Comment Log Display

Nuvera Fuel Cells is a provider of fuel cell systems for mobility
applications and of hydrogen generation and refueling equipment.
The company is owned by NACCO Materials Handling Group, a global
manufacturer of industrial vehicles, including Hyster(R) and
Yale(R) brand forklift trucks.

Nuvera endorses the proposed inclusion of hydrogen fuel for fuel
cell-powered forklifts as a means for generating LCFS credits. We
also propose extending the application beyond forklifts to other
industrial vehicles, such as ground support equipment, transport
refrigeration, and container handling equipment. These measures
will help drive the adoption of low carbon fuel alternatives within
California's large industrial vehicle sector, which includes
distribution centers, warehouses, manufacturing facilities, ports,
and other venues that are concentrated emissions sources.

Nuvera advises against the adoption of the proposed Provisional
Credit clause that would allow companies to earn provisional LCFS
credits but would not allow them to be traded for two years. This
provision would be a significant disincentive for prospective
producers.