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Amogy, an ammonia-to-power technology company, supports the efforts
and submits the following comments in response to California Air
Resources Board's (CARB) call for stakeholder feedback on Public
Workshop to Discuss Potential Changes to the Low Carbon Fuel
Standard, specifically CARB's request for information on the role
of ammonia, ammonia-to-power technology, as a carbon-free
alternative fuel. 

This is of particular importance to decarbonizing the maritime
sector. On April 12. 2022 the Biden Administration announced
support and commitment of the U.S. to establish Green Shipping
Corridors, "In support of the effort to achieve net-zero greenhouse
gas emissions by no later than 2050, and in support of the effort
to achieve zero greenhouse gas emissions from the international
shipping sector by the same year, the United States is charting a
course to advance domestic and international green shipping
corridors." Green Shipping Corridors (global and domestic) and
individual ports incentivizing and requiring emissions reductions
accelerate the need to create a robust portfolio of decarbonization
solutions. COP27 resulted in a recommitment and ramp up of global
efforts to decarbonize the maritime shipping sector. Mission
Innovation, to which the U.S. is a member country, enhanced its
global efforts to accelerate progress towards the Paris Agreement. 
 

Additionally, ammonia-to-power technology will provide for
off-the-grid hydrogen production and power solution. This is
critical to creating a resilient hydrogen ecosystem.
Ammonia-to-power technology allows for the easy transport of
hydrogen, with ammonia as its carrier.  As such, it serves as an
ideal solution for the challenges in serving the hydrogen needs of
more rural and remote areas within the hydrogen hub context. For
example, in this application, green hydrogen can be used to create
the green ammonia which can then be transported to an end user
where it can be cracked back into hydrogen. This negates the safety
concerns and complications that often accompany the transportation
of pure hydrogen.

Furthermore, given the dire need to reduce GHG emissions to zero by
2050 globally and with other jurisdictions and entities having more
aggressive intermittent dates, it is imperative that there be a
number of alternative solutions to increase the portfolio of
options. There is no one-size fits all approach. Instead it's an
all hands on deck effort to identify and solve the energy demand
needs of each polluting sector. 
 

ADVANTAGES of NH3 as energy source  
   	
Over 200 ammonia ports worldwide 
Ammonia is the second largest produced chemical globally
Over 4,500 miles of domestic ammonia pipeline
Energy density of NH3: ​​
Material - x20 battery & x10 H2 gas 
System - x5 battery & x2.5 H2 gas 
Ease of storage and transport (existing regulations and standards
for the handling and transport of NH3 given its prevalence as a
widely used chemical)
Historic infrastructure investment on the production of green
ammonia (NH3 produced using renewable energy) within the $10B
Hydrogen Hub program.
Ideal fuel source for agricultural applications. As farmers are
already familiar with the use of ammonia in an agriculture setting
for fertilizer applications, it is a natural fit to meet the fuel
needs for power demanding farm applications such as tractors, grain
dryers and the warming of livestock barns. Companies, such as
Amogy, have already successfully demonstrated the viability of
ammonia as a tractor fuel.

SAFETY 
   	 
Existing knowledge of safe handling of NH3 already as firm
foundation for the evolution of NH3 as fuel
Extensive network of global studies (ongoing and completed) to
advance safety measures for utilizing ammonia in the variety of
applications (for the user and the public) with support from a wide
variety of stakeholders including the American Bureau of Shipping 

ENVIRONMENT Benefits 
   	  
2.7% of global CO2 emissions are attributable to the shipping
sector (1% in US). IMO goals of 50% reduction of emissions (as
compared to 2008 levels by 2050, zero by the end of the century. 
Projections from the International Renewable Energy Agency (IRENA)
estimate that by 2050, in a scenario aligned with the Paris
Agreement goal of keeping global temperature rise within 1.5
degrees Celsius (°C), this transition would lead to a 688 Mt
ammonia market, nearly four times larger than today's market. This
ammonia would be decarbonized, with 566 Mt of new renewable ammonia
production (from renewable hydrogen and renewable power),
complemented with fossil-based ammonia production in combination
with carbon capture and storage (CCS). This drastic growth in the
ammonia market is significantly caused by the recognition of the
role of ammonia as a carbon-free fuel, especially in maritime
shipping. 
IMO regulation, MARPOL Annex VI,  sets limits on NOx and SOx
emissions from ship exhausts, and prohibits deliberate emissions of
ozone depleting substances from ships of 400 gross tonnage and
above engaged in voyages to ports or offshore terminals under the
jurisdiction of states that have ratified Annex. Ammonia fuel
technologies will be key to meeting these NOx standards.  


