Clean Energy Group Response to RFI on Regional Clean Hydrogen Hubs Implementation Strategy

Comments submitted in response to DOE’s request for information (RFI) regarding the implementation and structure of a DOE Funding Opportunity Announcement (FOA) to fund regional hydrogen hubs, in accordance with the Infrastructure Investment and Jobs Act. This submission reflects several of CEG’s concerns with the H2Hub program. The first is the program’s focus on hydrogen production from fossil fuels paired with carbon capture and storage (also known as blue hydrogen). This method has been proven to lead to increases in lifecycle greenhouse gas emissions compared to natural gas, and extends the life of polluting fossil fuel assets. For this reason, CEG supports prioritizing hydrogen production from renewable energy, with the caveat that this renewable energy should not be diverted from directly decarbonizing the grid. Finally, CEG highlighted several environmental justice concerns with the H2Hubs program, and advocates for immediate and responsive consultation with environmental justice communities in and around potential hydrogen hub sites.