Delaware Riverkeeper Network

File:  ltr to Congress, 76 scientists 2012.pdfResource Type: Letters

File:  ltr to Congress, 76 scientists 2012.pdfResource Type: Letters

File:  20240318 - Reply from OCED re MACH2.pdfOngoing Issues: Mid-Atlantic Hydrogen Hub

File:  20240326 - DRN testimony DOT, IRS, 45V.pdfOngoing Issues: Mid-Atlantic Hydrogen Hub

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Give the Dept. of Energy an Earful on the Mach 2 Hydrogen Hub!

April 10 virtual “Listening Session”: an opportunity to sound off!

The U.S. Department of Energy’s Office of Clean Energy Demonstrations (OCED) is holding a virtual public “listening session” for the Mid-Atlantic Hydrogen Hub (MACH2) on April 10 at 6pm. To be assured a speaking spot, click here to register for this session. The deadline to sign up is April 7.

To show that the government is attempting to “engage communities” OCED is holding sessions about the 7 hydrogen hubs proposed across the nation. The session for MACH2, to be held April 10, is a platform we can use to bring up our concerns. It is important they hear from the public, particularly people who are expected to live with the hydrogen projects that they are planning to build as part of MACH2 since the MACH2 leadership has been negligent in reaching out to frontline communities for input. This was starkly illustrated at MACH2’s March 11 public meeting at the Steamfitters Hall that was designed to exclude frontline communities from attending or being part of the day’s agenda.

OCED is insisting that community engagement and benefits are the top priority in deciding whether the hydrogen hubs will actually receive the funding that has been promised. But here in the footprint of MACH2, in Pennsylvania, New Jersey and Delaware, there has been no opportunity for input or expression. So little information about the components of MACH2 have been made available, leaving communities in the dark. This is not new in overburdened communities, this is history repeating itself in the densely populated Delaware River region where hydrogen production facilities, pipelines, storage complexes and power plants would be built on top of stressed environmental justice regions.

See some suggested talking points for your testimony below and to find out more, go here for information about MACH2 and hydrogen. At this link you will see MACH2 explained and supporting documents such as maps that can help – although there is not a lot of detailed information publicly available yet.

OCED’s virtual Public Listening Session for the Mid-Atlantic H2Hub: April 10, 2024, 6 p.m. ET. Interested in joining? Click here to sign up.

Some suggested Talking Points:

• MACH2 held a meeting on March 11 that excluded many of us who live where hub projects are supposed to be built and made it very difficult for those who did manage to get there; we had to hire buses at our own expense to carry us from more than an hour away in Chester and South Philadelphia for an 8:00 am meeting on a work day. Even though our area is where MACH2 shows hydrogen projects are supposed to be built for their Hub, we were ignored and even discouraged from attending and there was no room on the agenda for us to speak or present information. OCED says that MACH2 is required to demonstrate the quality of their Community Benefit Plan is worthy of funding. This exclusion of frontline communities must be acknowledged by the Dept. of Energy when they evaluate MACH2’s performance. I consider this affront to frontline communities must disqualify MACH2 from receiving any federal funding under the hydrogen hub program. They have failed the first test that DOE had arranged and must be given an “F” for community engagement.
• The Office of Clean Energy Demonstrations (OCED) says that MACH2 is required to engage communities and advance diversity, equity, inclusion, and accessibility. The principles cited in the community benefits plan prioritize “to ensure people impacted by energy development have a role in the decisions that affect their lives”. MACH2 knows nothing about our community, they don’t know the current burdens we are subjected to, the struggles we are engaged in to protect our community, nor the history and ongoing oppression that polluted air and water and an unhealthy environment imposes on us. If OCED understood this, why would you even consider laying further burdens on us? I have a question I want an answer to: Will you cancel plans to build a hydrogen hub project if the community says they do not want it? If not, your environmental benefits and engagement planning is a sham.
• OCED says that MACH2 is required to develop community “relationships” and “community agreements”. They were required to create a Community Benefits Plan in order for MACH2 to be considered for selection as one of the hydrogen hubs, prior to any funding. Since MACH2 was selected and is now in the “negotiation” phase with OCED, I want to see the Plan they produced that won them selection. Guidance from OCED says that MACH2 can share “at their own discretion” the plan they submitted publicly. But there is no copy of that plan available on the MACH2 website and I do not know of any public sharing of the plan or its details. Keeping that plan secret shows a lack of inclusion and relationship-building, the opposite of what MACH2 is supposed to be doing to engage the public. How can we get a copy of the Community Benefits Plan that MACH2 created? Secondly, I want to see the next iteration of that Plan that MACH2 is supposed to prepare and submit to OCED if they are to successfully advance from “Negotiation” to “Phase 1: Detailed Plan” under the Justice 40 rubric, making them eligible to receive the $750 million earmarked for them. Will OCED assist the public in gaining access to the next phase of its Community Benefits Plan before it is submitted, so the public can know what is being said about them?
• The Office of Clean Energy Demonstrations (OCED) says that MACH2 is required to ensure quality jobs are accessible to all Americans. The Dept. of Energy (DOE) says that “energy justice” is “the goal of achieving equity in both the social and economic participation in the energy system, while also remediating social, economic, and health burdens on those disproportionately harmed by the energy system.” DOE further states that “equity” is distinct from equality because equity recognizes that harms and benefits have not been distributed equally, and that just and fair remediation requires responding to these existing imbalances. I think this will require MACH2 to institute an affirmative action program to ensure that people of color and chronically underserved community members have access to fair wage jobs, including at high levels of employment. How will you require labor unions and employers to reach such a goal that to date has been unattainable? Will OCED require MACH2 to carry out an affirmative action hiring program, including within the labor unions?
• The Office of Clean Energy Demonstrations (OCED) says that MACH2 is required to include in their benefits planning “traditionally excluded stakeholders and those most vulnerable to project impacts, including frontline communities”. OCED goes on to say “Recipients of DOE funds should ensure that performance of project tasks within disadvantaged communities meaningfully benefits those communities and does not result in significant or permanent increased negative impacts to the disadvantaged community.” This is at odds with the hydrogen projects MACH2 states it is going to build and operate – specifically facilities that will burn hydrogen, which will emit nitrogen oxides into the air. NOx negatively impacts peoples’ lungs and heart and impairs neurological development. We already have way too much here, especially in the frontline communities in Pennsylvania, New Jersey, and Delaware. NOx also causes smog which is unhealthy and increases atmospheric warming, worsening the climate crisis, undermining the “decarbonization” role of the hydrogen hub. MACH2 is supposed to be clean and green but the MACH2 website itself admits they will combust hydrogen, increasing air pollution. MACH2 must eliminate all projects that burn hydrogen, emit pollution, and endanger the public. Otherwise, MACH2 is just like all the other environmental oppressors that have degraded our water and air quality and they must not be funded by the federal government. 
• The Office of Clean Energy Demonstrations (OCED) says that MACH2 is required to “Reduce negative impacts and harm, especially to already overburdened communities”. I find this wording problematic. The goal of MACH2 and all hydrogen hubs should be to avoid all negative impacts and harm, especially to our already overburdened communities, which OCED as is their priority. There are many threats raised by the buildout of MACH2, including air pollution from burning hydrogen and the dangers imposed by the extremely high flammability, combustibility, and explosive power of hydrogen. The management and handling of hydrogen has never been attempted on the scale of the $7B hydrogen hub program. Transporting hydrogen in pipelines and vehicles, storing it at the levels proposed in the densely populated Delaware River Watershed has not been proven safe. The stakes are very high should there be a release of hydrogen that causes a fire or explosion. The precautionary principle states that when an activity threatens substantial harm, measures to avoid the activity should be taken, even if the even if there is some uncertainty as to the activity’s cause and effect. I think that handling hydrogen as required by MACH2 endangers me and my community and the negative impacts must be addressed through the precautionary principle by avoiding all harm, not only reducing negative impacts. MACH2 cannot be built and operated in a manner that is protective of my community and my environment so it should not receive federal funding and should neo move ahead as a hydrogen hub.
• Hydrogen is an indirect greenhouse gas that prolongs the heat-trapping impact of methane and it leaks uncontrollably, even more than methane. The potential for leaks is not being fully considered by this enormous investment in what is the unmitigatable inefficiency of the earth’s smallest, lightest element. (Howarth, et al. (2021). How green is blue hydrogen? Energy Sci Eng. 2021;9: 1682). The leakage of hydrogen into the atmosphere decreases the tropospheric concentration of hydroxyl radicals (OH), which increases the atmospheric lifetime of methane and its impact on climate (Warwick et al. (2022). Atmospheric implications of increased Hydrogen use. UK Department of Business, Energy and Industrial Strategy (BEIS). If hydrogen were to scale up as promoters call for, leakage rates will increase (Fan et al. (2022). Hydrogen Leakage: A Potential Risk for the Hydrogen Economy. Columbia Center on Global Energy Policy). No matter how you make it, whether green, blue, or pink hydrogen, it will undermine the goal of reducing greenhouse gasses by 2030 (reduction of greenhouse gas emissions by 50-52% by 2030 is espoused by the Biden Administration) and clean energy goals by 2050 and it will further magnify and accelerate climate catastrophe. We cannot afford to waste billions on developing hydrogen as an energy source or waste precious time in the race to combat the climate crisis. The federal government must not waste energy to make hydrogen when we know it is NOT a climate friendly energy solution. MACH2 and the hydrogen hubs must be cancelled. Our nation must focus first and primarily on developing truly clean renewable energy and using it directly to electrify across the entire economy.
• What are the trade-offs that I and my family are expected to live with if MACH2 goes ahead? What about my child, who already suffers asthma from degraded air quality, how does she have a say in this process that is planning to allow pollution from burning hydrogen and the building of a hydrogen pipeline under my home or storage tanks in my back yard? How do you accurately measure the value of human health, the environment, clean air and water, and quality of life against the activities that these companies are planning to carry out in my area? What price are you putting on my life and the lives of future generations who will be forced to live with the pollution and endangerment that MACH2 and the other hydrogen hubs pose? How can our federal tax dollars be used to fund projects that will adversely burden us and our environment? I fail to see how the Justice40 program will protect us from the threats and negative impacts of MACH2, so it must be cancelled.

OCED references are all from OCED Community Benefits Fact Sheet and “Guidance for Creating a Community Benefits Plan for Regional Direct Air Capture Hubs”

YOUR VOICE MATTERS!

THANK YOU FOR TESTIFYING AT THE MACH2 HYDROGEN HUB PUBLIC SESSION!

 

File:  20240311 - Questions Submitted to MACH2 and Gov Shapiro.pdfOngoing Issues: Mid-Atlantic Hydrogen Hub

File:  20240311 - MACH2 Mtg Public Handout.pdfOngoing Issues: Mid-Atlantic Hydrogen Hub

File:  20240311 - Press Release - Communities Occupy MACH2 Hydrogen Hub Meeting.pdfResource Type: Press

File:  20240222 - MACH2 response to DRN.pdfOngoing Issues: Mid-Atlantic Hydrogen Hub

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Wharton State Forest is the largest state forest in New Jersey. It encompasses tributaries of the Rancocas Creek and Mullica River, as well as the Kirkwood-Cohansey Aquifer. As a popular outdoor attraction, Wharton State Forest receives many visitors who enjoy swimming, camping, biking, horseback riding, and a variety of other outdoor activities. 

With frequent visitors come the many Jeeps, SUVs, pickup trucks, and ATVs by people traveling to and throughout the forest. While driving a licensed vehicle is permitted in Wharton State Forest (ATVs and dirt bikes are not permitted), myriad sand paths and poor road demarcation have created confusion as to which roads are or are not intended for vehicles. Visitors engaging in off-road driving has resulted in running over of animals like frogs and snakes, muddying waters, collapsing streambeds, and destroyed vegetation including threatened and endangered plants. 

To address this problem, the New Jersey Department of Environmental Protection (NJDEP) has created a map that illustrates 200 miles of routes designated for vehicles. The map is not intended to block access to visitors, but instead clarify which paths are intended for vehicles in order to protect environmentally sensitive areas from harm. Routes included on the map will also facilitate focused routine maintenance by the State Park Service, enhancing the visitor experience and improving access for emergency response personnel.

The maps may be viewed HERE.

NJDEP is accepting comments until March 9th, 2024. This is your chance to weigh in and let them know that you support established vehicle routes for the protection of streams, wetlands, plants, and animals. Submit your comments HERE

File:  20240131 - Sign On Letter to OCED, DOE re MACH2.pdfOngoing Issues: Mid-Atlantic Hydrogen Hub

File:  20240216 - Org Sign On Letter to OCED,DOE, re MACH2 Meetings.pdfOngoing Issues: Mid-Atlantic Hydrogen Hub

Image: Body: Tell the federal government we don’t want to subsidize dirty hydrogen and we want meaningful public input! Please submit a written comment to the federal government today!
Deadline February 26, 11:59pm.

Please take a few minutes to submit a written comment to the Internal Revenue Service (IRS) on the proposed rules that would govern how our tax money is being doled out for the “hydrogen Hubs” that the Dept. of Energy is bankrolling. The “proposed regulations relating to the credit for production of clean hydrogen (clean hydrogen production credit)” under 45V of the Internal Revenue Code. 88 Fed. Reg. 89,220 (Dec. 26, 2023) (“Proposed Rule”) has tens of billions in tax subsidies that would go to energy providers and we don’t want greenwashed dirty energy to profit.

What’s more, the IRS is providing only one public hearing on the Proposed Rule set for 10:00am, March 25, and you must register to speak by March 18 by sending an email to publichearings@irs.gov. IRS may even cancel the hearing if they don’t receive the outlines they require by March 8 (See the Proposed Rule here). This sole hearing will be held in-person in Washington, DC with a telephonic option for non-local participants. This is not, by any stretch of the imagination, providing opportunity for sufficient public input. We need more hearings and more public participation.

The Proposed Rule has some strict requirements that some special industry interests such as fossil gas providers are trying to get eliminated so they can use these subsidies to develop more hydrogen made from gas and other dirty fuels. There are also dangerous loopholes in the proposed rule that must be removed. We must fight back to make these rules as strict as possible. Below are some talking points calling for strengthening of the rules.

 

Please act now by submitting a written comment here.
(Make sure to reference IRS and REG–117631–23)
It’s best to personalize your comment by adding some information about why you care, why this is important to you.
You can use any or all of the suggested points below – just copy and paste into the form.

 

Some Suggested Talking Points:

• More public input! I want the Internal Revenue Service (“IRS”) to: hold additional public hearings in, at minimum, each of the seven regions where hydrogen hubs have been proposed; provide virtual options where people can speak on the record; clarify the process for participation and oral comment at its public hearing(s) NOW. There is one public hearing scheduled but its scheduled after the comment period has ended and will be held at the IRS’s discretion, if they judge the comments to warrant it, and it’s unclear how people can take part virtually. This is unfair.
• IRS must not allow greenwashing to exploit these credits! The 45V hydrogen tax credit could have enormous impact on me and my community. If not implemented carefully, this credit could increase emissions and embed polluting practices in environmental justice communities.
• No Biomass pollution! I oppose woody biomass being used as a feedstock to make hydrogen, as the draft rule allows. The cutting, transport, and gasification of woody biomass to make hydrogen is a carbon-intensive process that releases large amounts of planet-heating CO2 and toxic air pollutants, worsening the climate emergency and harming public health. The draft rule also subsidize biomass-powered electricity used for hydrogen production, despite this production being more carbon intensive than the statutory requirement. Biomass power plants are more carbon-polluting at the smokestack than coal per unit of electricity produced and often concentrate pollution in communities of color and low-income communities, worsening environmental injustice. This dirty energy source must be eliminated from the rule.
• The rule needs to be strong – no fudging! We need you to ensure that the final rule maintains the “three pillars” that are supposed to prevent dirty and inefficient energy. The proposed rule states three pillars of “additionally, deliverability, and hourly time-matching”. Treasury and the IRS have rightfully identified that without these principles, hydrogen production from electricity would far exceed the carbon emissions requirements of the 45V tax credit. Treasury and IRS must ensure that the final rule strictly maintains these three pillars.
• No Loopholes! The proposed rule delays the implementation of “hourly time-matching” until 2028, which is concerning and unnecessary. You must enforce hourly matching without delay or polluters will undermine the program’s potential benefit and turn this credit into a counterproductive subsidy to Big Oil. Additionally, you must not bend the crucial three pillars of hydrogen by exempting nuclear power plants from the “additionally” requirement. This will serve as nothing but a bailout for the toxic nuclear fleet.

