Stakeholder Feedback on Clean Hydrogen Production Standard (CHPS) Draft Guidance

The document argues that the DOE's proposed 4 kgCO2e/kgH2 standard is too weak and should be lowered to 1 kgCO2e/kgH2 to prioritize truly zero-emission hydrogen. It criticizes the GREET model for underestimating methane leakage and grid emissions, warns against the safety and environmental risks of carbon capture and storage (CCS), and demands that the hydrogen hub program incorporate strict environmental justice protections and community engagement.

• The coalition recommends that the DOE adopt a CHPS lifecycle emissions threshold of no more than 1 kgCO2e/kgH2, arguing that the proposed 4 kgCO2e/kgH2 standard is too weak for scalable commercial technologies.
• The GREET model's assumption of a ~1% methane leakage rate is contradicted by peer-reviewed data; for example, a 2018 study found leakage rates of 5.4% in the Bakken and 3.2% in Eagle Ford East.
• Relying on grid-average emissions data underestimates the impact of green hydrogen because producers are incentivized to use grid power when emissions are highest, such as during hours of minimal solar production in California.
• The document urges a moratorium on new carbon capture infrastructure due to significant safety risks, citing a 2020 rupture in Mississippi where a CO2 plume traveled invisibly for miles and caused residents to collapse.
• Hydrogen's indirect climate warming potential is significantly higher than CO2, being over 30 times larger over a 20-year period and roughly 10 times larger over 100 years.
• The coalition opposes the use of unbundled renewable energy credits (RECs) to claim zero-emissions, stating such credits often do not lead to additional renewable energy generation.
• The document argues against funding 'blue hydrogen' (fossil-based with CCS), claiming it is less economically viable than green hydrogen and risks creating stranded assets.
• To ensure environmental justice, the DOE should include stringent limits on criteria and hazardous air pollutants (HAPs) and mandate meaningful community engagement and disclosure for hydrogen hub proposals.

APA

Gersen, S. (2022). Stakeholder Feedback on Clean Hydrogen Production Standard (CHPS) Draft Guidance. Earthjustice. https://earthjustice.org/wp-content/uploads/earthjustice-et-al_comments-on-chps-guidance.pdf

Chicago

Gersen, Sara. Stakeholder Feedback on Clean Hydrogen Production Standard (CHPS) Draft Guidance. Earthjustice, 2022. https://earthjustice.org/wp-content/uploads/earthjustice-et-al_comments-on-chps-guidance.pdf.

Wikipedia

{{cite press release |last1=Gersen |first1=Sara |title=Stakeholder Feedback on Clean Hydrogen Production Standard (CHPS) Draft Guidance |publisher=Earthjustice |date=14 November 2022 |url=https://earthjustice.org/wp-content/uploads/earthjustice-et-al_comments-on-chps-guidance.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{gersen2022stakeholder, author = {Gersen, Sara}, title = {{Stakeholder Feedback on Clean Hydrogen Production Standard (CHPS) Draft Guidance}}, publisher = {Earthjustice}, year = {2022}, month = nov, url = {https://earthjustice.org/wp-content/uploads/earthjustice-et-al_comments-on-chps-guidance.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }