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February 2007

DOE/NREL “Workshop on Facilitating Permitting of Hydrogen Fueling Stations"

[Download Entire Proceedings - 58,827KB MS Word Document]

Sponsored By: DOE Hydrogen, Fuel Cell and Infrastructure Technologies Program - Safety Codes and Standards Subprogram

Editor: Russell Hewett, National Renewable Energy
Laboratory (NREL)

DATE: FEBRUARY 1, 2007
LOCATION: SACRAMENTO, CA
HOST: CALIFORNIA AIR RESOURCES BOARD (CARB)
SITE: Monitoring and Laboratory Division Conference Room
1927 13th Street
Sacramento, CA 95814

1.0 OBJECTIVES

- Bring Together Local/State Permitting Officials, HFS Project Developers and Other Stakeholders to:
  1. Share permitting experiences
  2. Discuss lessons learned
  3. Discuss the critical issues
  4. Identify what is needed to facilitate efficient, timely
    permitting of projects
  5. Develop recommendations (and priorities) for a DOE Initiative to facilitate permitting (focusing on permitting retail fueling stations, rather than R&D projects)

2.0 WORKSHOP PARTICIPANTS

Workshop participants (17Kb Excel file)


3.0 AGENDA

Agenda (35Kb MS Word document)


4.0 BACKGROUND

Pat Davis (Manager of the Safety, Codes and Standards Subprogram within the DOE Hydrogen, Fuel Cell and Infrastructure Technologies Program) -- the Workshop sponsor -- welcomed the participants and articulated the background for conducting it.

Jim Ohi (NREL Senior Project Leader) gave a presentation covering:
  • Workshop objectives
  • Desired outcomes
  • Ground rules

Pat Davis' presentation (415Kb PowerPoint document)


5.0 CASE STUDIES – PERMITS & APPROVALS

5.1 Presentations: Hydrogen Fueling Station (HFS) Project Developers
5.2 Presentations: Hydrogen Fueling Station Permitting Officials
6.0 CRITICAL ISSUES – “LESSONS LEARNED”
  • 6.1 Permitting of AC Transit’s Two Hydrogen Fueling Stations: Lessons Learned in Two Different Jurisdictions - Oakland and Richmond (14,007Kb PowerPoint document)
    Mallory Nestor-Brush, Project Director, Fuel Cell Bus Program, AC Transit, Oakland, CA

  • 6.2 “Lessons Learned” – From the Perspective of HFS Project
    Developers
    1. There are emotional issues associated with permitting and they are different from the technical issues

    2. There is the need to establish the codes-and-standards-of-record to be used in the permitting process (also, be aware of local modifications to those codes and standards)

    3. Project developers need to identify up-front for permitting officials: (i) the deviations in their designs from the requirements in codes and standards of record; (ii) rationale
      for the deviations; and (iii) how the deviations are being addressed

    4. There should be transparency in the permitting process – everything needs to be on the table

    5. Project developers have short-term interests; code and permitting and fire safety officials have long-term interests

    6. There is the need to teach or familiarize fire safety officials about hydrogen and its properties as they relate to public safety (you don’t need to teach them about PEM fuel cells, etc.)

    7. Pre-permitting meetings with the permitting officials should be conducted
      - Start early and talk often!

    8. Project developers should make sure that they know and understand the local permitting process, as well as any state regulations governing the process
      - Also, be prepared to accept input from the permitting officials and modify the design based on it , if possible
      - Then too, it is a “no Win” situation in trying to argue which jurisdiction is responsible for what, so pleas all involved

    9. There is the need for a Permitting Template – ideally, provided by DOE – for navigating through the permitting process

    10. Different states, more than likely, do permitting differently (For example, permitting in Michigan is done at the state level; in California both the state government and the local AHJ are involved)
      - Each community is different

    11. Perceived risks of a project are not the same as the actual risks

    12. There is the need for public/community involvement in the project development and permitting of stations – from the beginning!!!

    13. In general, permitting and fire safety officials do not have the technical capabilities and resources that project developers have (As on permitting official commented, “ It is not wise for a project developer and his staff of 10 technical experts to descend on a three-person permitting office with a set of documents a foot tall. Besides, the permitting staff has other
      things to do, in addition to dealing with HFS project developers”)
      - On the other hand, it is difficult to get the full attention of the AHJ without a complete project package
      - When approaching fire marshals regarding a project, do not “overwhelm” them with a large number of participants

    14. Fuel cell vehicle safety is perceived as being different than HFS safety
      - There is the possibility that in a jurisdiction for which an HFS is being planned, the officials are “comfortable” with fuel cell-powered vehicles, but have reservations about HFSs.

