We urgently need pollution limits for hydrogen facilities

A hydrogen center in Germany. 

The Environmental Protection Agency has now finalized a wide array of standards to protect people and the climate from dangerous pollution. Those standards cover some of the largest polluting sectors in the U.S., including oil and gas production, power plants, and cars and trucks.

But there’s another source of dangerous pollution that still isn’t subject to air pollution limits. With a projected doubling of hydrogen production over the next decade, we need protective standards that will ensure any growth in this industry doesn’t exacerbate public health and environmental harms. Luckily, EPA recently announced that it plans to do just that (see page 539).

Hydrogen made with fossil fuels — sometimes called gray, brown, or blue hydrogen – comes with inherent pollution risks that must be addressed through enforceable standards. Existing facilities using high-polluting methods are located in communities already facing industrial pollution burdens, including California’s South Coast and the Gulf Coast portions of Texas and Louisiana. And projections show up to half of new hydrogen production in the next decade could come from fossil-based methods.

Incentives like the clean hydrogen production tax credit in the Inflation Reduction Act are expected to drive production toward lower polluting methods, including renewable electrolysis, but incentives don’t come with any enforceable pollution limits. What that means is producers can still pollute freely if they’re willing to forego that source of funding.

Also, even producers who limit their climate pollution and qualify for the credit aren’t subject to any standards for other types of health-harming pollution, like air toxics. EPA pollution standards are therefore critical alongside implementation of tax credits and other incentive-based programs.

EPA is expected to soon begin gathering the technical information and stakeholder concerns that will serve as a critical foundation for durable regulatory solutions.

Here are four key considerations:

  • A multi-pollutant approach: Fossil hydrogen production releases a suite of pollutants, including air toxics and criteria pollutants, in addition to carbon dioxide. A comprehensive approach is critical for protecting communities most impacted by these facilities.
  • Comprehensive coverage: While the projected buildout of hydrogen facilities in coming years necessitates rigorous standards for new facilities to guide investment decisions, hydrogen facilities already exist and are polluting freely at the expense of nearby communities.
  • Electrification alternatives: Hydrogen can readily be produced through low-polluting methods using renewable electricity and water. Similarly, certain processes used in fossil-based production can be electrified. Full evaluation of these options is needed.
  • Hydrogen emissions: New research shows that leakage of hydrogen occurring during production, transportation, and use can undermine hydrogen’s climate benefits over fossil fuels. Standards to prevent and minimize leakage will be central to ensure hydrogen acts as a climate solution.

We at EDF urge EPA to move forward with rigorous, comprehensive limits on the multiple climate and air pollutants from hydrogen production facilities. EPA must adopt national emission standards that will protect all Americans and provide a world-leading model for well-designed safeguards.

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