Environmental Justice Concerns with Carbon Capture and Hydrogen Co-Firing in the Power Sector

Read the latest report on Environmental Justice Concerns with Carbon Capture and Hydrogen Co-Firing in the Power Sector, prepared in partnership with the New School Tishman Environment and Design Center, Center for the Urban Environment of the John S. Watson Institute for Urban Policy and Research at Kean University, and the Center for Earth, Energy, and Democracy.

For questions, please reach out to Brooke Helmick, Director of Policy at brooke@njeja.org.

A Quick Guide to Hydrogen Production and Hydrogen Co-Firing

As the country sees a proliferation of hydrogen fuel projects through both private and public investment, NJEJA has developed this fact sheet to explain hydrogen fuel production, the risks to our communities, and how to understand the “colors” for each type of hydrogen.

For questions, please reach out to Brooke Helmick, Director of Policy at brooke@njeja.org.

Comments to the White House Environmental Justice Advisory Council on Carbon Management

On June 19, the New jersey Environmental Justice Alliance submitted comments to the White House Environmental Justice Advisory Council (WHEJAC) regarding carbon management. NJEJA highlighted the risks of CCS and hydrogen co-firing, the necessity of directing federal funding towards communities and sustainable, renewable technologies, and recommending increased oversight, transparency, and accountability in DOE project development. Click here to read more about the WHEJAC.

Read our full comments below:

NJEJA and ICC Submit Comments on the Energy Master Plan

On June 12, the New Jersey Environmental Justice Alliance and the Ironbound Community Corporation submitted public comment to the Board of Public Utilities regarding the 2024 Energy Master Plan. These comments reflect a joint effort to decrease emissions in the state of New Jersey and facilitate to swift transition to affordable truly-clean energy for everyone, particularly low- and moderate-income and EJ communities. Click here read other public comments and view the BPU’s docket.

Read our full comments below:

NJEJA and Partners Submit Comments on EPA’s Power Plant Rule

On May 28, the New Jersey Environmental Justice Alliance and EJ partners submitted crucial comments to the U.S. Environmental Protection Agency (EPA) regarding the second part to their Power Plant Rules. These comments reflect a unified effort from numerous EJ organizations across the country to call on the EPA to substantially address the cumulative impacts of air pollution and the disproportionate burden of both greenhouse gases and greenhouse gas co-pollutants on environmental justice communities. Click here to read our full comments.

Read Our Statement Below, and hear what EJ advocates had to say about the unique opportunity in this comment period:

Comments to the U.S. EPA regarding the Power Plant Rules

On May 28, the New Jersey Environmental Justice Alliance and EJ partners across the country submitted comments to the EPA regarding the Power Plant Rules for Existing Natural Gas Plants. The comments reflected a unified effort from EJ organizations to call upon the EPA to address the cumulative impacts of pollution and the disproportionate burden of greenhouse gases and greenhouse gas co-pollutants in EJ communities.

In all, the comments addressed four key areas:

  1. Recognizing that retrofitting for carbon capture and hydrogen co-firing must not qualify as a “BSER” (Best System of Emission Reduction) ;
  2. Locating other operational mechanisms to increase efficiency, such as heat rate improvements;
  3. Ensuring that the EPA provide effective oversight to state implementation of these rules;
  4. Demonstrating that facilities sited in EJ communities will not cause or contribute to adverse cumulative impacts as a result of their compliance with the rules;
  5. Incorporating a cumulative impacts framework into the rule.

For all questions and concerns regarding these comments, please contact Brooke Helmick, Director of Policy at brooke@njeja.org.

NJEJA Toolkit: EPA Power Plant Rule

 

On April 25, the EPA announced a new suite of rules aiming to decreasing pollution in four areas. Key among these was the EPA’s decision not to consider hydrogen co-firing as a solution to mitigating emissions in the power sector. Communities now have an unprecedented and unique moment to continue influencing the EPA rule making process, which will have repercussions for decades to come. 

Recognizing the importance of this moment, NJEJA hosted a webinar on Tuesday, May 14 for community organizations, advocacy groups, and individuals interested in engaging in this comment period.

 

Use this toolkit to learn more about the rule and its relationship to carbon capture and hydrogen, as well as what you can do to take action for your community!

Questions at the MACH2 April 10 Listening Session

The New Jersey Environmental Justice Alliance has raised significant questions to the MACH2 engagement team both via email and at the April 10 MACH2 Listening Session. During the April 10 Listening Session, our team sent in questions via chat. Due to the number of participants, only one person from NJEJA was put onto the speaking list which was created and shared by OCED prior to the event.

We raise these questions out of deep concern and love for our community. The life cycle of hydrogen production is not only costly and economically inviable, but has not been proven safe for our communities. In fact, in many instances, demonstration tests for hydrogen projects have proved to be dangerous, unsustainable, and not effective projects. Furthermore, regardless of whether or not the hydrogen produced is “green” (I.e. hydrogen theoretically created from entirely renewable technology), it poses the same risks during transportation, storage, and end use as hydrogen created from fossil fuels.

In an effort to increase transparency and get these questions answered, please see the concerns that NJEJA has raised to the MACH2 team regarding the structure, function, intention, and infrastructural development of the MACH2 project.

Questions for the MACH2 Community Engagement Team

The New Jersey Environmental Justice Alliance has raised significant questions to the MACH2 engagement team both via email and at the April 10 MACH2 Listening Session. We are deeply concerned about the level of community engagement and the claim of community benefits agreements without significant investment, input, and consent from the communities who will host this infrastructure.

It is imperative that organizers for the hub consider the input of host communities, which are primary Environmental Justice communities and frontline communities who are already significant burdened by pollution and negative air quality. We call upon OCED and hub organizers to honor the community’s right to exercise free, prior and informed consent as well as their right to refuse, by providing transparent and robust information.

In an effort to increase transparency and get these questions answered, please see the concerns that NJEJA has raised to the MACH Community Engagement team regarding the logistical development of this process.

Comments to the Dept. of Treasury on Credits for Hydrogen Production

To date, climate change mitigation policy has typically been carbon-centric and focused solely on reducing carbon emissions. We urge the 45(v) tax credit proposed rule to move away from carbon centrism by addressing EJ issues that include limiting the emissions of GHG co-pollutants in general as much as possible.

A carbon centric approach and focus on solely using the lifecycle GHG emissions rate of hydrogen production as the metric to determine whether the hydrogen produced is “clean”, is a significant EJ concern. This approach ignores the emissions of GHG co-pollutants along the life cycle of not just hydrogen production but storage, delivery and end uses (such as the burning of hydrogen-blended natural gas at power plants3). Additionally, when a life cycle GHG emissions rate is the sole metric to determine whether the hydrogen produced is clean, a myriad of environmental and health impacts along the hydrogen production chain remain insufficiently addressed.