2021 Advocacy Activities

Contents

California Governor’s Office

California Assembly and Senate

  • On August 18, the CHBC submitted a letter of support for SB 643 (Archuleta). The bill will require the Air Resources Board (ARB) to prepare a statewide assessment of the fuel cell electric vehicle (FCEV) fueling infrastructure needed to support the adoption of zero-emission trucks, buses, and off-road vehicles. This assessment is critical for the development and deployment of the necessary refueling infrastructure that supports heavy-duty and off-road FCEVs. Read the letter here >>
  • On August 18, the CHBC submitted a letter of support for SB 551 (Stern/Hertzberg). The CHBC expressed enthusiasm to see amendments to the bill that are inclusive of hydrogen, fuel cells, and the refueling infrastructure necessary to support these zero-emission vehicles.  Read the letter here >>
  • On June 25, a CHBC-led industry coalition submitted multiple letters opposing SB 551, which would have established the California Electric Vehicle Authority focused on solely BEVs. Since the submission of the opposition letters, all proposed amendments to SB 551 were accepted by the bill sponsor and author. SB 551 now includes favorable language for tech-neutrality and includes hydrogen refueling specifically.
  • On June 25, the CHBC-led coalition submitted two letters of opposition to SB 551 (Stern/Hertzberg). The CHBC and its coalition members opposed the establishment of the California Electric Vehicle Authority due to its unnecessarily duplicative role to the Governor’s Office of Business and Economic Development (GO-Biz) in the development and deployment of the Zero-Emission Vehicle Strategy (ZEV Strategy), and as written, the authority would only oversee battery electric vehicles (BEVs) because the language is not inclusive of fuel cell electric vehicles (FCEVs).
  • On June 14, the CHBC sent a letter of support for SB 372 (Leyva) to Assembly Transportation Committee Chair, Assemblymember Laura Friedman. SB 372 promotes the commercialization of medium and heavy duty zero-emission vehicles, including fuel cell electric vehicles (FCEV), furthering progress on reaching California’s stated decarbonization and air quality goals. The CHBC also suggested that the bill encompass all “off-road vehicles”, not just off-road construction vehicles. Read the letter here >>
  • On June 11, the CHBC sent a letter of support for the Governor’s Proposed Budget to Senate Budget Committee Chair, Senator Nancy Skinner, and Assembly Budget Chair, Assemblymember Phil Ting. The CHBC expressed strong support of the funding proposals for zero-emission vehicles (ZEV), including renewable hydrogen refueling infrastructure, renewable energy production, and long-term clean energy storage. Read the letter here >>
  • On April 26, the CHBC sent a letter of support for SB 697 to Senate Environmental Quality Committee Chair, Senator Benjamin Allen. SB 697 provides a policy structure that promotes investment in green hydrogen production, which is a solution to reduce greenhouse gas emissions in difficult-to-decarbonize sectors, such as industrial facilities. Read the letter here >>
  • On April 9, the CHBC sent a letter of support to Senator Ben Hueso for SB 589, which will require the commission to identify workforce development and training resources needed to meet the state’s goal of putting at least 5 million zero-emission vehicles in service by 2030 and reducing greenhouse gases emissions to 40% below 1990 levels by 2030. The CHBC letter also included recommended amendments to clarify language related to zero emissions vehicles and hydrogen refueling infrastructure. Read the letter here >>
  • On April 7, the CHBC sent a letter of support for SB 662 (Archuleta) to the Senate Committee on Energy, Utilities & Communications Chair Ben Hueso. SB 662 supports the commercialization of hydrogen and fuel cell technology in California and will help the state meet its air quality and carbon reduction goals. The bill would allow gas utilities to fund projects related to the infrastructure needed to distribute zero-emission, renewable hydrogen transportation fuel. Read the letter here >>
  • On April 6, the CHBC sent a letter of support to Senator Bob Archuleta for Senate Bill 643. SB 643 will require the State Air Resources Board, the Energy Commission and the Public Utilities Commission to form a working group that will prepare a statewide assessment of fuel cell electric vehicle (FCEV) fueling infrastructure and fuel production needed to support the adoption of zero-emission trucks, buses, and off-road vehicles necessary for the state to meet its air pollution and climate change goals. Read the letter here >>
  • On March 10, the CHBC sent a letter of support for SB 18 – Green Hydrogen to Senator Ben Hueso, Chair of the Senate Committee on Energy, Utilities, and Communications. SB 18 will create pathways for California to meet its critical decarbonization goals by facilitating the production and use of green hydrogen. Read the letter here >>
  • On March 3, the CHBC sent a letter of support for Assembly Bill 322 to Assemblymember Chris Holden, Chair of the Assembly Utilities & Energy Committee. AB 322 will help meet California’s health and climate goals, reducing some of the most damaging climate and air
    pollutants, accelerating the transition to advanced biomass energy technologies, and reducing catastrophic wildfires. Read the letter here >>
  • On February 11, the CHBC sent a letter of support for Assemblymember Freddie Rodriguez’s proposed legislation to set a 100% green and zero-carbon hydrogen transportation fuel standard and enables greater zero emission light and heavy-duty vehicle adoption by providing a 10-year investment tax credit for renewable hydrogen production, distribution and refueling stations. Read the letter here >>
  • On January 27, the CHBC sent a letter of support for Senate Bill 18 – Green Hydrogen to Senator Nancy Skinner. SB 18 will create pathways for California to meet its critical decarbonization goals by facilitating the production and use of green hydrogen. The CHBC also expressed a desire to work with Senator Skinner on additional measures in the bill, including improved access to wholesale electricity markets to enable flexible demand response, hybrid renewable generation and storage, and/or energy storage resource(s), along with greater flexibility in the Low Carbon Fuel Standard to better support green electrolytic hydrogen. Read the letter here >>

