I submitted a longer form of…

I submitted a longer form of the following document to hydrogen@ontario.ca.

EXECUTIVE SUMMARY

Emerald Energy from Waste is a privately owned Ontario business operating in Brampton Ontario. Our facility has been recovering energy in the form of steam and electricity from municipal solid waste since 1992. We are very excited about adding hydrogen to our energy product mix to the benefit of both Ontario and our business.

We are very supportive of Ontario’s discussion paper and offer the following general comments:

• Evaluating the total carbon reduction of a project rather than focusing on the fuel source is a sophisticated approach that is a positive step toward advancing hydrogen economy.
• Ontario’s vision for the hydrogen economy is appropriate; it outlines benefits the government foresees from a thriving hydrogen economy but does not commit the province to specific actions or goals. This approach is prudent as the hydrogen economy is in the very early stages of development and any specific commitments (other than contributing to carbon emission reduction) would be premature.
• We appreciate that the province acknowledges developing the hydrogen economy will require policy flexibility across a many provincial jurisdictions including energy production and distribution, the environment, transportation, engineering standards and even municipal planning and development.
• The Key Principles provide producers a template for designing their hydrogen systems evaluating their proposals.
Our comments focus on our experience of attempting to develop the production of producing electrolytic hydrogen locally using energy recovered from municipal waste. Our project received funding from the Ontario Centre of Excellence but was suspended because of the barriers we faced.
We recommend the province adopt policies and programs to stimulate both the hydrogen demand and the hydrogen supply. To stimulate demand, special attention should be placed on:
• Commercializing existing fuel cell technology in transit (buses, trains) and the commercial sector (warehousing, emergency power, light delivery vehicles),
• Developing hydrogen as a fuel supplement to fossil fuels (e.g. diesel and natural gas) used in larger commercial vehicles and the natural gas pipeline, and
• Supporting the design of fuel cell technologies for heavy duty commercial vehicles (Class 8 trucks, heavy equipment).

On the supply side, the province should look to local ‘underutilized’ sources of electricity that can produce electrolytic hydrogen. In our case, Emerald can produce 325 kg/d of electrolytic hydrogen using excess electricity that we currently feed into the Ontario grid. This electricity has little value to Ontario, as reflected in the wholesale price but could create more value by conversion to hydrogen and use as transportation fuel.

Although proposed more than 3 years ago, our project met many of the principles laid out in the Discussion Paper including lowering greenhouse emissions, encouraging economic development and jobs, improving energy resiliency, focus on action and using hydrogen where it makes sense.

From our experience in trying to establish a hydrogen project in Ontario, we suggest several policy changes including:

Energy Production
The province should provide more flexible contracts for Non-Utility Generators to support the ability of small generators to produce hydrogen from local energy production.

Technology
The province should develop Ontario specific technical standards for the design, installation and operation of hydrogen equipment.

Procurement
The province should include factors other than cost when assessing purchases by government agencies such as carbon intensity, air quality improvement and waste diversion and offset the incremental capital cost of hydrogen technologies for provincial agencies.

Environmental
The province must recognize that energy recovery is an important part in the waste management hierarchy and plays and role in the circular economy. EFW is distinct from disposal.

Planning
Hydrogen is a flammable gas that is stored at high pressures. Local municipalities will need guidance on how to resolve potential land use conflicts caused by its production, storage and use.

We found that developing the hydrogen economy involves coordination between many provincial agencies. While these agencies may play an important role in developing the hydrogen economy, navigating the many review and approval processes is very difficult for any project developer. To facilitate projects, we recommend the province develop a Hydrogen Secretariat charged with the responsibility of:

• Providing a forum where hydrogen users, producers and technology suppliers can exchange ideas and develop partnerships.
• Facilitating hydrogen pilot projects through Ontario’s multi-agency regulatory processes.
• Developing a regulatory template for commercial hydrogen projects.
• Using existing programs to distribute funding for pilot projects.
• Monitoring and reporting on the progress of pilot projects.
• Accelerating the development of technical standards for the use of hydrogen in Ontario including the process for injecting hydrogen into the natural gas pipelines.
• Reporting to the Premier on the progress of the hydrogen economy.

For ease of reference, we also condensed our comments into the 18 questions posed in the Discussion Paper.