HomePolicy Issues2020 Advocacy Activities

2020 Advocacy Activities

Contents

California Governor’s Office

  • The California Hydrogen Business Council (CHBC) believes Governor Gavin Newsom’s Executive Order N-79-20 underscores the importance of hydrogen electric fuel cells to the future of mobility in California. The Executive Order is California’s latest action to combat climate change by requiring new car and drayage truck sales be zero emission beginning in 2035. The Governor announced his order in the wake of a devastating wildfire season that has thus far consumed 3.6 million acres. Read the full statement here >>
  • On September 1, the CHBC sent a letter to Governor Gavin Newsom, requesting his signage of AB 3163, which would expand the definition of biomethane to include the non-combustion thermal conversion of eligible biomass. AB 3163 will support an important new pathway to creating renewable hydrogen, which is the only gas that emits zero greenhouse gas over its lifecycle and a key enabler of California’s climate goals. Read the letter here >>
  • On February 19, the CHBC sent a letter to Governor Gavin Newsom regarding the proposed 2020-2021 budget. The CHBC expressed appreciation for the Governor’s continued support climate, energy and air quality issues, as well as support for the Climate Catalyst Fund. Read the letter here >>

California Assembly and Senate

  • On June 12, the CHBC sent a letter of support to Senate Committee on Energy, Utilities, and Communications Chair, Senator Ben Hueso, for AB 3163, which would expand the definition of biogas to include the non-combustion thermal conversion of eligible biomass. This legislation will support an important pathway to creating renewable hydrogen, which is the only gas that emits zero greenhouse gas over its lifecycle and a key enabler of California’s climate goals. Read the letter here >>
  • On May 29, the CHBC sent a letter to Assemblymember Richard Bloom and Budget Subcommittee 3 in response to the Governor’s Proposed Budget and the Revisions proposed by the Administration on May 14, 2020. The CHBC urged the Assembly to consider postponing any decision on 2020-2021 Greenhouse Gas Reduction Funds (GGRF) until after the next auction results are known in August and to take immediate action to modify the proposals in the Governor’s budget to ensure public health is maximized in the current compounded crisis of COVID-19 and the increased catastrophic wildfire threat. Read the letter here >>
  • On May 20, the CHBC sent a letter of support for AB 3163 to Assembly Member Lorena Gonzalez Fletcher, Chair of the Assembly Appropriations Committee. The bill would expand the definition of biogas to include the non-combustion thermal conversion of eligible biomass, supporting an important new pathway to creating renewable hydrogen. Read the letter here >>
  • On May 11, the CHBC sent a letter of support for SB 1352 to Senator Ben Hueso, recognizing that the bill will not advance in the 2020 legislative session due to the COVID-19 pandemic. SB 1352 would establish a renewable gas standard (RGS) by 2030 and help drive the market development for renewable gas, including hydrogen. Read the letter of support here >>
  • On March 24, the CHBC sent a letter of support for SB 1122 to Senator Nancy Skinner. The proposed legislation would provide clarification that green electrolytic hydrogen ought to be eligible as a zero carbon-emitting supply-side resource in any plans developed to help California develop a cost effective, reliable and balanced power portfolio. Read the letter here >>

California Public Utilities Commission (CPUC)

