the Joint IOUs’ application for hydrogen pipeline blending projects; and
3: Urge the Commission to approve SoCalGas’ Phase II Angeles Link application expeditiously.
Read CHBC’s comments here >> - On January 23, CHBC submitted a response in support the SoCalGas Phase 2 application for their Angeles Link dedicated hydrogen pipeline project. – Read CHBC’s comments here >>
U.S. Congress
- On June 5, 2025, CHBC and a coalition of nearly 250 signatories, led by the Fuel Cell and Hydrogen Energy Association, sent a letter to U.S. Senate leadership outlining the economic and strategic importance of preserving the §45V Hydrogen Production Tax Credit. The letter presents a unified request for the tax credit to remain in place with a commence construction date set no earlier than December 31, 2029. This change would provide a necessary four-year minimum runway for the industry to advance projects already in development, representing tens of billions of dollars of private sector investments. This would ensure that the United States retains tens of thousands of jobs and large-scale hydrogen manufacturing facilities, develops hydrogen and clean fuel projects for ammonia and methanol exports, and secures America’s global hydrogen leadership for years to come. Read the Full Letter >>
- On May 13, 2025, CHBC and a coalition of more than 100 companies, associations, and stakeholders led by the Fuel Cell and Hydrogen Energy Association submitted a Rapid Response letter yesterday urging House leadership and Congress to protect the Section 45V hydrogen production tax credit. The letter was issued in response to a proposed elimination of §45V in the House reconciliation markup bill. §45V is critical to advancing clean hydrogen, securing domestic energy leadership, and maintaining U.S. competitiveness against aggressive investments in Europe and China. Read the Full Letter >>
- On February 18, 2025, CHBC joined the Fuel Cell & Hydrogen Energy Association and over 110 associations, business groups, Hydrogen Hubs, and corporate entities in signing a letter to Congressional leadership advocating for the §45V Production Tax Credit (PTC). This collective effort underscores the industry’s unified stance: robust and stable federal incentives are critical for the success of the U.S. hydrogen sector. Read the Full Letter >>