POWER September 2023 - S25

SEPTEMBER 2023 | WWW.POWERMAG.COM
mitting, and materials compatibility-remains
an obstacle " and some
producers continue to struggle to find
offtakers with sufficient hydrogen
demand willing to sign long-term contracts.
Furthermore, the weight and
volume of hydrogen storage systems
required to safely transport and store
hydrogen can be cost-prohibitive. To
underscore these challenges, the Hydrogen
Roadmap notes data from California
which shows the delivered cost
of hydrogen to fueling stations can be
more than three times higher than the
cost required to be competitive.
The Hydrogen Roadmap emphasizes
that logistical costs need to " fall significantly
compared to their current
level if hydrogen is to become competitive
from a sustainable, market- driven
perspective. "
Strategies and
Implementation
The Hydrogen Roadmap identifies
three strategies " to ensure that clean
hydrogen is developed and adopted as
an effective decarbonization tool and
for maximum benefits for the United
States. " These three strategies are:
(1) target strategic, high-impact uses
of clean hydrogen; (2) reduce the cost
of clean hydrogen; and (3) focus on regional
networks.
The first strategy addresses the use
of hydrogen in industrial applications
such as chemicals and steelmaking,
transportation, and the power sector.
The
second
strategy
Guidelines and Standards. The Hydrogen
Roadmap identifies a variety
of steps DOE will take to address areas
where uncertainty stands in the way of
advancement of hydrogen projects and
technologies.
For example, DOE is developing a
Clean Hydrogen Production Standard,
which will serve, among other things,
as a guide for the Regional Clean Hydrogen
Hubs and the Clean Hydrogen
Research and Development Program.
The standard will (1) support clean hydrogen
production from specified low
carbon energy sources (including but
not limited to fossil fuels with carbon
capture and sequestration; hydrogen-carrier
fuels (including ethanol
and methanol), renewable energy resources,
including biomass, and nuclear
energy); (2) define " clean hydrogen "
to mean hydrogen produced with a carbon
intensity equal to or less than 2 kilograms
of carbon dioxide-equivalent
produced at the site of production per
kilogram of hydrogen produced; and (3)
consider " technological and economic
feasibility. " DOE aims to establish this
standard sometime between 20232025.
DOE
will also: (1) lay the regulatory
contemplates
reducing the cost of clean hydrogen
to $1 per kilogram in the next decade.
The third strategy focuses on
achieving large-scale, commercially
viable deployment of clean hydrogen
by matching the scaleup of clean hydrogen
supplies with growing regional
demand.
To implement the strategies, the Hydrogen
Roadmap identifies actions the
federal government is undertaking to
achieve the benefits of clean hydrogen:
Funding. As described above, the
IRA and BIL provide significant funding
support for clean hydrogen projects
and technology development and deployment.
groundwork
for large-scale clean hydrogen
deployments across production,
processing, delivery, storage, and
end-use; (2) develop streamlined guidance
on hydrogen pipeline and largescale
project permitting; (3) address
challenges to increase supply of electrolyzers
available for renewable and
nuclear energy efforts; and (4) develop
national guidance for hydrogen blending
limits.
Notwithstanding these promised
government actions, the Hydrogen
Roadmap does not address certain
critical issues, such as the definition
of clean hydrogen used to determine
eligibility for the clean hydrogen PTC.
For example, it is unclear whether hydrogen
production powered by nuclear
energy qualifies. The question of
" additionality, " whether hydrogen production
needs to be powered by additional
clean energy sources, and how
that would even be measured, also rewww.re-plus.com
mains
open. DOE Secretary Granholm
has stated it is something that is being
weighed by DOE but she has not provided
an indication of where DOE will
land on this topic as it is very likely to
influence the IRS's view of clean hydrogen
under the PTC.
Research. The Hydrogen Roadmap
offers conceptual summaries of research
that government can foster to
fill technological gaps. For example,
the Hydrogen Roadmap addresses research
and development for uses of
hydrogen in medium- and heavy-duty
trucks, rail, maritime transportation,
and aviation, as well as for the deployment
of regional hydrogen networks.
Community Engagement. DOE describes
guiding principles for defining
success in communities in which hydrogen
technologies will be deployed. DOE
also plans to develop and implement
frameworks for broad and inclusive
community engagement, with specific
focus on environmental justice and disadvantaged
communities. The purpose
of these efforts will be to ensure broad
participation and to gather stakeholder
feedback. The Hydrogen Roadmap
does not address how DOE will balance
its community engagement objectives
with other priorities, such as streamlined
permitting and regional network
location preferences.
Observations and Conclusion
The Hydrogen Roadmap provides a
useful overview of the burgeoning
clean hydrogen industry in the U.S.
and throughout the world, as well as
the critical steps needed to push these
efforts forward. It notes the transformative
potential that hydrogen offers
to support decarbonization efforts and
the significant financial and regulatory
support that the federal government
is providing to help with these efforts.
However, the Hydrogen Roadmap also
notes the significant challenges that
lie ahead, and the need for active engagement
by industry, the government,
and other stakeholders to ensure the
broad commercial success of hydrogen
through many different forms.
-Members of the legal team at
King & Spalding.
25
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POWER September 2023

Table of Contents for the Digital Edition of POWER September 2023
