NEPA and Hydrogen Hubs: Four things to know

To receive funding allocated through the Bipartisan Infrastructure Act, Hydrogen Hub projects will need to comply with National Environmental Policy Act (NEPA) to determine if their proposed actions will have significant environmental effects.

Here are four things to know about how the NEPA process will affect the Hydrogen Hubs:

Programmatic NEPA will likely require a hub Environmental Impact Statement (EIS).

Each hub may take a different approach to complete an overarching EIS or to include the individual projects. Regardless, coordination by the participants with the hub consortium and Department of Energy (DOE) will be through an environmental information volume (EIV). The programmatic NEPA process will establish bounds/limits in coordination with applicable state and federal agencies that would allow individual hubs and activities at hubs to be put in place through tiering to the programmatic document with a Categorical Exclusion (CATEX), Environmental Assessment (EA) or EIS. Bounds can be driven by magnitude or lack of impact, defined through established regulatory guidelines or negotiated through the programmatic NEPA process through agency discussion and collaboration. If an issue is covered in the programmatic NEPA document at a sufficient level of detail, then it may not need to be included in subsequent NEPA documentation for individual projects (greenhouse gas [GHG], traffic, socioeconomic). Alternately, if the issue(s) is/are not completely covered, then the subsequent analysis can be reduced to only cover site-specific details not covered in the programmatic review.

Inclusion of climate change and environmental justice connections.

Recent revisions to the NEPA Implementing Regulations by the Council on Environmental Quality (CEQ) require climate change and environmental justice – including connections between them – be evaluated in all NEPA reviews for projects of the type and scale that are proposed for the Hydrogen Hubs. These requirements will mean more public engagement with stakeholders and likely increased engagement with tribal entities in some locations. Varying levels of NEPA have different requirements for public engagement. For example, the CATEX process may require a simple public notice while the EIS process often includes public meetings and comment periods at certain stages as the effort progresses.

Level of detail needed for NEPA.

Many projects are in the conceptual phase and conducting site-specific or non-programmatic NEPA reviews might be difficult due to a lack of information. Preliminary conceptual designs need to have sufficient information on proposed project details to conduct a site-specific NEPA assessment. The conceptual level will need to be advanced to plot plan, and have an estimated construction timeframe, full operational details, greenhouse gas emissions estimates, water supply and discharge estimate, as well as development of community engagement plans.

Plan to be patient.

Reviews could take time, especially if significant input and coordination with agencies is needed. Early coordination will likely streamline the overall NEPA review process, particularly if operations and maintenance activities and potential future growth are included in the analysis. The up-front investment in money and time is often worthwhile when schedule is an important issue. If a facility is able to include this time ahead of starting construction, the investment will pay off in the long run.

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