California Public Utilities Commission (CPUC)

  • On August 16, the CHBC provided opening comments to the CPUC in Order Instituting Rulemaking to Modernize the Electric Grid for a High Distributed Energy Resources Future (R.21-06-017). The comments stated that CHBC supports preparing the electric grid for a high number of distributed energy resources (DER) by including clean (existing and emerging) technologies that will assist in decarbonizing and providing added resiliency to the electric grid. The CHBC specifically seek the consideration of hydrogen, fuel cell, and hydrogen storage technology, as required by SB 1369 (Skinner), which can play an important role in modernizing the California electric grid. Read CHBC’s comments here >>
  • On July 6, the CHBC summited comments to the California Public Utilities Commission on the Proposed Decision (PD) adopting a suspension of the capacity reservation component of the standby charge for eligible microgrid distributed technologies. The CHBC reply comments align with statements made by the National Fuel Cell Research Center (NFCRC), Bloom Energy, and SoCal Gas in relation to annual recertification of performance standards. Additionally, the CHBC’s reply comments respond to statements made by the California Environmental Justice Alliance (CEJA), Local Clean Energy Alliance (LCEA), and 350 Bay Area regarding the PD’s capacity eligibility requirements by aligning with comments by Bloom Energy and SoCal Gas. Read the reply comments here >>
  • On June 15, the CHBC offered reply comments to the same proceeding. CHBC expressed its agreement the Green Hydrogen Coalition (GHC) regarding: (1) A direction for investor owned-utilities (IOUs) to procure more than 300 megawatts (MW) of green hydrogen/fossil net qualifying capacity (NQC) by 20253; (2) The institution of a loading order prioritizing green hydrogen/fossil resources; (3) An increase in contract length for green hydrogen/fossil resources; (4) The definition of green hydrogen; and (5) A clarification about the portion of electricity supplied by green hydrogen either through combustion or via fuel cell generation be treated as RPS-eligible so long as the feedstocks and energy used in the production of hydrogen is also RPS-eligible. Read the reply comments here >>
  • On June 10, the CHBC submitted comments to the CPUC on the Proposed Decision and Alternative Proposed Decision Requiring Procurement to Address Mid-Term Reliability (2023-2026). The PD and APD include green hydrogen, which will create demand within the energy sector, increase the production of green hydrogen and ultimately help to decrease the cost of energy for ratepayers. The CHBC provided the following: (1) The PD should be modified to “direct,” instead of “authorize,” the investor-owned utilities (IOUs) to procure more than 300 MW of green hydrogen net qualifying capacity (NQC) by 2025; (2) The Commission should establish a loading order for the green hydrogen and fossil fuel blend that IOUs would be directed to use on the electric grid; (3) The Commission should modify the PD and APD to allow IOUs to engage in longer contracts for green hydrogen; and, (4) The CHBC proposes a definition of green hydrogen to be used in reference to this order. Read the comments here >>
  • On May 24, the CHBC submitted its reply comments to the CPUC regarding the Proposed Decision Revising the SGIP. Read the reply comments here >>
  • On May 19, the CHBC submitted its opening comments to the California Public Utilities Commission on the “Proposed Decision (PD) Revising the Self-Generation Incentive Program Renewable Generation Technology Program Requirements and Other Matters.” Read the opening comments here >>
  • On April 8, the CHBC sent reply comments to the CPUC on the Application of SoCalGas, SDG&E, PG&E, and SWGC regarding Hydrogen-Related Additions or Revisions to the Standard Renewable Gas A.20-11-004 Interconnection Tariff. The CHBC expressed its agreement with the comments submitted by the Green Hydrogen Coalition and the Joint Utilities, as well as its disagreement with the comments made by The Public Advocates Office at the California Public Utilities Commission (Cal Advocates). Read the comments here >>
  • On March 30, the CHBC submitted comments to the CPUC on the Ruling Superceding Administrative Law Judge’s Ruling on Hydrogen-related Additions or Revisions to the Standard Renewable Gas Interconnection Tariff. The CHBC expressed disappointment that the CPUC proposed decision dismissed the application and concerned about the lack of urgency the CPUC is displaying to address decarbonization of the gas grid. Read the comments here >>
