Tell the Department of Energy to stop propping up dirty energy!

Dirty energy contaminates the air we breathe and the water we drink. And the impacts are not shared evenly -- pollution hits low-income communities and communities of color the hardest.

But the Department of Energy is planning to increase hydrogen energy production from fossil fuels, worsening pollution and contributing to climate chaos. Will you use your voice to demand the agency put clean energy over Big Polluters?

Comments

I am writing with serious concerns about the pending implementation of DOE’s new ‘clean’ hydrogen hubs programs. The DOE seems set on a course to undermine any potential for ‘clean’ hydrogen by allowing polluter interests to co-opt this $8 billion program. The current hydrogen production standard is set at 2kg/CO2 per kg/H2, a disastrously low bar that will only undermine efforts to move towards sustainable energy. If lifecycle, as opposed to facility emissions, is appropriately considered, no hydrogen produced from fossil fuels (even using CCUS) could ever achieve this standard. Qualifying hydrogen produced from fossil fuels as ‘clean’ hydrogen will turn the clean hydrogen standard into another meaningless greenwashing term. The DOE must use its discretion over hub selection criteria by setting a higher bar than what was legislatively required. This will require an analysis of fugitive emissions and a carbon intensity standard that does not allow hydrogen produced from fossil fuels to be qualified as ‘clean’.

Due to high energy and water demands, there are very few end-uses where even green hydrogen is sustainable and well suited. Although the Infrastructure Investment and Jobs Act does seem to mandate feedstock diversity in hub selection ‘to the maximum extent practicable,’ that still grants DOE the discretion to refrain from using these funds for obviously impractical applications. Particularly given the considerations raised in Category 4, it seems prudent for the DOE to prioritize hydrogen projects demonstrating usage in industrial sectors rather than in the power sector, transportation, or in uses where direct electrification is feasible.

Category 3 of this RFI solicits input on Equity, Environmental, and Energy Justice (EEEJ) Priorities. Given the strong potential of hydrogen investments to exacerbate existing inequities, EEEJ priorities must be central in the selection criteria and remain centered at each step of the process. Further, the White House Environmental Justice Advisory Council specifically names the procurement of nuclear power and the projects that facilitate fossil-fired generation as not beneficial to a community. I encourage the DOE to incorporate these recommendations into its criteria during the hub selection process and in its consideration of what spending should count towards Justice40 commitments.

In addition to the issues with the program’s criteria, the way this RFI is being conducted seems to indicate that the DOE is not taking its responsibility to listen to public input seriously. Public participation improves the quality of agency action and ensures that the administrative process has both public accountability and legitimacy. Despite this, the comment period for this RFI is only 30 days, a shockingly short period for the public to be able to respond and/or raise concerns with how this massive new $8 billion program will be implemented. I am concerned that this will be the only opportunity to comment on program design before the NEPA reviews alluded to in Phase 1 -- after which it could be too late to prevent harmful and short-sighted projects. The short comment period is only further exemplified when compared with DE-FOA-0002698, an RFI on two much smaller and less consequential hydrogen programs that was opened on the same day as this RFI but has a comment period that is nearly twice as long. I encourage the DOE to deeply consider its own question #31 about meaningful engagement, as the bare minimum of engagement is allowing adequate response time. Given the potential impact of this program, I ask the DOE to extend this comment period.

Thank you,
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