Public Comment Letters for Section 45V→



ARCHES Community Stakeholder Meeting co-hosted with the DOE, October 25, 2023 (slides here)

ARCHES presentation at the Annual Merit Review conference May 9, 2024 (slides here)

White Papers

ARCHES white papers were written by the ARCHES working groups who met to discuss California’s hydrogen market liftoff between 2022-2024. These documents are living documents and are expected to be updated regularly. These white papers reflect the voices of over 400 ARCHES members and constitute what is needed for overall market liftoff, by no means limited by the scope of the ARCHES DOE H2Hub. 

Coming soon!


ARCHES’ role in policy is to educate decision-makers on the effects of proposed policy on the hydrogen market in California, for both the larger California ecosystem as well as the DOE H2Hub. 

You can read our public comment letters on 45V here


ARCHES is a public-private partnership to create a sustainable, statewide, clean hydrogen hub in California and beyond. For more information, see

Please fill out our contact form at

ARCHES will first review the agreement you signed. We aim to process Memoranda of Commitment within a week of their submission. Nondisclosure Agreements may take longer to process. The duration of these processes will depend on the number of submissions we receive. Once your agreement is approved, you will receive a confirmation from ARCHES and be added to the appropriate ARCHES email lists. Please add to your email client’s safe sender list to avoid messages being filtered as spam. You will receive an email from to catch you up on current events and inform you of future messages.

Check your spam folder; this is the primary reason people do not see ARCHES emails. If there are no ARCHES emails in your spam folder, please contact and we will troubleshoot with you.

Maximizing transparency within the limitations of state and federal law and a competitive environment is a top priority for ARCHES. To that end, we have hosted and will continue to host public meetings and discussions to share as much information as we can about ARCHES governance, plans, and processes. Our team is also meeting directly with community members to answer questions.

That said, many entities are competing for the $8 billion in hydrogen hub funding. Disclosing proposal contents would give our competition an advantage. In addition, the Procurement Integrity Act prohibits sharing contents of proposals for federal grant competitions. If and when it is feasible to reveal proposal information, ARCHES will do so in support of public transparency.

ARCHES recognizes this need and is exploring the best way to compensate and/or otherwise support the participation of community members and groups. This may take the form of reimbursement for lost wages, child support, transportation costs, etc. We are seeking insight from community leaders for input on best practices for a compensation policy. ARCHES did offer a stipend to community group leaders who reviewed project proposals submitted to ARCHES for inclusion in the hydrogen hub proposal being submitted to the DOE on April 7, 2023. There will be more opportunities in the future as ARCHES develops its compensation plan. Please email or check back on this website, if you are interested in being kept informed.

ARCHES is committed to establishing and sustaining productive partnerships with community, EJ, and environmental advocates.

ARCHES is creating positions for community representatives at multiple levels of the organization to represent the interests of California communities at all aspects and phases of its operation, from project selection to governance. Community representatives will have seats on the ARCHES Board. Board members will be nominated by Advisory Committees representing different aspects of California communities, including organized labor, environmental/EJ NGOs, and other representatives of impacted communities, cities and local governments, and tribal nations.

ARCHES is engaging community groups including labor leaders, environmental advocates, EJ leaders, and tribal nations to clarify questions about ARCHES and obtain inputs to inform planning.

ARCHES is creating a Community Benefits and Engagement Plan that will be a required component of all funded ARCHES projects. It will include significant community engagement and partnership components and is continuously evolving with input from diverse community stakeholders.

If you are interested in collaborating on the creation of this plan, please email about joining ARCHES' virtual Community Engagement Working Group. Additionally, ARCHES is collecting community leader insight via this survey.

Additionally, ARCHES has components such as Workforce Development that include outreach and community engagement and support throughout the state. These activities will inform the ARCHES Board and actions.