Thank you for commenting on this proposed rule!

 

 

File:  20240221 PR Organizations File Objections to MACH2 Hydrogen Hub.pdfResource Type: Press

File:  20240220 Attachments to comments on EPA HQ-OW-2023-0222.pdfOngoing Issues: Dissolved Oxygen Criteria

File:  20240220 Comment on EPA HQ-OW-2023-0222.pdfOngoing Issues: Dissolved Oxygen Criteria

File:  20231103 PR DRN Impugns LNG Task Force Report.pdfOngoing Issues: Chester PA: Penn America Energy Proposed LNG export project

File:  20231031 LNG Task Force Minority Report.pdfOngoing Issues: Chester PA: Penn America Energy Proposed LNG export project

File:  20240212 - CBD HorseshoeCrab Petition - Dept of Commerce - ESA.pdfOngoing Issues: Red Knot and Horseshoe Crabs

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Please Join Us!
Hydrogen Hub MACH2 Webinar focused on community engagement
7:00pm to 8:00pm, Monday February 26

REGISTER HERE. (Registration is required)

After registering, you will receive a confirmation email containing information about joining the webinar.

Featuring community activists from hydrogen hub impacted regions: Zulene Mayfield, Founder, Chester Residents Concerned for Quality Living; Ari Eisenstadt, Energy Justice Manager at the California Environmental Justice Alliance; Tracy Carluccio, Deputy Director, Delaware Riverkeeper Network; and Anneke van Rossum, Advocacy and Policy Coordinator, Delaware Riverkeeper Network.

Scant information has been available about MACH2 and the other “hydrogen hubs” planned across the nation; most of the details have been kept secret. On the Powerfully Engaging MACH2 Communities webinar we will hear from community representatives from three areas about their concerns regarding impacts they would be expected to live and work with and their ideas for how to meaningfully influence the decisions being made about MACH2. Their frontline perspectives form what should be the foundation of the MACH2 public process.

The Mid-Atlantic Hydrogen Hub (MACH2) is being proposed as one of seven hydrogen hubs that is slated to receive a total of $7B in federal funding administered by the Department of Energy and its Office of Clean Energy Demonstrations. MACH2 would receive $750M and is a constellation of projects planned to be located in the Delaware River Watershed, centered in Southeastern Pennsylvania, Southern New Jersey, and Delaware. How the hub components will impact communities, air and water quality, and precisely where the hydrogen hub elements would be built is largely unknown. But research has revealed some details and we will discuss what we are learning on the webinar.

Delaware Riverkeeper Network is presenting a webinar series on various aspects of MACH2, sharing information about hydrogen production, transport, storage, and use and about what constitutes the hub, its environmental and public health and safety footprint, and the implications for the climate crisis.

Go here for more information on MACH2.

Please join us to learn more, ask questions, and get engaged!

REGISTER HERE. (Registration is required)

Zulene Mayfield is the driving force behind Chester Residents Concerned for Quality Living (CRCQL) with a goal to ensure that families in Chester live free from polluting industries. She and other residents founded CRCQL in 1992 in response to the construction of the largest trash incinerator in the country, which moved in just a block down from her neighborhood. Despite personal attacks, hostility and pushback from industry groups and politicians over the decades, Zulene has remained committed to fighting for environmental justice and for the health of all those living in Chester City. Ari Eisenstadt (pronouns he/him) is an Energy Justice Manager at the California Environmental Justice Alliance (CEJA). Ari works with CEJA member organizations to build community power towards shutting down gas-fired power plants with the Regenerate California coalition. Ari has experience in youth education in New York City, in advancing campaigns for nature access and equitable climate policies in Washington, DC, and has an academic background in chemical oceanography and climate science. Ari grew up in Brooklyn, NY and now lives in Los Angeles with his partner, cat, and a community of loved ones. Tracy Carluccio is Deputy Director of the Delaware Riverkeeper Network (DRN), where she works as an environmental advocate since 1989, working throughout the Delaware River Watershed in New Jersey, Pennsylvania, New York, and Delaware. Anneke van Rossum is the current Advocacy and Policy Coordinator at Delaware Riverkeeper Network where her role focuses on directly assisting the Deputy Director and researching developing pollution, legislation, and working on community organizing initiatives.