EQUITY Benefits   
Using NH3 as an energy source is consistent with goals of the Biden
Admin Justice40 Initiative especially in the decarbonization of
ports, port infrastructure and board maritime applications. Ports:
Given NH3's natural fit for decarbonizing a variety of port and
maritime applications. 12% of the population (39 million people)
live near seaports, many in what is considered environmental
justice communities. These communities exhibit higher rates of
respiratory and cardiovascular disease, dangerous soil and water
quality, and poorer health outcomes exacerbated by elevated
emissions from port related equipment/vehicles/ships (standard port
related activities).   

ECONOMY Benefits      
Energy security for US - domestic green NH3 production 
NH3 can be used as a carbon-free energy solution in pretty much
every application, especially those with heavy duty cycle
requirements.
Existing infrastructure to support usage (4,500 existing domestic
pipeline miles, over 200 ports worldwide)   
Consistent with the US Department of Energy's National Clean
Hydrogen Strategy and Roadmap which states:  "Container ships carry
about 90 percent of global trade by volume, producing about 3% of
global carbon emissions and a larger share of sulfur dioxide
emissions. Potential alternatives during the third wave include
clean ammonia, clean methanol, and liquified clean hydrogen."
Maritime engine manufacturers expect to commercialize
ammonia-fuelled two-stroke and four-stroke engines by 2024 or 2025,
for new builds and retrofits. Ammonia engine developers can deliver
commercial performance within existing regulatory limits for
nitrogen oxides. 


Thank you for the opportunity to provide comments on potential
changes to the Low Carbon Fuel Standard, specifically the role of
ammonia . We welcome the opportunity to engage in discussions with
the CARB and other relevant agencies about the role of ammonia and
supporting technologies to help advance local, state, national and
global emissions goals. 

About Amogy: 
 
Amogy is an ammonia energy company developing the technology to use
liquid ammonia (hydrogen carrier) as a zero-emission fuel to
decarbonize maritime shipping, heavy-duty & industrial
transportation, and stationary power. Amogy was founded in November
2020 and is headquartered in the Brooklyn Navy Yard in Brooklyn NY
with offices in Stavanger, Norway and Houston, TX.  As of March
2023, Amogy has over 100 employees.
 
Amogy's technology uses liquid ammonia as a zero-emission fuel to
decarbonize maritime, heavy-duty & industrial transportation, and
stationary power. Amogy's technology cracks ammonia (NI3) in situ
into nitrogen and hydrogen, and the hydrogen that is formed can
then be utilized three ways: (1) distributed to an integrated FC,
(2) the hydrogen can be used as a pilot fuel in an ammonia
combustion engine, or (3) remain as pure hydrogen for chemical
applications or other hydrogen needed end-uses. In all three
instances, using ammonia as the hydrogen carrier and the on-demand
cracking technology, the need to store and transport hydrogen is
eliminated, which is the biggest challenge in hydrogen use. In
addition, ammonia can be transported more easily than pure hydrogen
which makes Amogy's cracking technology idea for meeting hydrogen
demand in rural and more remote locations.  Ammonia can be easily
stored as a liquid and as such, it gives our system a high energy
density that is 5x that of a battery and almost 3x that of H2 gas. 
Eliminating the need for both intermittent hydrogen storage and
complicated hydrogen transport and the energy density of ammonia
enables Amogy's technology to be compact, efficient, and scalable.

 
Amogy demonstrated its first proof of concept in July 2021 with the
first-ever ammonia-powered zero-emissions 5kW drone and
subsequently a 100kW retrofitted John Deere tractor in May 2022. In
January 2023, Amogy demonstrated its technology at 300 kW in a
class 8 truck, and is planning a 1 MW marine vessel demonstration
in late 2023.  In Sept 2022, Amogy received its Approval in
Principle (AiP) from Lloyd's Register for the ammonia-to-power
system in said marine vessel. These demonstrations will lead to the
commercialization of Amogy technology starting in 2024 as a
solution to meet global and national fuel decarbonization goals.

Original File Name: Amogy White Paper 041522_FINAL (4).pdf

Date and Time Comment Was Submitted: 2023-03-14 11:14:26