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Comment 45 for Proposed Low Carbon Fuel Standard Amendments (lcfs2024) - 45 Day.

First NameFelipe
Last NameAmaya
Email Addressfelipe.amaya@modernhydrogen.com
Affiliation
SubjectWhy Excluding H2 Produced from Fossil Fuels Undermines California’s Environmental Goals
Comment
To effectively combat climate change, our focus must be on reducing
carbon emissions, not on eliminating hydrocarbons. Modern
technologies like methane pyrolysis allow us to separate carbon
from hydrocarbons, enabling the production of clean hydrogen while
utilizing existing infrastructure and minimizing costs. This
approach yields hydrogen as clean, if not cleaner, than so-called
"green hydrogen," without relying on renewable power.
Categorically excluding fossil fuels from hydrogen production under
the LCFS undermines California's environmental goals by ignoring a
critical, low-carbon, and scalable solution. Here's why:
1. Fossil fuel-based hydrogen can achieve carbon neutrality or
negativity: methane pyrolysis can produce hydrogen with minimal or
even negative carbon footprints, offering a competitive and
immediate pathway to emission reduction.
2. Urgent decarbonization: delaying the adoption of all viable
low-carbon technologies will harm vulnerable communities
disproportionately affected by pollution and climate change. We
need immediate, practical solutions to meet our environmental
targets.
3. Infrastructure reliability: using existing natural gas pipelines
for hydrogen distribution ensures reliable supply and enhances fuel
cell vehicle adoption. Limiting fossil fuel-derived hydrogen would
hinder the transition to clean transportation.
4. Cost competitiveness: a diverse hydrogen market lowers costs and
price to end users. Excluding fossil fuel-derived hydrogen stifles
innovation, limiting affordable decarbonization options.
5. Water conservation: unlike electrolyzers, hydrogen production
from methane pyrolysis requires no water, a crucial advantage in
drought-prone areas of California.

We can and should leverage fossil fuels to produce clean hydrogen.
Excluding this pathway further delays critical progress in
achieving California's urgent climate goals.

Attachment
Original File Name
Date and Time Comment Was Submitted 2024-11-08 11:11:00

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