  • On March 29, the CHBC submitted reply comments to the CPUC on the Assigned Commissioner’s Ruling Seeking Comment on Renewable Generation Fuels and Technologies. The CHBC expressed its agreement with multiple parties that support a broad definition of green hydrogen and inclusion of biogenic sources, which would keep the eligibility for all types of green hydrogen open in the Self-Generation Incentive Program (SGIP). The CHBC also strongly opposed expanding the double standard already permeating California regulation, in which a higher standard is applied to hydrogen and fuel cells than is applied to electricity and batteries by responding to the TURN, Sierra Club and CEERT opening comments. Read the comments here >>
  • On March 22, the CHBC submitted comments to the CPUC on the Assigned Commissioner’s Ruling Seeking Party Comment on Renewable Generation Fuels and Technologies. Read the comments here >>
  • On March 10, the CHBC submitted comments to the California Public Utilities Commission on the Amended Scoping Memo and Ruling Questions for Track 3. The CHBC urged the Commission to promptly begin work on Track 3 to evaluate resiliency to inform the development of the multi-property microgrid tariff and the customer-facing microgrid tariff to fairly create a compensation framework across all microgrid programs and technologies. Read the comments here >>
  • On March 8, the CHBC submitted its response to the Joint Comments of SoCalGas, SDG&E, PG&E, and SWG regarding Hydrogen-related Additions or Revisions to the Standard Renewable Gas Interconnection Tariff. The CHBC supported the near-term development of several demonstration projects, gather relevant data, and inform the development of hydrogen injection standards and interconnection protocols and agreements. The CHBC also agreed on any Injection Standard development to be independent of the definition discussion of renewable and/or green hydrogen. Read the comments here >>
  • On March 5, the CHBC submitted comments to the California Public Utilities Commission regarding the Draft Resolution G-3573, which provided approval of the renewable gas program area, of which renewable hydrogen is a primary element. The CHBC urged the CPUC to amend the draft resolution to allow funds to be directed toward developing technologies to convert methane to hydrogen (and value-added products) as these conversion technologies support the expanded use of renewable hydrogen. The CHBC also agreed with the CPUC that SoCalGas, in their proposed Clean Transportation program, should support zero-emission vehicles, focusing on hydrogen fuel cell electric vehicle development and fueling infrastructure. Read the comments here >>
  • On February 1, the CHBC submitted reply comments to the California Public Utilities Commission on the Proposed Decision Adopting Guiding Principles for the Development of the Successor to the Current Net Energy Metering Tariff. The CHBC supported balancing NEM with energy storage, as long as the principle of technology neutrality is upheld, so that a broad range of storage technologies, including green electrolytic hydrogen, are eligible to participate as part of the program design. Read the reply comments here >>
  • On January 25, the CHBC submitted comments to the California Public Utilities Commission regarding R.14-10-003 Proposed Decision Adopting Pilots to Test Two Frameworks for Procuring Distributed Energy Resources That Avoid or Defer Utility Capital Investments. The CHBC supported the Commission’s recommendation that the DER tariff design ought to maintain the principle of technology neutrality. Read the comments here >>
  • On January 4, the CHBC submitted a response to the Joint Application of Southern California Gas Company, San Diego Gas and Electric Company, Pacific Gas & Electric Company, and Southwest Gas Corporation regarding Hydrogen-related Additions or Revisions to the Standard Renewable Gas Interconnection Tariff. Read the response here >>
  • On January 4, the CHBC submitted reply comments to the CPUC on the Proposed Decision Adopting Rates, Tariffs, and Rules Facilitating the Commercialization of Microgrids Pursuant to Senate Bill 1339 and Resiliency Strategies.. The reply comments are available here >>