ARCHES is a limited liability corporation with a management team and a Board of Directors. Ultimate decision-making authority rests with the Board. Project selection will be decided by the ARCHES Board, based on recommendations from a team of independent technical merit reviewers and ARCHES management. Decisions about project funding will be based on the ARCHES vetting process, which lays out a set of criteria for selecting projects. These criteria are based on a combination of the DOE requirements, California priorities, and ARCHES principles. ARCHES staff will vet applicants based on these criteria, and the ARCHES Board will make final decisions about which projects will apply for matching funds from the DOE and the State of California.

Community representatives will have seats on the ARCHES Board. Board members will be nominated by Advisory Committees representing different aspects of California communities, including organized labor, environmental NGOs, EJ and other representatives of impacted communities, cities and local governments, and tribal nations.

Additionally, ARCHES has components such as Workforce Development that include outreach and community engagement and support throughout the state. These activities will inform the ARCHES Board and actions.

The Bagley-Keene and Brown Acts do not apply to ARCHES since it is a private entity. However, ARCHES is committed to openness and transparency in all its proceedings.

ARCHES will be as open and transparent as possible about all its proceedings, while maintaining strict confidentiality where necessary to protect personal, proposal, and business information.

It is the intention of ARCHES to only fund the production and use of hydrogen 1) produced with renewable resources and 2) that meet or exceed federal carbon intensity requirements on a life cycle emission basis. Beyond that, ARCHES also will consider other emissions criteria from pollutants, water resources, etc. to be “green” hydrogen production.

All electrolytic hydrogen projects that receive funding support will have to meet ARCHES criteria. Proposals will be evaluated based on ARCHES vetting criteria and overall GHG, local air quality, state environmental goals, and community impacts. To be accepted as part of the state hydrogen hub, such projects will have to undergo rigorous analysis to show they do not emit criteria emissions, toxics, or noxious odors that harm local communities. In addition, DOE-funded hub projects must comply with DOE requirements and definitions.

ARCHES hub projects will not include the use of plastics, dairy biogas, or fossil methane paired with biomethane credits.

ARCHES will use mechanisms that are recognized by state and federal authorities to track that electricity used to produce hydrogen is renewable and to evaluate hub carbon intensity. Examples are dedicated off grid renewables, PPAs, 100% renewable electricity plans offered by Community Choice Aggregators or utilities, and methodology being created to implement federal tax credits for low and zero carbon hydrogen production.

As the concept of "green" hydrogen has continued to garner excitement and support, a challenge has been lack of a common or easily applied definition. ARCHES focuses on the term "clean, renewable" hydrogen instead of color-based language in order to align with federal government law that established funding for regional hydrogen hubs like the proposed ARCHES hub, and also because the federal terminology, which is based on lifecycle carbon intensity and feedstocks, is easier to objectively apply. The federal Infrastrucure Investment and Jobs Act (IIJA), the law that established the clean regional hydrogen hubs program of which ARCHES aims to be a part, defined “clean” hydrogen as hydrogen"produced with a carbon intensity equal to or less than 2 kilograms (kg) of carbon dioxide-equivalent (CO2e) produced at the site of production per kilogram of hydrogen produced,” which may be “made from renewable energy resources.” Following the law's passage, the DOE solicited feedback from stakeholders, and subsequently the Inflation Reduction Act, which among other provisions established 10 years of production tax credits for clean hydrogen on a lifecycle carbon intensity basis, revised the definition of clean hydrogen to 0-4 kg CO2e per kg of hydrogen on a lifecycle basis, with incentives going up as carbon intensity goes down. A recent federal proceeding to establish a Clean Hydrogen Production Standard is further refining guidance on how to ensure hydrogen investments made under the IIJA are done based on objective scientific criteria that ensure greenhouse gas reduction. See this article by Lawrence Berkeley National Laboratory for more on why scientists are moving away from colors to carbon intensity.

ARCHES has developed a set of project selection criteria. An initial draft was informed by conversations with community, environmental, labor, industry, agency, and consortium representatives throughout the state. It was discussed and refined in consultation with ARCHES partners and others who signed an NDA in the October ARCHES Launch workshop in Long Beach.