  • On November 17, the CHBC submitted reply comments to the CPUC on the Order Instituting Rulemaking to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and Perform Long-Term Gas System Planning. The CHBC agreed with several parties who called for greater inclusion of green hydrogen and methanated green hydrogen in gas system planning. By supporting green hydrogen in this proceeding, the CPUC will send market signals that ensure solutions are ready and available, as required in the energy system. Read the comments here >>
  • On November 2, the CHBC submitted comments to the CPUC on R.20-01-007 Track 1A: Reliability Standards and Track 1B: Market Structure and Regulations, Workshop Report and Recommendations. The CHBC expressed its appreciation that the Workshop Report including a summary of comments in support of hydrogen by Dr. Jeff Reed on behalf of the CHBC at the Track 1B workshop, along with CHBC’s oral comments. Additionally, CHBC was concerned and disappointed that the report’s recommendations completely neglect to include actions to examine or advance the incorporation of hydrogen into future state gas and electricity system planning. Read the comments here >>
  • On October 16, the CHBC submitted reply comments to the California Public Utilities Commission on the ALJ’s Ruling Setting Prehearing Conference and Directing Comments on Energy Division Phase II Staff Proposal. Read comments here >>
  • On October 2, the CHBC submitted comments to the CPUC’s ruling seeking comment regarding Policy Questions and an Interim Approach for Minimizing Emissions from Generation During Transmission Outages. Read the comments here >>
  • On August 28, the CHBC submitted reply comments to the CPUC on the “Track 2 Microgrid and Resiliency Strategies Staff Proposal, Facilitating the Commercialization of  Microgrids Pursuant to Senate Bill 1339.” The CHBC appreciated the Commission’s recognition that hydrogen is one of the fuels to be considered in microgrid planning and that fuel cells are to be considered as a generation resource. Read the reply comments here >>
  • On August 21, the CHBC submitted reply comments to the CPUC for the Administrative Law Judge’s Ruling Requesting Comments on Wireline Provider Resiliency Strategies. Read the comments here >>
  • On August 14, the CHBC submitted its opening comments to the CPUC on the proposal titled “Facilitating the Commercialization of Microgrids Pursuant to Senate Bill 1339.” The CHBC expressed its appreciation that the Commission recognized that hydrogen is one of the fuels to be considered in microgrid planning and that fuel cells are to be considered as a generation resource. The CHBC also recommended the Commission select Proposal 3 Option 2 for a simple standardized tariff for customer-owned, behind-the-meter microgrids. Read the comments here >>
  • On July 7, the CHBC submitted reply comments to the California Public Utilities Commission on the Order Instituting Rulemaking Regarding Policies, Procedures, and Rules for the Self-Generation Incentive Program and Related Issues. The CHBC comments called attention to and agreed with the interest expressed by a number of parties in green hydrogen being included in the SGIP program as a clean and resilient generation resource capable of providing reliable power. Read the comments here >>
  • On July 1, the CHBC submitted comments to the CPUC on the Proposed Decision Adopting Wireless Provider Resiliency Strategies. The CHBC expressed disappointment that the decision continues to allow use of polluting diesel generators while doing nothing to encourage use of zero emissions hydrogen fuel cell backup generators to ensure that critical services, including telecommunication, remain resilient and reliable 24/7/365 without emitting criteria air pollutants or air toxics. Read the comments here >>
  • On June 30, the CHBC submitted comments to the CPUC regarding the OIR to Continue Electric Integrated Resource Planning and Related Procurement Processes. Read the comments here >>
  • On June 29, the CHBC submitted comments to the CPUC regarding the Order Instituting Rulemaking Regarding Policies, Procedures and Rules for the Self-Generation Incentive Program and Related Issues. Read the comments here >>
