Bloom Energy Corporation, maker of fuel cell-based "Energy Servers," has petitioned the Federal Energy Regulatory Commission for a declaratory order that its facilities meet the Commission’s standards for cogeneration units and thus that those 5 megawatts or smaller are "Qualifying Facilities" under federal law.
According to Bloom, its Energy Server Facilities employ solid oxide fuel cells that convert chemical energy directly into electricity using fuel and oxygen without combustion. In Bloom's petition, the company says "each Bloom Server Facility uses innovative technology to generate electricity from hydrogen, relying on internalized chemical processes as part of its cogeneration function." The petition describes a two-step electricity generation process: first, "hydrogen H2 is generated from methane CH4 (i.e., pipeline natural gas) through steam reformation. Second, the hydrogen H2 is reacted with oxygen to produce electricity." According to the petition, "Bloom's Facilities utilize the heat and steam that are incidental to the chemical reaction to perform a secondary use of converting methane into hydrogen through steam reformation."
Under the federal Public Utility Regulatory Policies Act of 1978 (or PURPA), generators meeting certain standards may be certified by the Commission as Qualifying Facilities. The Commission defines a cogeneration facility as a generating facility that sequentially produces electricity and another form of useful thermal energy (such as heat or steam) in a way that is more efficient than the
separate production of both forms of energy. Cogeneration facilities meeting prescribed output and efficiency standards can be certified as qualifying facilities under PURPA, which guarantees QFs various rights. Historically, cogeneration facilities have typically burned or combusted their fuel, as opposed to the fuel cell technology developed by Bloom.
Bloom argues that its Facilities are Qualifying Facilities, each meeting the standards for topping-cycle cogeneration facilities, because they produce electricity and in that process create heat and steam that is used to create hydrogen, all with output and operating efficiencies that meet the Commission's standards for Qualifying Facilities. It also notes that its facilities further the purposes of PURPA including the development of alternatives to traditional utility-owned energy resources.
If the Commission grants Bloom's petition, its facilities 5 megawatts and smaller could be certified as QFs. The Commission has docketed Bloom's petition as EL18-10, and has posted a notice and an opportunity for public comment through 5:00 pm Eastern time on November 9, 2017.
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