ARCHES is still developing its Community Benefits Plan. As a start, we are referencing guidance documents such as the DOE Community Benefits Plan Toolkit.

However, ARCHES is prepared to make the following set of commitments to the community:

ARCHES Commitments to Community, Energy and Environmental Equity and Justice:

  • ARCHES will only fund production, distribution, storage, and use of clean renewable hydrogen.
  • ARCHES will not fund blending of hydrogen in natural gas distribution pipelines.
  • ARCHES will include organized labor, cities and local governments, tribal nations, communities and environmental justice organizations in its governance and decision-making.
  • ARCHES will involve local communities in decision-making about projects in their communities.
  • ARCHES will ensure that training programs, career development support, and high-road career opportunities are available to California's disadvantaged communities.
  • ARCHES will require that all projects advance diversity, equity, inclusion, and accessibility.
  • ARCHES will require at least 40% of the benefits from its projects to flow to California’s disadvantaged communities.

ARCHES will only support state-of-the-art new technologies. We will also perform extensive modeling and analyses to inform project selection. ARCHES will conduct safety, codes, and standards work to determine appropriate mechanisms for monitoring and rectifying any potential hydrogen leaks. ARCHES projects will be required to monitor and repair leaks. The use of hydrogen fuel for many decades in industrial settings, including pipelines in Long Beach and Los Angeles Basin, has led to continuing improvements in technologies for repairing hydrogen leaks.

It is the intention of ARCHES to only fund power plants capable of using 100% hydrogen feedstock by the end of the DOE federal funding timeframe.

ARCHES hub may include power plant projects that replace fossil natural gas with clean, renewable hydrogen. Using clean, renewable hydrogen instead of natural gas to fuel power production drastically lowers greenhouse gas emissions and does not emit particulate matter, carbon monoxide, or volatile organic compounds that contribute to public health problems. Such projects will not increase NOx emissions and will probably reduce them, and will be subject to stringent local air pollution requirements that verify this is the case.

The preferred alternative for replacing natural gas with hydrogen power production is stationary hydrogen fuel cells, which emit zero criteria pollutants. Where fuel cells are infeasible due to size, cost, or other constraints, ARCHES will consider power plant projects that combust clean, renewable hydrogen. Such projects will be required to commit to not increasing NOx and to replacing fossil natural gas with 100% hydrogen during the time frame of the hub project.

Some community members have raised concerns that using hydrogen in gas power plants with current technology will raise NOx levels. Extensive scientific research has shown hydrogen can safely be used in power plants without increasing NOx. The US Department of Energy National Energy Technology Laboratory (NETL) has confirmed that using current technology, 30-60% blends of hydrogen in gas plant turbines can be achieved without raising NOx levels. NETL also states, "Public and private research is underway to produce a 100% hydrogen-fueled turbine" and "anticipates that industry will achieve this technology by around 2030 based on current research progress and publicly announced forecasts.”

Demonstrating this finding in the field, New York Power Authority (NYPA) has achieved up to 44% blends of hydrogen in gas plant combustion while maintaining NOx levels below state standards with the help of existing catalytic reduction and CO catalyst post-combustion control systems. 100% hydrogen turbines achieving low NOx have also been demonstrated at the MW scale and are in development at the scale needed for large California power plants.

Protecting and ultimately improving public health is a top priority for ARCHES, and we will remain vigilant to ensure that all projects funded by ARCHES help achieve this important goal.

Electrolysis produces hydrogen by splitting water (H2O) molecules into hydrogen (H2) and oxygen (O2). The source of water used for electrolysis is one of the vetting criteria for ARCHES hub projects. ARCHES prioritizes using recycled water resources for electrolysis that do not interfere with drinking or agricultural water demands.  Overall the use of water for electrolysis is far less than the water resources needed for fossil fuel production and use.  Therefore, transitioning to renewable, electrolytic hydrogen and away from the extraction fossil industry will reduce overall water consumption in California and elsewhere.

