Comment Log Display

FuelCell Energy (FCE) appreciates the opportunity to offer input to
the California Air Resources Board (CARB) on the Draft Regulation
on Mandatory GHG Reporting that was released by the ARB staff on
October 19, 2007, and discussed during the public workshop on
October 31, 2007.

FuelCell Energy has been activly deploying highly efficient and
ultra clean fuel cells to private and public facilities within the
State of California, North America, Europe and Asia. There are
currently nearly 20 MWs of FuelCell Energy’s high temperature
molten carbonate based fuel cells operating or under contract in
California. Typically these facilities are less than 2 MWs in size
but interest and the favorable economics of larger deployment of
this beneficial technology is growing. 

By deploying FuelCell Energy Combined Heat and Power (FCE-CHP)
systems at load centers throughout the state we can raise the
total system efficiency first by the inherent higher electrical
conversion efficiencies of a high temperature fuel cell, secondly
by removing the line losses required to transmit the electricity
to the facility and finally compound the CO2 savings by using the
waste heat to offload the boilers that are operating at
facilities. These onsite FCE-CHP systems actually reduce local
emissions since the fuel cells themselves are Ultra Clean and the
boilers are burning less fuel.

FuelCell Energy has been proud to work with municipal waste water
facilities throughout the state deploying fuel cells at waste
water facilities. These installations are producing up to 40% more
ultra clean renewable kwhrs from the same amount of digester gas
compared to standard combustion technologies.

Additionally, FuelCell Energy has been honored to be actively
engaged with the food and beverage industry in our state in an
effort to reduce operating costs, maintain industry
competitiveness, and create a sustainable business environment by
introducing a waste to energy model where in the facility’s
typical waste is used in an onsite digester to reduce disposal
costs and the associated emissions. The digester gas is fed back
to the fuel cell which then produces ultra clean and efficient
renewable energy in the form of electricity and heat for the
facility’s process. This closed loop ultra clean and highly
efficient system is the sustainable model that must be supported
and credited wherever possible. 

Based on the above FuelCell Energy requests the following changes
be made to the reporting guidelines
•	Generating facilities reporting size should be raised from 1 MW
or greater to 12 MWs or greater recognizing the greater good
distributed generation brings to our states electrical needs
•	Biogas utilization should be credited with a CO2 sink factor
recognizing the inherent renewable and sustainability aspect of
investing in the development and utilization of this fuel
•	Facilities who have invested in onsite generation should have a
CO2 credit due to the reduction of line losses and the associated
CO2 emissions

Respectfully,
Joe Heinzmann
FuelCell Energy