Industry Responds to DOT Gap Analysis
Karen Hall, National Hydrogen Association

In its report entitled Hydrogen Infrastructure Safety Technical Assessment and Research Results Gap Analysis, DOT-T-06-01, April 2006, (DOT Report - see Hydrogen and Fuel Cell Safety, August 2006) the U.S. Department of Transportation (DOT) has provided a starting point for assessing existing regulations within DOTs purview, and determining where research is needed to revise existing regulations or develop new regulations, and where amendments may be necessary to enable the hydrogen infrastructure. DOT has identified the status of applicable regulations for hydrogen infrastructure. DOT is requested stakeholder feedback on its report to assist in prioritizing future efforts.

The NHA took up the challenge to coordinate feedback. Two articles describing the report and inviting stakeholder input were published in the NHA’s Hydrogen and Fuel Cell Safety Report (August 2006 and July 2006). In addition, the NHA’s Codes & Standards Coordinating Committee and the US Fuel Cell Council were specifically asked for input and to review draft responses. The topic was also the subject of an In-Person meeting of the National Hydrogen and Fuel Cell Codes & Standards Steering Committee (Hydrogen and Fuel Cell Safety, September 2006, listed under item 4.0) in September in Detroit, Michigan.

After many discussions and iterations, I am pleased to announce that the US Fuel Cell Council and the NHA Codes & Standards Steering Committee have endorsed the industry report. It was delivered to DOT on December 5, and contains specific feedback on the following topics:

Issues Raised by the Industry Sector

• Issues from Original Equipment Manufacturers (OEMs)
• Hydrogen Infrastructure
• Fuel Cell Manufacturers
• Portable Power Suppliers

Discussion of Gaps

• Stationary Applications
• Transportation Applications
• Portable and Micro Applications
• Hydrogen Infrastructure