Comment Log Display

Dear California Air Resources Board,

We appreciate the opportunity to share our thoughts on California
Air Resources Board's Low Carbon Fuel Standard amendments. The
United States Hydrogen Alliance is a non-profit trade association
dedicated to building the U.S. hydrogen economy. Our organization
represents hydrogen companies actively deploying clean technologies
across the country.

We are writing to share our perspective on several key program
areas for your consideration. These requests address the light duty
hydrogen refueling infrastructure pathway, low carbon intensity
electricity, methane pyrolysis, along with recommendations for
pyrolysis and renewable hydrogen definitions.

Regarding the new light duty hydrogen refueling infrastructure
pathway, we believe the location restrictions to disadvantaged
communities, low-income communities, and rural areas is overly
limiting. While we respect the intent of these restrictions, we ask
for removal of the hydrogen refueling station location restrictions
to allow alignment with traffic/use forecasts to ensure high usage
and maximum societal benefit and to avoid applying a double
standard for hydrogen, a zero emission fuel, in comparison to
electricity.

New restrictions for low carbon intensity electricity require it to
be supplied by new or expanded production, or within three years of
a hydrogen production facility or air capture project's creation
date. These restrictions resemble "additionality" or
"incrementality," and is something the hydrogen industry is opposed
to on all accounts. We suggest the removal of the new 100%
renewable electricity requirement given the policy bias for
electricity against hydrogen, as battery electric vehicles are not
required to charge with 100% renewable electricity. Through
California's Renewables Portfolio Standard, it is already required
for retail electricity to be 100% renewable by 2045; with the grid
already moving in this direction, this requirement seems redundant.


For the definition of pyrolysis we suggest two amendments, the
inclusion of both biomethane and solid carbon. We believe that
solid carbon should be considered as a form of carbon capture and
sequestration. Methane pyrolysis should also be included in a
pathway for flexible access to low greenhouse gas methane sources
to reduce both greenhouse gasses and the cost of hydrogen. We also
suggest an amendment to the definition of renewable hydrogen to
include pyrolysis in section two.

In section § 95490. Provisions for Fuels Produced Using Carbon
Capture and Sequestration, we suggest adding the eligibility
requirement below: 
 (3) "Hydrogen producers from methane pyrolysis that capture
precombustion carbon in solid form and permanently store it or
provide proof of permanent storage. 1kg of solid carbon is
equivalent to 3.67kg of avoided carbon dioxide"

We at the United States Hydrogen Alliance thank you for your time
and consideration. Please reach out to us if you have any
questions.

Respectfully,

Roxana Bekemohammadi
Founder and Executive Director
United States Hydrogen Alliance