  • On June 15, the CHBC submitted comments to the CPUC regarding the OIR to Continue Electric Integrated Resource Planning & Related Procurement. The CHBC’s main points were: (1) including green electrolytic hydrogen in IRP modeling is in line with state law; (2) green electrolytic hydrogen is the most scalable, geographically flexible long duration storage option and more cost effective than lithium ion batteries at longer durations; (3) additional variable renewable generation, which will be needed to achieve state policy targets and which is part of the PUC’s proposed integrated resource planning, risks not being financeable without electrolytic hydrogen as a storage resource, and; (4) by including hydrogen as a storage and electricity generation in IRP modeling, the PUC would be responding to rising interest not only internationally, but also in the US and California, by investing in renewable hydrogen solutions to decarbonize the electricity sector while maintaining system reliability. Read the comments here >>
  • On May 26, the CHBC submitted comments to the CPUC regarding the proposed decision adopting short-term actions to accelerate microgrid deployment and related resiliency solutions. The CHBC supported the comments of several parties calling for the Track 1 microgrid proposed decision to be expanded to include fuel cells (and hydrogen-based fuel cells), to ensure more resilient, reliable, pollution-free energy service 24/7 in all weather conditions, which current proposed solutions cannot supply on their own. Read the comments here >>
  • On April 27 the CHBC submitted comments to the CPUC Energy Division on the draft transportation electrification framework (TEF). Read the comments here >>
  •  On April 17, the CHBC submitted reply comments to the CPUC for the R.18-03-011 proceeding proposal, which addressed Communications Service Provider Resiliency and Disaster Response Requirements. The CHBC comments highlighted hydrogen fuel cell backup generation as a means to ensure that critical services, including telecommunication, remain resilient and reliable 24/7/365 without emitting criteria air pollutants. Read the comments here >>
  • On March 17, the CHBC submitted its reply comments to the CPUC regarding the R.16-02-007 proceeding on the Proposed Decision on the 2019-2020 Resource Portfolios. The CHBC expressed its agreement with comments made by CESA and EDF that support the Commission to include a wide range of long duration storage technologies in the resource portfolio by 2026. Read the comments here >>
  • On March 12, the CHBC submitted its opening comments to the CPUC regarding the R.16-02-007 proceeding on the Proposed Decision on the 2019-2020 Resource Portfolios. Read the comments here >>
  • On March 12, the CHBC submitted its reply comments to the CPUC on the R.20-01-007 proceeding, which will establish policies, processes, and rules for the gas system. Read the comments here >>
  • On March 9, the CHBC submitted comments to the CPUC regarding the proposed decision to establish building decarbonization pilot programs. Read the full comments here >>
  •  On February 26, the CHBC submitted comments to the CPUC regarding the “OIR to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and Perform Long-Term Gas System Planning.” The comments outlined the role of renewable gas to address short lived climate pollutants, the need for a rigorous, peer-reviewed analysis to optimize the use of hydrogen, and consideration of electric/gas grid interconnection. Read the full comments here >>
  • On February 6, the CHBC submitted reply comments to the CPUC regarding the R.19-09-009 proceeding on the Track 1 Microgrid and Resiliency Strategies Staff Proposal. Read the full comments here >>
  • On January 30, the CHBC submitted comments to the CPUC regarding the staff proposal titled, “Short-Term Actions to Accelerate the Deployment of Microgrids and Related Resiliency Solutions.” The CHBC comments addressed prioritizing interconnection applications to deliver resiliency services at key sites and locations. Read the full comments here >>
  • On January 27, the CHBC submitted comments to the CPUC on the R.13-02-008 Phase 4, which is addressing a variety of issues related to hydrogen. The CHBC continues to strongly support establishing hydrogen injection standards and protocols, a technical study to determine safe blending limits, and a preliminary injection standard within 12 months, which will help enable California to achieve its GHG reduction targets. However, the CHBC disagreed with the sentiment that “consideration of injecting hydrogen into the natural gas pipeline is a distraction to increasing the injection of renewable methane (biomethane).” Read the comments here >>
  • On January 10, the CHBC submitted comments to the CPUC regarding the R.13-02-008 proceeding, which will consider issues related to hydrogen. The CHBC’s opening comments covered an array of points for the CPUC to consider as it works to establish injection standards and protocols for California. Overall, the CHBC strongly supports the opening of Phase 4 of the proceeding due to its potential to expand renewable hydrogen production and distribution in the state. Read the CHBC comments here >>

