Introduction

It seems like everyone in the clean energy space is talking about hydrogen these days: Canary Media recently reported a series called The Dawn of the Clean Hydrogen Economy; the US Department of Energy (DOE) selected the PNWH2 Hub for an award of up to $1B to fund clean hydrogen production for Washington, Oregon and Montana; and our inbox is full of newsletters with subject lines like “Getting a Handle on Clean Hydrogen” and “Unpacking Clean Hydrogen Tax Credits.”  

CETI’s Net-Zero Northwest Energy Pathways-Clean Fuels analysis found strong demand for green electrolytic hydrogen and associated clean fuels as part of a pathway to net-zero emissions in the Northwest by 2050.

In January, the Washington Department of Commerce released the Green Electrolytic Hydrogen and Renewable Fuels Report (Hydrogen Report) that CETI produced with Evolved Energy Research under a contract with the agency that assesses opportunities for and barriers to deploying green electrolytic hydrogen and renewable fuels in the state. This deep dive summarizes key findings from the chapter that we wrote addressing environmental and energy justice concerns.

Assessing Hydrogen Development’s Environmental Justice Impacts

We know that green hydrogen has the potential to play a major role in achieving a clean energy transition in the Northwest – especially when it comes to hard-to-decarbonize industries – but many questions remain about the environmental justice impacts of developing a hydrogen and clean fuels supply chain.

While green electrolytic hydrogen—hydrogen created through electrolysis that is powered by clean electricity—does not produce as many emissions as other forms of hydrogen production, siting any energy project has the same potential as fossil fuel projects to perpetuate historical energy injustices and impart health and economic burden on communities.

With intention and effort, it is possible to address environmental justice concerns and support equitable green electrolytic hydrogen and renewable fuels deployment in ways that advance energy justice and address past harms.

It is therefore imperative that project developers and governments work together to implement strategies that allow the fears and concerns of impacted communities to be heard and addressed, to ensure that any clean hydrogen project is developed in meaningful collaboration with the communities it will impact.  

Interdisciplinary Frameworks Help Determine Plans for Equitable Development

In the Hydrogen Report, we discuss four helpful theoretical frameworks to incorporate environmental and energy justice into clean energy project development: Social Life Cycle Assessment (S-LCA); Social Framework for Projects; Three Tenets of Energy Justice; and Meaningful Energy Development (MED).

While there are similarities among the four—namely, whole systems thinking, transparent communication, and meaningful community engagement—the process of incorporating energy justice into project development is challenging, complex, and iterative, and therefore will likely draw upon different aspects of each framework. For a more detailed discussion, see Appendix D: Interdisciplinary Justice-Centered Frameworks of our report.

Environmental Justice Considerations for Green Hydrogen

The primary environmental justice concerns with transitioning to green electrolytic hydrogen can be thought of in the context of the three aspects of hydrogen economies:

• Upstream: Production — Use of water and electricity, placement of production facilities with respect to communities and sites of sacred, cultural, or other importance to Tribes.
• Midstream: Distribution and Storage — Environmental, safety, and aesthetic impacts of pipelines and storage facilities, safety of on-road hydrogen transport.
• Downstream: End Uses — Nitrogen oxides (NOx) emissions, health impacts, and other safety concerns around consumer end-use, and economic burden resulting from potential energy cost increases.

Chapter 4 of the Hydrogen Report discusses many more examples of how to apply the interdisciplinary environmental justice frameworks and the results from our technical modeling to these three components of green hydrogen supply chains. Here are just a few:

Upstream: Production

The solar and wind resources needed to power green electrolysis require a much larger land footprint than the electrolyzers themselves (see Appendix C: Framework for Siting and Permitting, slide 14). Therefore, concerns about the production of hydrogen should include the potential community impacts of siting the renewable energy generation needed. This points to the value of implementing environmental justice frameworks like the S-LCA that consider impacts from the full life cycle of energy project development.

As with any energy project, there are also concerns about siting hydrogen production facilities close to communities that have already experienced disproportionate industrial pollution, especially when considering retrofitting existing fossil hydrogen plants or fossil fuel facilities to produce hydrogen.

