Even some US EPA rule proponents skeptical of hydrogen in power sector

Clean energy technology advocates are warning US regulators that hydrogen co-firing is an imperfect compliance measure for proposed CO₂ emissions caps for power plants, with some arguing that carbon capture is the more realistic option.

Even if technically feasible, hydrogen blending is an inefficient way to decarbonize the power sector and could even increase emissions if the US Environmental Protection Agency does not set stringent standards for "low-greenhouse gas" or "clean" hydrogen, the advocacy groups said.

Hydrogen industry groups, however, say such stringent standards would hamper producers' ability to meet utility sector demand.

The viewpoints were among the million-plus comments the EPA received by the Aug. 8 deadline for feedback on a May proposal to limit the CO₂ emissions of baseload coal- and gas-fired power plants. If implemented, the rule would create a de facto mandate for certain units to install carbon capture systems or blend clean hydrogen into their natural gas feedstock.

While clean technology experts said the requirements for using carbon capture are feasible, they were less willing to defend the EPA's proposed alternative for gas-fired plants, which is hydrogen co-firing. To comply, power plants must burn at least 30% low-greenhouse gas hydrogen by 2032 and 96% by 2038.

Some power producers were already pursuing hydrogen blending before the rule's proposal. One early mover, the Intermountain Power Agency, plans to incrementally increase the amount of hydrogen burned at its Intermountain power plant to reach 100% by 2045.

But the Breakthrough Institute is discouraging the EPA from considering clean hydrogen co-firing a "best system of emissions reduction" for gas plants, arguing that the scarce resource should be prioritized for other applications, such as fertilizer production and heavy-duty transportation.

"Even if cheap, green hydrogen is widely available by the beginning of the 2030s, using it to co-fire natural gas plants would be to misuse an otherwise valuable resource," the Breakthrough Institute, an environmental research group, wrote to the EPA. "It is not at all clear that hydrogen blending for power generation is technologically feasible at the scale modeled by the EPA."

The group cited a 2022 study commissioned by California regulators that found even small fractions of hydrogen in natural gas pipelines — less than 5% — raise the risk of embrittlement and gas leakage.

In joint comments, the Clean Air Task Force and Natural Resources Defense Council did not dispute hydrogen blending's technical feasibility but found it cost-ineffective, with the exception of low- and intermediate-load gas generation. For baseload gas units, the groups urged the EPA to recommend only carbon capture and storage (CCS).

Hydrogen's "use in this rule should be focused only where there is not a better alternative, and only where it can be assured that hydrogen has been produced with truly low-[greenhouse gas] emissions," the two groups said.

Industry response

Even some hydrogen advocates are urging regulators to temper their expectations, depending on how the EPA defines clean hydrogen. The Renewable Hydrogen Alliance said it was "concerned with EPA's optimistic projections" of clean hydrogen supply, asking the agency to adopt a higher CO₂ emissions cap of 4 kg CO₂e per kilogram of hydrogen produced. The US Inflation Reduction Act, by comparison, limits clean hydrogen producers to 0.45 kg CO₂e to receive the full $3/kg tax credit.

The EPA power plant debate comes as the hydrogen industry lobbies against tough standards for the $3/kg incentive. The US Treasury Department is poised to release guidance on the incentive that could require hydrogen producers to procure new clean power capacity to claim the necessary emissions reductions. The safeguards are supported by environmental groups, but trade groups say the rules will hinder clean hydrogen deployment.

If implemented, "these restrictions will put such a chilling effect on the ability to scale the production of clean hydrogen that it is unlikely that needed supply would be available for the power generation sector or any other sector seeking to decarbonize," the Renewable Hydrogen Alliance told the EPA.

Compliance alternatives

The EPA's May proposal was a long time coming for CCS advocates, who argued that the technology is mature despite a history of cost overruns at coal-fired power plants.

Carbon capture groups Global CCS Institute and Carbon Capture Coalition defended CCS's legitimacy, noting successful applications of the technology in other industries.

While the Carbon Capture Coalition — whose members include the Clean Air Task Force, utilities and oil producers — stopped short of endorsing the EPA rule, it agreed with the EPA's assumption that a carbon capture retrofit can be done within five years, "provided no obstacles are presented." The coalition urged the EPA to specify the consequences for delays "outside the owner's control," such as permitting queues.

The comments run counter to those of the utility trade group Edison Electric Institute, which told the EPA that CCS is neither "adequately demonstrated" nor cost-effective. The proposed rule would require large coal- and gas-fired units to capture at least 90% of their CO₂ emissions by 2030 or find another way to comply with emissions caps.

But even as clean energy advocates defended carbon capture's technical feasibility, some, including the Breakthrough Institute, questioned the EPA's "rather heroic cost figures" for CCS.

"Modeling of carbon removal technologies should account for the high costs of existing technologies and elaborate on how scaling and learning are expected to occur before the model deploys lower cost technologies in the 2030s," the research group said.

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