| First Name: | Randy |
|---|---|
| Last Name: | Hull |
| Email Address: | rhull@innosepra.com |
| Affiliation | Chief Commercial Advisor @ Innosepra |
| Subject | High CI factor threshold for liquid hydrogen not aligned with IRA |
| Comment |
The threshold CI factor as reported in the Feb 22 workshop for
gaseous H2 roughly equates to the maximum level of CO2 allowed to
obtain a "Clean Hydrogen Production Tax Credit." That is at a
maximum CI of 55 gCO2e/MJ H2, above which no LCFS credits are
allowed, roughly equates to the Inflation Reduction Act of 2022
threhold of 4 kg CO2e/kg H2 when adjusted by the EER factor for
FCEV engines.
Allowing liquid hydrogen ("LH2") a maximum CI of 95 gCO2e/MJ makes
no sense whatsoever and that CI is really not materially different
than CNG. Gaseous H2 is the precursor for production of both
high-pressure gaseous H2 as well as liquid hydrogen. While the
capital cost differences are significant between the two
approaches, the energy inputs are not that different: 3-5 kwh/kg
for UHP gaseous H2 vs 12-13 kwh/kg for LH2 production and fueling
station recompression. The maximum CI limit for hydrogen should be
the same no matter the mode of production and supply. |
| Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2023-02-23 08:00:14 |
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