"Hello, I'm Dr. Joe Pratt, CEO at Zero Emission Industries. Looking carefully at the proposed additionality rules, it's very clear that they are well-intentioned, but that put into practice would severely hinder our ability to decarbonize all the energy sectors in the country. This is especially true for the hardest to decarbonize ones, which are the heavy-duty sectors like long-haul trucking, rail, construction, marine, along with very fuel-intensive industries like steelmaking, fertilizer production, industrial heat, and power generation.
The heavy-duty transportation sector relies on diesel as the primary fuel. Diesel is more polluting and has a higher greenhouse gas impact than gasoline or natural gas. The duty cycles and runtime hours of use for these transportation applications mean that every single vehicle, locomotive, or ship has a much higher fuel demand and environmental impact than a passenger vehicle. For example, when I was at Sandia National Laboratories, we completed a study that showed a single container ship uses as much fuel in one day as 880,000 vehicles.
The other aspect of heavy-duty use is that they are disproportionately collocated with economically and socially disadvantaged communities. This means that failure to clean up these industries will have the biggest impact on these communities. Finally, these industries are extremely cost-sensitive to fuel cost. The fuel cost in some of these applications can make up over 50%, and sometimes over 80%, of the total cost of ownership of running, for example, a long-haul locomotive or container ship.
In summary, additionality tenants work together to make it incredibly difficult to make available the huge amounts of cost-effective, low-carbon hydrogen that enables us to clean up and decarbonize our heavy-duty sectors. The result of the additionality requirements will be that these sectors continue to burn diesel and other fossil fuels. This will continue to do damage to our climate and air quality. These problems are urgent ones that require solutions now. We need to be looking for ways to make hydrogen more available and more cost-effective. Thank you."
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