California Energy Commission (CEC)

  • On September 15, the CHBC submitted comments to the California Energy Commission on the SB 100 Draft Results Workshop, which focused on draft modeling results and in the wake of Governor Newsom’s announcement to accelerate state climate goals, including the schedule for achieving California’s 100% zero carbon electricity target. Download the comments here >>
  • On September 9, the CHBC submitted comments to the California Energy Commission on the Commissioner Workshop on Clean Transportation Funding Programs – Clean Transportation Equity, Jobs, and Economic Recovery. Download the comments here >>
  • On August 20, the CHBC submitted comments to the California Energy Commission SB 100 Joint Agency Report Docket No. 19-SB-100, urging inclusion of a zero-carbon scenario and green electrolytic hydrogen as a long-duration storage and electricity generation resource. Green electrolytic hydrogen holds great promise to provide dispatchable, decarbonized firm power that can be stored in vast quantities until needed, such as during seasonal and peak demand periods. It also presents many economic opportunities for California, due to its high potential for a rapid downward cost trajectory and for creating and retaining good, green jobs in the state. Download the comments here >>
  • On July 30 the CHBC submitted comments to the California Energy Commission on the IEPR Update Workshops on Accessing the Future Role of Microgrids, which occurred on July 7 and 9. Download the comments here >>
  • On July 23, the CHBC submitted comments to the California Energy Commission on the recently held IEPR Update Workshops on Hydrogen Supply, Infrastructure, and Fuel Cell Electric Vehicle Market Status, urging the CEC to join ARB in calling for an extension of AB 8 funding of hydrogen fueling infrastructure, the only current policy mechanism that provides FCEV OEMs the forward-looking certainty they require to do their critical part in meeting the 5 million ZEV goal of Executive Order B-48-18. Download the comments here: https://lnkd.in/dd4hfwq
  • On July 2, CHBC executive director, Bill Zobel, provided comments during the California Energy Commission IEPR Commissioner Workshop on Hydrogen and Fuel Cell Electric Vehicle Market Status. The comments focused on the need for regulatory certainty to attract more private capital to make its way into this market and achieve the scale necessary to meet the challenge and leverage the full economic potential of hydrogen; the importance of extending AB 8 funds beyond the 2023 sunset date; and need policies that accelerate production of decarbonized hydrogen at scale to achieve cost-competitiveness. Read the comments here >>
  • On July 2, the CHBC submitted comments to the California Energy Commission on the June 11 and June 12 IEPR Update workshops focused on Transportation Trends and a Light-Duty Zero-Emission Vehicle Market Update. The CHBC comments focused on the opportunities and policy issues related to accelerating light duty hydrogen fuel cell electric vehicles, as well as scaling of hydrogen production. Read the comments here >>
  • On June 12, the CHBC submitted comments to the CEC on the May 29 Distributed Energy Resources Research Roadmap Workshop. The comments clarified the record on the commercial availability of zero emissions hydrogen fuel cells and urged the CEC to add hydrogen fuel cells to the technologies considered for research on microgrids and backup generation, which will ensure that resiliency does not compromise State clean air and climate goals. In addition, the CHBC supported the DER Research Roadmap inclusion of green electrolytic hydrogen among priorities identified for energy storage research. Download the comments here >>
  • On June 8, the CHBC submitted comments to the CEC regarding the Commissioner Workshop on Heavy-Duty Zero-Emission Vehicle Market Trends. The CHBC expressed disappointment due to the agenda for this workshop excluding any focus or panelist experts on hydrogen fuel cell electric vehicles (FCEVs), which has become a common pattern at the Commission and risks creating a misperception that ZEV is equivalent battery electric vehicles (BEVs). Additionally, the CHBC expressed appreciation to CEC staff and Commissioner Monahan for their comments and questions during the workshop that recognized hydrogen fuel cell electric technology as an important piece of the Heavy Duty ZEV market and their expression of support for including this solution in future 2020 IEPR update workshops. Download the comments here >>
  • On April 24, the CHBC submitted comments to the CEC on the EPIC Program Policy and Innovation Coordination Group (PICG) Partnership Area Framework results workshop. Read the comments here >>
  • On April 24, the CHBC submitted comments to the CEC on Docket #19-TRAN-02 Zero-Emission Transit Fleet Infrastructure Deployment and focused on the need for the CEC to help balance zero emissions transportation funding to support hydrogen fuel cell electric transit fleet technology deployment. There are currently no funding mechanisms in other California agency programs to insure the Innovative Clean Transit Regulation’s (ICT) success. Download the comments here >>
  •  On March 30, the CHBC submitted comments to the CEC on the draft staff report on the 2020-2023 Investment Plan Update for the Clean Transportation Program. Download the comments here >>
  • On March 20, the CHBC submitted comments to the CEC on the staff Workshop on Research and Development Opportunities for Floating Offshore Wind. The comments supported the recommendation to facilitate advanced hydrogen and other technologies to integrate offshore wind into the grid. Additionally, the CHBC recommended including studies and projects related to coupling offshore wind and hydrogen technologies in the research database. Download the comments here >>
  • On March 9, the CHBC submitted comments to the CEC regarding the SB 100 Joint Agency Report.The CHBC agreed with the direction of commenters thus far to ensure implementation of SB 100 is not prescriptive, maximizes optionality, and is technology inclusive. Download the comments here >>
  • On January 31, the CHBC submitted comments to the CEC regarding the draft scoping order for the 2020 IEPR. Download the full comments here >>
  •  On January 21, the CHBC submitted comments to the California Energy Commission on the proposed draft of the 2020 Load Management Rulemaking Scoping Memo (Scoping Memo). The CHBC expressed its general support to deploy an array of load management technologies to enable achievement of the state’s renewable and carbon neutral energy goals. Download the comments here >>