    15. The pace of adoption of C&S documents differs from AHJ to AHJ

    16. Interesting “Lesson Learned” by one project developer: the two most difficult permits to get were the permits for signage and for landscaping

    17. There can be a disconnect between those officials involved in permitting the construction of a project and those involved in inspecting the project and approving its operation


  • 6.3 “Lessons Learned” – From the Perspective of HFS Permitting Officials
    1. There are emotional issues associated with permitting and they are different from the technical issues

    2. Project developers need to identify up-front for permitting officials: (i) the deviations in their designs from the requirements in codes and standards of record; (ii) rationale for the deviations; and (iii) how the deviations are being addressed

    3. There should be transparency in the permitting process – everything needs to be on the table

    4. There is the need to teach or familiarize fire safety officials about hydrogen and its properties as they relate to public safety (there is no need to teach them about PEM fuel cells, etc.)

    5. Pre-permitting meetings with the permitting officials should be conducted

    6. There is the need for a Permitting Template – ideally, provided by DOE – for navigating the permitting process

    7. Perceived risks of a project are not the same as the actual risks

    8. There is the need for public/community involvement in the project development and permitting of stations – from the beginning!!!

    9. There is the need for DOE-developed “Cliff Notes” on different hydrogen production technologies

    10. Fuel cell vehicle safety is perceived as being different than HFS safety
      - There is the possibility that in a jurisdiction for which an HFS is being planned, the officials (especially elected officials) are “comfortable” with fuel cell-powered vehicles, but have reservations about HFSs.

    11. Permitting officials need to be receptive to being involved and working with HFS project developers, beginning in the pre-planning stage

    12. The pace of adoption of C&S documents differs from AHJ to AHJ

    13. There can be a disconnect between those officials involved in permitting the construction of a project and those involved in inspecting the project and approving
      its operation


7.0 RECOMMENDATIONS TO DOE
  1. Support development of a Permitting Template that permitting officials and project developers can use to navigate the permitting process

  2. Develop a Detailed Process Flowchart for getting hydrogen fueling stations in place -- a flowchart that is all-inclusive (i.e., includes issues such as zoning, getting liquid hydrogen to the station, etc.)

  3. Identify the applicable codes and standards (i.e., documents and specific safety requirements in those documents) and make them accessible to permitting officials

  4. Develop a Hydrogen Fueling Station Technology Information Repository having validated, credible information

  5. Collect information on HFS Best Practices for the use of codes and standards developers

  6. There are two issues in permitting:
    - Construction permitting
    - Inspection and permitting for operation

    Investigate the need for a generic OMI checklist that might be the basis for an OMI Guide

  7. Develop three-page Factory-Mutual-type hydrogen technology/fueling station equipment fact sheets for permitting and fire safety officials, taking into account
    their technical backgrounds

  8. Develop a Pathway (with respect to permitting) to go from today’s R&D hydrogen fueling stations to retail stations available to the public

  9. Make resources available to facilitate networking (for permitting officials) and for conducting outreach programs targeted at the public and communities where
    proposed projected are planned
    - In doing so, address the issue of “perceived risk versus actual risk”

  10. Develop Generic HFS Safety Case Studies for the use of project developers and for CDOs and SDOs

  11. Develop a “Check List” that unbiased third parties can utilize, in working with permitting officials, to determine that all safety requirements have been met

  12. Establish a process for DOE to work collaboratively with the national organizations of fire safety officials and permitting officials that “filters down” to local officials involved in the permitting process

8.0 “PARKING LOT” ITEMS FROM THE WORKSHOP

These are items and/or issues that arose during the Workshop that were “tabled” and should be addressed in other forums:
  1. What is the possibility of the hydrogen fueling station regulations being developed by the state of Michigan serving as a model for the development of regulations by other states (In Michigan, HFS permitting is done at the state-level).

  2. What constitutes HFS safety?

9.0 NEXT STEPS

The Proceedings will be made available to the Workshop participants, the members of the National Hydrogen and Fuel Cells Codes and Standards Coordinating Committee and other stakeholders. In addition, they will be made available via the NHA hydrogenand fuelcellsafetyreport website.

The DOE Safety and Codes and Standards Subprogram of the HFCIT Program will use the workshop results in planning the Annual Operating Plan for FY08.