It is therefore important to use frameworks such as Three Tenants of Energy Justice that consider recognition, procedural, and distributional pillars of energy justice to address community concerns about continuing legacies of harmful siting of energy infrastructure.

Midstream: Distribution and Storage

After producing hydrogen, it must be transported via pipeline (generally for higher volumes; either hydrogen-specific pipelines or blending with natural gas) or trucks (generally for lower volumes), and/or stored, which brings up infrastructure-related environmental justice concerns.

There are safety risks with the use of pipelines to transport hydrogen, especially when it is blended into existing natural gas infrastructure above safe limits. There is a clear relationship between higher blends of hydrogen in pipelines and increased safety risk.

Hydrogen leaks can also cause explosions, as hydrogen is a highly flammable gas. To mitigate risk and transport hydrogen safely, existing steel gas pipeline infrastructure would need to be replaced, at significant cost. Even in new pipelines designed for hydrogen, developers and policymakers need to be careful to ensure safety by employing leak detection technology and ongoing monitoring.

Safety concerns apply to hydrogen storage, as well. While salt caverns may be a safer option for hydrogen storage, these only exist in certain parts of the country (and not in Washington). Therefore, gas and liquid tank storage will likely be the main in-state options for storing hydrogen, especially in the near term.

This may bring up concerns about explosion risks, which can potentially be addressed with proper safety measures, protocols, and monitoring. Applying aspects of all four environmental justice frameworks will be critical to ensure that the transportation and storage of hydrogen does not exacerbate existing (or create new) burdens on communities.  

Downstream: End uses

Hydrogen can be used in many ways, some of which bring up serious health, safety, and environmental/energy justice concerns.Nitrogen oxides (NOx) are at the forefront of environmental justice concerns for frontline communities as they increase vulnerability to respiratory infections and asthma and lead to environmental effects such as acid rain, hazy air, and nutrient pollution in coastal waters.

When hydrogen is used in a fuel cell, its only products are electricity, water, and heat. However, the combustion of hydrogen in a gas turbine can lead to NOx emissions that are six times greater than methane combustion. Hydrogen boilers used for industrial processes also involve combusting hydrogen and may produce harmful NOx emissions.

There are existing air pollution controls to limit NOx emissions in gas turbines, but additional research is needed to apply this technology to control NOx emissions in hydrogen-powered combustion turbines.

While concerns about NOx emissions from hydrogen combustion are serious and should be addressed when considering the role of hydrogen in the clean energy transition, modeling in the Hydrogen Report does not show significant use of hydrogen combustion in gas turbines or hydrogen boilers.

However, individual project economics may support end uses that are not economic in system-wide analyses, and it will be important to address the health concerns connected to NOx emissions in any project applications, particularly if the combustion is sited close to population centers. Aspects of the S-LCA and the Three Tenants of Energy Justice will be especially critical frameworks to apply in these cases.

Decommissioning

There may also be environmental and energy justice concerns around the decommissioning of hydrogen production facilities and related infrastructure. Current permitting processes already require plans for decommissioning, and any environmental/energy justice community engagement process should address concerns around this lifecycle stage as well.

It will be important to define responsibility for decommissioning hydrogen projects from the outset to mitigate negative impacts down the road. The lens of restorative justice, which considers a project’s potential harm to people and environments as well as the associated costs and reparations, should be applied here.  

Keeping EJ Considerations at the Forefront

While there is great potential for green hydrogen to be a key part of the Northwest’s clean energy future, there is work to be done to ensure clean hydrogen technologies are advanced without perpetuating past harms and with meaningful engagement from impacted communities.

A recent framework published by the Just Solutions Collective echoes recommendations that came out of our Hydrogen Report, emphasizing the importance of using hydrogen only in beneficial end uses, centering transparency in all aspects of hydrogen projects, managing air pollutants such as NOx to ensure that these don’t add to the toxicity burden in overburdened communities, and focusing on community engagement around siting and permitting, among other recommendations.

As CETI works to accelerate an equitable clean energy transition in the Northwest, these critical environmental justice will be at the forefront of our work.