California Air Resources Board (CARB)

  • On November 16, the CHBC sent a letter to CARB Chair Mary Nichols, expressing its appreciation for CARB taking the lead on examining how to achieve carbon neutrality economy wide by 2045, as called for in Executive Order B-55-18. The CHBC also welcomed CARB to generally include hydrogen in E3’s analysis for heavy duty vehicles, rail, electricity generation, industry, and agriculture. Read the letter here >>
  • On September 9, the CHBC Submitted comments to the California Air Resources Board on the Public Workshop to Discuss Achieving Carbon Neutrality in California: A Report by E3, which initiated a dialogue on significant issues and questions related to how California should implement the state’s goal to achieve carbon neutrality economy-wide by 2045. The Draft Report included key roles for hydrogen in all the scenarios considered, and especially the widespread use of hydrogen in the Balanced Scenario and Zero Carbon Scenario. which presents a prime opportunity to retain jobs in the gas and industrial sectors and create a massive number of new green jobs across the hydrogen supply chain, from production to distribution to end use. Read the comments here >>
  • On August 5, the CHBC submitted comments to the California Air Resources Board on the July 15 workshop on Fuels and Infrastructure for a Carbon Neutral Economy. The CHBC focused on two major areas that require efforts to decarbonize fuels and realize a carbon neutral economy. Read the comments here >>
  • On June 12, The CHBC and  33 member signatories sent a letter to CARB Chair Mary Nichols to include in its Scoping Plan update and other programs nine recommendations to help drive renewable and green electrolytic hydrogen market development. Read the letter to Chair Nichols here >>
  • On April 17, the CHBC submitted an addendum to the Air Resources Board Chair and Members, which provided information on hydrogen and fuel cell technology. This addendum was developed in response to the ACT Coalition’s letter the Board received in March on battery electric technology. These materials were provided to the ARB as it develops the Advanced Clean Truck Regulation, which will require a certain percentage of new truck sales be zero emission and a reporting requirement for large companies and fleets. Read the CHBC addendum here >>
  • On March 6, the CHBC submitted comments to the CARB regarding its Webinar on California’s Carbon Neutrality Goals: Approaches for the Industrial Sector Meeting. The CHBC expressed its support continued focus on industrial sector emissions in its efforts to pursue statewide carbon neutrality by 2045. Read the full comments here >>

California Environmental Protection Agency (CalEPA)

  • On June 12, the CHBC and 32 member signatories sent a letter to Secretary Jared Bumenfeld encouraging the California Environmental Protection Agency (CalEPA) to consider hydrogen and fuel cell development as a pillar of its strategy to address the economic devastation caused by the global COVID-19 pandemic, outlining nine recommendations to do so. Read the letter to Secretary Blumenfeld here >>
  • On May 5, the CHBC sent a letter to CalEPA Secretary Jared Blumenfeld, requesting the expeditious implementation of SB 1383, which is imperative to reduce short lived climate pollutants (SLCPs), the most imminently dangerous greenhouse gas emissions. Renewable hydrogen can contribute to achieving SB 1383’s SLCP reduction goals by displacing fossil natural gas with a zero greenhouse gas alternative in the gas pipeline. Read the letter here >>