California Energy Commission (CEC)

  • On August 13, the CHBC submitted comments on the 21-IEPR-07 Transportation Benefits Report Workshop. The CHBC argued that with the climate crisis raging through California’s forests and drying reservoirs, it is imperative for California to maximize the benefits of the CTP and expand funding eligibility to all technologies that contribute to decarbonization. Specifically, the CHBC supports (1) expanding the 200 light-duty hydrogen refueling station goal that is set to support only 230,000 fuel cell electric vehicles (FCEV) to a 1,000-station goal that would support approximately 1 million FCEVs, (2) allocating funding for 200 heavy-duty hydrogen refueling stations, and (3) utilizing a carbon intensity score in determining all funding awards under the CTP. Read the comments here >> 
  • On August 11, the CHBC submitted comments on 21-IEPR-05 Natural Gas Outlook and Assessments workshop hosted by the CEC. The workshop presented a positive outlook on California’s decarbonization potential if renewable hydrogen is integrated into the state’s energy systems. The CHBC supports the integration of renewable hydrogen technologies into California’s gas demand forecasts and scenarios to replace and/or complement the use of natural gas. Renewable hydrogen is a viable option for powering the state’s gas energy systems so long as renewable hydrogen becomes scalable and utilized wherever possible. To achieve scalability, the state must understand the cross-sectoral benefits of hydrogen and apply renewable hydrogen technologies where there are decarbonization gaps; the state must change current market design and allow wholesale market access for electrolytic hydrogen producers; and, the state must evaluate renewable hydrogen—and all existing and emerging technologies—through a carbon intensity score rather than a color wheel determinant allotted to the numerous feedstock options for production pathways. Read CHBC’s comments here >>
  • On July 30, the CHBC submitted comments to the California Energy Commission for the Electric Program Investment Charge 2021-2025 Investment Plan Scoping on Technology Advancements for Energy Storage. The CHBC emphasized that the EPIC program continue efforts to fund the research and development of innovative technologies that have helped California significantly reduce greenhouse gas (GHG) emissions. The CEC should do so by committing to research and development of new and emerging zero and low carbon technologies, such as long duration energy storage (LDES) of renewable energy sources, such as hydrogen, through California’s existing and retired infrastructure, such as depleted oil fields, rock formations, and pipelines. Download the comments here >>
  • On July 23, the CHBC submitted comments on IEPR Summer 2021 Workshop requesting the consideration of including renewable hydrogen as a firm, dispatchable resource for LDES within rock formations, depleted oil fields, and pipelines. Download the comments here >>
  • On June 2, the CHBC submitted comments to the California Energy Commission on the Workshop on Natural Gas Infrastructure. The CHBC addressed the following points in its comments: (1) Supports utilizing California’s existing pipeline distribution infrastructure to transition the state to decarbonized energy systems; (2) Supports research, demonstration projects, system modeling, and technical analyses by the CEC, the pipeline distribution utilities, and other stakeholders to ensure the transition to decarbonized pipelines is informed and inclusive of the newest technologies and best practices; and (3) Strongly supports the CEC’s inclusion of pipeline safety and integrity in its plan to transition the state to decarbonized pipeline systems. Download the comments here >>
