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I found the hydrogen simplified calculator very helpful and easy to
use.  I appreciate CARB drafting this as it will expedite hydrogen
projects as a tier 1 application.  The application of the
calculator is vast as it considers both SMR and electrolysis in
addition to book and claim for both RNG and low-CI electricity.

I performed a detailed check on the calculations and found little
to point out.  I also included minor comments on the instruction
manual.

• The calculator states that it is for hydrogen used as either a
transportation fuel or as a process input for alternate
transportation fuels; however, the calculator seems set up as only
as a transportation fuel since a CI is not calculated when Field
4.10 or Field 4.11 (To Fueling Station) is not input.  Also, the
defaults (SMR & Electrolysis), do not even have as input Field 4.9
Hydrogen Produced at Fuel Production Facility.
• I understand that only one Book and Claim option can be chosen
per Section D of the instruction manual; however, RNG should be
possible (though not likely) for electrolysis.  Natural gas is an
option for electrolysis, and it might be possible to have Direct-CI
Electricity and RNG.  It is also allowed per 9588.8(i)(2).
• The values in columns D and F of 'Pathway Summary' are hard to
read being in scientific notation.
• The following are potential errors in the calculator:
o The Quantity Matched for both Fields 4.6 and 4.8 is not utilized
in the CI calculation.
o Field 4.10 or Field 4.11 (To Fueling Station is not input) is not
utilized in the CI calculation for site-specific data, only Field
4.9 is.
• The Introduction tab of the calculator, states, "The Predefined
Inputs" worksheet contains..." when the worksheet tab is labeled
'CA-GREET4.0'.  The instructions also uses 'CA-GREET4.0' as the
worksheet name.
• The instructions for Field 3.8 H2 Transport Distance (miles)
refers only to the fueling station.  Can it instead include mileage
to the alternate transportation fuel production facility?
• The instructions for Field 4.4 Direct Supply Low-CI Electricity
(kWh) refers to Regulation section 95488.xx.  Should 95488.xx be
95488.8(h)?
• Consider adding the following to Field 4.6 Quantity Matched
(MMBtu, HHV), "For more details refer to LCFS Regulation section
95488.8(i)(2).
• Consider adding the following to Field 4.8 Quantity Matched
(MMBtu, HHV), "For more details refer to LCFS Regulation section
95488.8(i)(1).

I am eager to discuss these comments and help in expediting the
implementation of the calculator in any way I can.

Original File Name:

Date and Time Comment Was Submitted: 2023-03-09 14:16:15