Comments on the California Energy Commission (CEC) Clean Hydrogen Program under AB209 (Docket 22-ERDD-03)

CRS’s comments include general support for the CEC’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen production and use claims that meet the requirements of AB 209.