  • On May 14, the CHBC submitted comments to the California Energy Commission on the 2021-2022 Investment Plan Update for the Clean Transportation Program. The CHBC expressed its continued support for the development of the state’s hydrogen refueling infrastructure to help the state achieve its air quality and carbon-neutral goals. The CHBC also pointed out that California’s current pace of FCEV and HRS deployment is not keeping pace with the rest of the world. Download the comments here >>
  • On April 2, the CHBC submitted comments to the CEC on the Hydrogen Blending into Existing Natural Gas Systems Scoping Workshop. The CHBC comments addressed four questions outlined in the workshop by the CEC. Download the comments here >>
  • On March 22, the CHBC submitted comments to the CEC on the Draft 2020 IEPR Update, Volume II: The Role of Microgrids in California’s Clean and Resilient Energy Future. The CHBC requested clarification on terminology for renewable and fossil-fueled generation, that the report differentiate between combustion and non-combustion/zero-emission and urged the CEC to maintain technology neutrality. Download the comments here >>
  • On February 19, the CHBC submitted comments to the California Energy Commissions regarding the Draft Scoping Order for the 2021 Integrated Energy Policy Report. The CHBC expressed its support for the focus areas of energy reliability over the next five years, evolving role of the pipeline gas system, building decarbonization and energy efficiency, and energy demand as key topics for in-depth discussion and analysis via the IEPR process. Download the comments here >>
  • On February 12, the CHBC sent comments to the California Energy Commission on the Clean Energy Alternatives to Diesel Backup Generator Systems Workshop. The CHBC expressed its position that diesel generators should not provide California’s default back-up power supply for power outages in 2021 and that the state should prioritize accelerating the expanded deployment of clean power generation technologies, in particular hydrogen fuel cells, which are far cleaner, safer, and commercially available today. Download the comments here >>
  • On January 20, the CHBC submitted comments to the California Energy Commission on the Integrated Energy Policy Report Volume 1 Update – Transportation. The CHBC agreed with the California Energy Commission (CEC) that hydrogen and fuel cell technology have an important role to play in decarbonizing and reducing harmful emissions from the transportation sector and that the cross-sector benefits of hydrogen extend well beyond transportation (i.e. power generation, long term energy storage, decarbonization of the gas grid and hard to decarbonize sectors of heavy industry). Download the comments here >>

California Air Resources Board (CARB)

  • On September 22, the CHBC submitted comments on the California Air Resources Board (CARB) 2022 Scoping Update – Short Lived Climate Pollutants (SLCP). The CHBC stated that it supports capturing SLCPs (namely methane emissions) from livestock operations, dairy operations, and landfills. The CHBC supports the conversion of this renewable, low carbon intensity (CI) methane to renewable hydrogen which provides a versatile sub-zero/zero/low carbon energy solution for reducing SLCPs. Read the comments here >>
  • On September 3, CHBC commented on ARB 2022 Scoping Plan Update – Scenario Concepts Technical Workshop. The CHBC replied with recommendations on data inputs and scenario assumptions. Read the comments here >>
  • On March 31, the CHBC submitted comments to the California Air Resources Board on the proposed Advanced Clean Fleets Regulation. Read the comments here >>

California Environmental Protection Agency (CalEPA)

South Coast Air Quality Management District (SCAQMD)

  • On April 15, the CHBC submitted comments to the South Coast Air Quality Management District (SCAQMD) Board of Directors on Proposed Rule 2305 (Warehouse Indirect Source Rule). The CHBC expressed its support for the proposed warehouse ISR rule and urged the Board to adopt the most stringent alternative. Read the comments here >>