California Air Resources Board

Dear Ms. Sahota,

Bloom Energy appreciates the opportunity to submit feedback to the California Air Resources Board (“CARB”, or “Board”) as it works to implement Senate Bill (“SB”) 905 (Caballero, Statutes of 2022).

Bloom Energy is a California-based manufacturer of solid oxide fuel cells and hydrogen electrolyzers. The company produces fuel cells for onsite power generation for commercial and industrial customers including hospitals, data centers, wholesalers, manufacturers, education, and research institutions. Bloom Energy’s fuel cells are distinct from other forms of firm generation because they use a non-combustion electrochemical process to convert hydrogen in methane molecules into electricity. Rather than using natural gas as a fuel for combustion, fuel cells use natural gas only as a carrier of hydrogen. This approach to power generation results in reduced carbon emissions, near-zero criteria pollutant emissions and minimal water use. In addition, Bloom’s solid oxide fuel cell systems are skid-mounted and can be deployed for relatively short project lives which, in combination with the inherent fuel flexibility, means fuel cells can be quickly deployed to meet onsite demand.

Critically for the issue at hand, fuel cells are ideally positioned for integration with carbon capture, utilization, and sequestration technologies (“CCUS”). Because they operate without combustion and its associated air emissions, fuel cells allow for carbon dioxide (“CO2”) to be separated from other exhaust constituents far more easily than is possible with combustion processes. When carbon capture technology is combined with Bloom’s generation technology, the result is a reliable, firm energy resource that minimizes air, water, noise, and climate impacts.

Bloom Energy strongly supports CARB’s work on the implementation of SB 905. We see enabling carbon capture, including projects paired with distributed, highly efficient, and modular energy generation systems, as a necessary component to addressing California’s energy supply and reliability challenges while reducing emissions. We support your efforts to quickly develop frameworks to support deployment of CCUS projects.

As part of CARB’s solicitation for feedback for implementation, staff provided a series of questions about program design and considerations for future rulemaking. Bloom Energy offers the following specific responses:

Question 10: What specific criteria pollutants or toxics emissions should be prioritized for monitoring and where along the CCUS/CDR project components (i.e. capture, transport, injection/utilization) should monitoring be prioritized?

The program should prioritize monitoring the main criteria pollutant emissions that are a result of combustion at the point of capture: particulate emissions (“PM”), nitrogen oxides (“NOx”), sulfur oxides (“SOx”), carbon monoxide (“CO”), and volatile organic compounds (“VOCs”). In doing so, different technologies’ impacts to local air quality can be best assessed, thus meeting statutory directives to minimize impacts to local air quality and health.

Question 15: What types of strategies are in use in other regulatory or voluntary programs that could be adapted to meet the statutory requirements?

Similar to our response to Question 10, SB 905 places emphasis on the requirement to minimize co-pollutant emissions and water quality impacts from carbon capture and storage (“CCS”) and CCUS projects enabled under the bill. Non-combustion technologies, such as fuel cells, are ideally suited for supporting SB 905’s air and water quality impact priorities, since they generate power through an electrochemical process that results in virtually zero criteria air pollutants and requires almost no water to run during normal operation. This results in the elimination of the emissions most harmful to air quality and public health. The reduction of co-pollutants also makes non-combustion technologies ideal candidates for carbon capture, since less energy and cost is required to separate CO2 from the emissions stream.

Question 22: What role could projects developed under SB 905 play in these programs and are there other programs or policies in which carbon capture removal, storage, and utilization could play a role for compliance?

Distributed energy projects developed under SB 905 could have the following effects:

• Cap-and-Trade and Low Carbon Fuel Standard (“LCFS”) Integration:
These projects should be eligible for credit under the Cap-and-Trade Program and LCFS, and emissions reductions via CCS and CCUS should be included in the Mandatory Reporting Regulation, corporate climate disclosure rules, and other relevant programs and regulations.

• Utility Procurement
CCUS projects could contribute to utility procurement goals. Ongoing discussions at the California Public Utilities Commission (“CPUC”) around Integrated Resource Planning (“IRP”) have identified CCS and CCUS as a potential tool for meeting reliability and emissions targets. SB 905 can help streamline development and enable utilities to procure CCS/CCUS resources through a unified framework.

• Grant Funding Opportunities
Distributed energy resources with CCS and CCUS may qualify for programs like the Distributed Energy Backup Assets (“DEBA”) initiative, which funds deployment of zero or low-emission technologies. A unified permitting process under SB 905 could enhance competitiveness and access to funding.

Question 23: Are there other things the state could be doing to scale up deployment of projects under SB 905?

In addition to its existing generation portfolio, California faces unprecedented load growth as a result of increased electrification and the expansion of digital infrastructure projects like data centers. In order to meet this load and maintain reliability amid extreme weather events, firm electricity resources with carbon capture must be a component of California’s energy mix. The SB 905 program is an important step for assessing and preparing for increased adoption of carbon capture technologies. In addition to “CCUS technologies” and related projects, which are defined within the statutory language, consideration should be given to those generation technologies that can be paired with CCS and CCUS technologies and result in cost-effective carbon capture at scale and most expeditiously.

Question 26: Should CARB consider adopting project type specific protocols or defining more widely applicable standards, or a combination of both? If CARB were to define key standards applicable to all methodologies as opposed to individual methodologies based on specific technology or storage, what could those look like (i.e. recommendations on existing standards), and would that approach help to scale and innovate in this space faster than development of individual protocols?

While there are many potential pathways CARB may consider creating protocols for, the board risks creating regulatory delays that will limit the amount and scale of carbon capture projects developed. One recommendation Bloom Energy would like to make would be the adoption of a single methodology for quantifying project emissions, sequestration, and providing for ongoing monitoring in sequestration ecosystems as a means of streamlining the Carbon Capture, Removal, Utilization, and Storage Program. CARB should also consider aligning its methodology with those already in common use or which are being developed. The American Carbon Registry, for example, has a draft of such methodologies that, as of submission of these comments, is nearing completion and which is likely to be considered an industry reference.

Bloom Energy appreciates the opportunity to respond to the Board’s solicitation for implementation of the SB 905 Carbon Capture, Removal, Utilization, and Storage Program and hopes CARB will consider the role of distributed generation in the design of the program.

Respectfully Submitted,

Dated: October 6, 2025

/s/ Sara O’Niell

Sara O'Neill
Vice President, Policy
Bloom Energy Corporation
4353 N First St.
San Jose, CA 95134
Tel: 916-802-7386
Email: sara.oneill@bloomenergy.com