No. Electrolyzers that are grid-connected can be turned on and off quickly in response to grid needs. They strengthen grid reliability by absorbing overgeneration of variable renewables like solar and wind and by providing decarbonized fuel to gas power plants needed to meet daily and seasonal peak demands when other zero carbon resources like solar, wind, and batteries are not sufficient or economical. Furthermore, electrolyzers are often co-located with dedicated renewable power, therefore having no impacts on the electricity grid. ARCHES hub will prioritize using electrolyzers to increase grid reliability.

Over the past four decades, industry has developed infrastructure to safely produce, store, distribute, and use vast quantities of hydrogen as an industrial chemical and for space exploration, and in California, thousands of hydrogen fuel cell vehicles and stationary fuel cells have been safely deployed. Like all flammable energy resources,  hydrogen must be handled responsibly. ARCHES hub will adhere to the DOE requirement of all hydrogen hubs to develop and adhere to codes and standards that ensure safe deployment of all hydrogen projects, and we believe can be a leading entity in their continued refinement. For a summary of DOE’s overview of hydrogen safety, click here.

Hydrogen is not a greenhouse gas (GHG). Hydrogen released into the atmosphere during production, transportation, or storage can indirectly generate a warming effect by reacting with other elements to produce GHGs or extend their lifetime. Recently estimated global warming potential (GWP) for hydrogen ranges from approximately 5-12, which is low compared to 28-36 for methane and in the thousands for CFCs. By displacing fossil fuels, renewable clean hydrogen use also mitigates emissions of GHGs (e.g. methane and CO2), and therefore is expected to enable significant net reduction in GHGs, even if climate impacts of hydrogen leaks or losses lessen that reduction. To put that in perspective, DOE reports that use of renewable clean hydrogen in transportation and industrial applications can reduce emissions from 40-90%. DOE also expects reduction in global warming benefit caused by indirect warming due to modest hydrogen releases, whether as a known part of the system(e.g. liquid hydrogen boil off releases) or unintentional (e.g. leaks), to be relatively small on a life cycle basis. DOE is working now to improve understanding of hydrogen’s GWP as well as monitoring and mitigating hydrogen losses through all aspects of its life cycle from production to end-use. ARCHES will follow these developments carefully and implement best practices to ensure ARCHES hydrogen hub projects mitigate and eliminate any potential leaks or losses and are climate protective.

ARCHES is initially focused on three essential end-use sectors: medium- and heavy-duty vehicles, ports, and power plants, that are especially difficult to decarbonize using any other existing technologies. Hydrogen fuel cell technologies are the most promising zero-emissions solution for medium and heavy duty vehicles and port equipment that require long usage cycles, quick refueling, and lightweight, as well as where electric infrastructure upgrades are not feasible to accommodate battery electric technologies. Renewable clean hydrogen is also the most scalable zero-carbon alternative to natural gas for use in gas power plants required by state planning to remain operational to ensure reliability. Hydrogen is an important complement to other carbon free solutions, such as solar, wind, and batteries, that are needed to reach California’s clean air, clean energy, and climate goals.

The initial ARCHES hub will not include such projects.

ARCHES working groups are exploring the potential for future use of fuels derived from renewable clean hydrogen, in the form of hydrogen derivatives such as ammonia, to decarbonize hard to abate applications such as maritime, and which can safely be harbored away from population centers.

Ammonia produced from clean hydrogen can also provide a CA domestic source of fertilizer that is currently imported and made using fossil fuels, thus perhaps providing overall economic and environmental benefits including utilization of the state’s abundant renewable resources and agricultural community workforce. ARCHES will be analyzing the risks and benefits of such approaches.

In the near-term future, as the ARCHES’ application is being reviewed by the Department of Energy, the organization is finalizing critical staffing and governance details along with establishing protocols and budget. Therefore, currently, ARCHES is unable to make any firm financial commitments or engagements with potential partners during this time. Please check our website regularly for updates on the project and opportunities for collaboration and engagement.