NEPA Recommendations for Regional Clean Hydrogen Hubs

The Clean Air Task Force (CATF) recommends that the U.S. Department of Energy (DOE) use a programmatic NEPA analysis with tiered analyses for individual projects within each hydrogen hub to manage varying project schedules and cumulative impacts. CATF advises the DOE to build internal capacity, coordinate early with federal and state resource agencies, and provide consistent technical guidance and templates to applicants. To ensure transparency and environmental justice, the document suggests implementing public dashboards, regional scoping meetings, and accessible communication strategies to engage local communities.

• The DOE should implement a programmatic NEPA analysis for each hydrogen hub, utilizing tiered analyses for individual projects to accommodate different design schedules and evaluate cumulative impacts across the hub.
• To avoid internal bottlenecks and delays, the DOE needs to increase internal resources, establish clear roles for signing off on environmental documents, and develop internal training and tracking systems for NEPA reviews.
• Early engagement and pre-consultation with federal and state resource agencies, including the EPA and Army Corps of Engineers, are recommended to align processes and avoid duplication with state 'mini NEPAs'.
• The DOE should streamline permitting by establishing Memoranda of Understanding (MOUs) with other agencies and creating checklists of potential impacts that trigger specific reviews.
• To ensure consistency and quality across the program, the DOE should provide applicants with robust technical assistance, including templates for NEPA documentation and reference lists of impact analysis tools.
• The DOE should maintain oversight of NEPA consultants by approving their selection based on qualifications and regularly monitoring milestones to ensure consistency across different hubs.
• To advance environmental justice and Justice 40 commitments, the DOE should use regional public scoping meetings, a public progress dashboard, and accessible communication methods like interpreters and non-work hour meetings.

APA

Clean Air Task Force (2024). NEPA Recommendations for Regional Clean Hydrogen Hubs. https://cdn.catf.us/wp-content/uploads/2024/08/15095152/catf-nepa-recommendations-hydrogen-hubs.pdf

Chicago

Clean Air Task Force. NEPA Recommendations for Regional Clean Hydrogen Hubs. 2024. https://cdn.catf.us/wp-content/uploads/2024/08/15095152/catf-nepa-recommendations-hydrogen-hubs.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=NEPA Recommendations for Regional Clean Hydrogen Hubs |date=5 August 2024 |url=https://cdn.catf.us/wp-content/uploads/2024/08/15095152/catf-nepa-recommendations-hydrogen-hubs.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2024nepa, author = {{Clean Air Task Force}}, title = {{NEPA Recommendations for Regional Clean Hydrogen Hubs}}, publisher = {Clean Air Task Force}, year = {2024}, month = aug, url = {https://cdn.catf.us/wp-content/uploads/2024/08/15095152/catf-nepa-recommendations-hydrogen-hubs.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }