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CVNM Position on Hydrogen Production and Use

The transition to clean, renewable energy will be complex. Some sectors – at least for the moment – are “hard-to-decarbonize.” These include heavy industry like steel and cement, medium- and long-haul aviation, maritime shipping, and long-haul trucking, and as a limited complement to electric battery storage for longer duration energy storage. However, research and development is advancing rapidly with emerging renewable technologies being on track to meet much of this need in the near future.

We do not support development of hydrogen infrastructure for sectors where there are current or near-term cost-effective renewable energy alternatives, including electricity generation, most vehicles, cooking and building heating and cooling. It is more efficient to provide power directly from renewable sources than to use renewable energy to produce hydrogen and then use that as an energy source. This is true across sectors and end uses.

 CVNM acknowledges a limited role for hydrolytic hydrogen, commonly called green hydrogen and defined as hydrogen created from water hydrolysis using renewable energy. Green hydrogen could be useful in hard-to-decarbonize sectors. However, it can present problems at various stages of production if it is not made with truly additional renewable energy (that is, not diverting renewable energy that would have been used in other sectors) and burning hydrogen produces NOx (nitrogen oxides); NOx are potent GHGs and a health hazard. There are also concerns about the amount of water required for hydrolytic hydrogen production. Even green hydrogen can feed into uses that are not appropriate such as home heating, blended into gas-powered energy plants, or for fueling stations, and long-haul pipelines are also a concern.

We must stop the build out of all forms of fossil-fuel based hydrogen. These are created with fossil-fuel energy sources using feed stocks that also are fossil-based, such as methane gas and coal. The industry likes to color-code them: gray hydrogen made from methane currently supplies 99% of our annual hydrogen and accounts for 3-4% of global greenhouse gas (GHG) emissions. Black is made from bituminous coal and brown from lignite. This also includes blue hydrogen, defined as hydrogen made from fossil fuels with carbon capture (CC) sequestration or use; it is promoted as “clean” hydrogen.

Blue hydrogen is typically produced using steam methane reforming and is energy intensive to create. It also requires high rates of CC to make it “clean” and no project has come close to meeting its CC goals. Many studies have shown that fossil-fuel hydrogen with CC may increase GHG emissions compared with directly burning methane gas due to the additional steps that provide additional outlets for methane leakage; hydrogen combustion emits its own GHG, which has to be factored into the overall “clean” hydrogen budget. In addition, carbon capture itself is energy intensive, reducing a large part of the net energy production. All this makes blue hydrogen bad for the climate, bad for public health, and financially non-competitive. Resources and time should not be invested in a technology that will not substantially and reliably reduce climate pollution.

Hydrolytic hydrogen – in the limited sectors where such use makes economic and climate sense – should be produced as much as possible in co-location with its end-uses. Pipeline infrastructure is not equipped to transport hydrogen in high quantities. Building out that pipeline infrastructure carries many of the same environmental, environmental justice and health concerns as our existing fossil fuel pipeline infrastructure. Hydrogen may be even more likely to leak and even more volatile and explosive than methane, posing additional risks to workers and community members. Any hydrogen leakage could undermine the benefits of green hydrogen because hydrogen is an indirect greenhouse gas that is at least five times more potent than carbon dioxide over a 100-year timeframe. In addition, new long pipelines will inevitably cross Native lands and otherwise likely impact low-income and communities of color, increasing their energy production and pollution burden.

Regardless of the “color,” hydrogen production cannot be used to justify expansion of fossil fuel infrastructure that will prolong and exacerbate pollution and safety risks in already burdened environmental justice communities. We recognize that this means we are potentially working against the short-term interests of workers and communities in oil and gas basins, many of whom understand that they are living a trade-off between good-paying jobs and their health and that of the planet. That is why we call for a just transition for impacted workers and communities that acknowledges their past contributions; provides good-paying jobs and real community support; and that is centered on informed and effective community engagement in transition discussions and planning.



[These principles were laid out in an October 5, 2021, letter signed by 30 organizations – including CVNM Education Fund – addressed to Governor Michelle Lujan Grisham, State Land Commissioner Stephanie Garcia Richard, the New Mexico Congressional delegation, and the New Mexico Legislature’s leadership. Read the letter and full Principles.]

Principle 1: New Mexico must first put in place a comprehensive, durable and enforceable climate policy framework before assessing hydrogen.

Principle 2: Equity and justice must shape hydrogen policy decision and implementation.

Principle 3: Hydrogen must neither divert nor delay NM’s transition to a renewable energy future.

Principle 4: Hydrogen must avoid adverse climate, environmental, public health, and community impacts.

Principle 5: New Mexico must rigorously scrutinize the financial and economic prospects of hydrogen as a climate and energy transition tool.

Principle 6: NM must provide a clear-eyed assessment of water availability, efficiency challenges, and end-use markets for green hydrogen.

Principle 7: NM must carefully consider hydrogen infrastructure concerns.


Three Pillars for Hydrogen Use

On October 26, 2023, Public Citizen, Consumer Reports and 15 other state and national consumer and public interest organizations sent a letter to Biden administration Treasury department officials and the White House senior advisor on energy. The letter proposed “three pillars” or guardrails that the IRS should use in determining which hydrogen projects can claim the Inflation Reduction Act (IRA) section 45V clean hydrogen production tax credits ($3-per-kilogram). The signatories pointed to the “strong climate and business arguments” made by environmental groups [see the resources below from NRDC and UCSUSA] regarding the need for Treasury to require the three pillars to avoid significant emissions increases on the grid and adhere to the IRA’s statutory requirements. The consumer groups urged an additional consideration, citing the “potential negative impacts of weak Treasury guidelines” on electricity consumers.

The three pillars are:

  • Additionality – Hydrogen projects would have to get their energy from new renewable energy supplies, not by diverting already existing renewable energy supply that otherwise would power consumers and businesses
  • Hourly matching – The energy used by the hydrolytic hydrogen projects should be generated at the same time it is used. Under “annual matching,” projects could revert to fossil fuel-based energy if there was a shortage of renewable energy supply; the renewable energy requirement would be met by an annual accounting that would mask this use
  • Deliverability – The energy used by hydrogen electrolysis would have to come from the same grid that is connected to the project, ensuring build out of robust and efficient renewable energy transportation and storage infrastructure

Without these guardrails, the consumer groups said there’s a risk that demand from new, “power-hungry electrolyzers” used to generate hydrogen will cause the diversion of existing clean electricity to those ventures, depriving households of low-cost energy. That could increase electricity prices for customers and would undermine the climate goals that electrolytic hydrogen is supposed to provide.