Hydrogen Energy: A Critical Review to Ensure Community and Climate Benefits Open Access

As the United States grapples with the urgent need to transition away from fossil fuels, hydrogen has emerged as a potential solution to the climate crisis. The federal government has announced a total of $9.5 billion for funding through the Infrastructure Investment and Jobs Act (2021) with $7 billion specifically for “clean hydrogen hubs” and an additional $4.7 billion in tax credits as part of its promotion of hydrogen as a clean energy solution (Joint Committee on Taxation, 2023). Long used as a chemical commodity, hydrogen is now being promoted as a major energy source capable of decarbonizing sectors that are difficult to electrify, such as heavy industry and long-haul transportation. However, the implications of hydrogen production and use are far from straightforward, and its potential to either perpetuate or rectify environmental injustices depends critically on how it is implemented.

Just Solutions, a BIPOC-led national nonprofit, works with frontline communities to shape federal implementation to advance healthy, resilient communities and accountable democratic institutions. Recognizing the complexity, scale, and stakes involved, Just Solutions, in partnership with community organizations located in areas where hydrogen energy is to be sited, initiated a nearly year-long collaborative process to develop a Hydrogen Environmental Justice Framework for evaluating hydrogen as a clean energy technology. This community-created and directed analysis was designed to ensure that hydrogen does not simply become another false solution that exacerbates existing inequities. Instead, it provides communities with the tools to critically assess hydrogen projects and their impacts, empowering them to make informed decisions that prioritize their health, safety, and environmental well-being (Just Solutions, 2024).

At the heart of this framework is a deep commitment to environmental justice. The United States’ reliance on fossil fuels has been a central cause of both the climate crisis and environmental injustice, disproportionately impacting marginalized communities. Hydrogen, if not carefully managed, could continue this legacy of harm. The environmental and social impacts of hydrogen are highly dependent on the methods of production, the inputs used, and the specific applications for which it is employed. For instance, hydrogen produced from renewable resources—known as green hydrogen—offers significant environmental benefits. However, hydrogen derived from fossil fuels, even with carbon capture, risks perpetuating the same environmental injustices that have plagued frontline communities for decades.

Hydrogen is now emerging as a favored energy source following decades of building interest among policymakers and industry, driven by concern about energy independence, greenhouse gas emissions, and economic growth. The United States’ energy policy has included support for hydrogen since the passage of the Energy Policy Act of 1992 (1992), which included hydrogen in its definition of “alternative fuel” in the context of reducing demand for imported oil and the environmental impacts of the energy system as well as maintaining the United States’ technological competitiveness. Later congressional updates to the Energy Policy Act, executive actions, and state efforts established further policy support for hydrogen. In 2021, Congress enacted Infrastructure Investment and Jobs Act (2021), providing $9.5 billion in funding to support hydrogen, and in 2022, the Inflation Reduction Act (2022) was passed, which includes hydrogen production tax credits that industry can claim $3 per kilogram of qualified clean hydrogen produced. Traditional energy companies, including oil majors like ExxonMobil, Shell, BP, and Chevron, have invested in hydrogen production and proposed projects in communities that are already overburdened with pollution. These communities were not meaningfully involved before developers, along with their state and local government partners, applied to the U.S. Department of Energy’s (DOE) $8 billion Regional Clean Hydrogen Hubs competitive grant program (DOE, 2023c). Congress required that the selected hubs reflected geographic diversity and a range of feedstocks, including methane gas and nuclear. Given the localized environmental and health issues associated with such feedstocks, along with the emerging nature of this technology and lack of a comprehensive regulatory scheme to ensure safety, frontline communities were concerned about the impacts and potential outcomes of these proposed projects.

The Hydrogen Environmental Justice Framework emphasizes the importance of evaluating hydrogen’s impacts at various geographic scales. While hydrogen may offer net global benefits in reducing greenhouse gas emissions, local negative impacts can still be significant, particularly in communities where production facilities or infrastructure are located. These impacts must be weighed against potential alternatives that might offer lower overall environmental footprints or greater climate mitigation benefits with similar inputs or both.

Central to this framework is the principle that community consent is always essential, even when global benefits are at stake. Too often, decisions about energy infrastructure are made without the meaningful involvement of the communities most affected. This framework seeks to change that by ensuring that community voices are not just heard but are central to the decision-making process. Only by involving communities from the outset can we ensure that hydrogen projects are designed and implemented in ways that truly serve the public good.

Ultimately, the Hydrogen Environmental Justice Framework provides a critical lens through which to evaluate hydrogen as part of the broader clean energy transition. It is a tool for communities to ensure that their needs and concerns are prioritized in the pursuit of climate solutions. By carefully evaluating hydrogen projects through this framework, we can work toward a future where clean energy not only addresses the climate crisis but also advances environmental justice, protecting marginalized communities from further harm and ensuring a just and equitable transition.

The use of hydrogen as an energy source is one of the most complex issues facing the energy transition. Even though it is a major chemical commodity, hydrogen is not used as an energy source today. The main reason is cost: hydrogen is made from primary energy sources like natural gas and coal, which are generally cheaper and more efficient to burn directly.

The present interest in hydrogen arises from the fact that it emits no greenhouse gases when used as an energy source, though it does create nitrogen oxide pollution when burned. It is also a flexible fuel that can be used in a wide variety of applications and can be stored for months in large amounts at relatively modest cost. This long-duration storage aspect makes it especially attractive in an energy system consisting mainly of variable sources like solar and wind (Mayyas et al., 2020). Yet, hydrogen as an energy source presents a number of challenges, including climate impacts and large water requirements for its production, as well as cost and adverse environmental justice impacts. The various costs, benefits, and challenges need sound technical analysis as part of the basis on which communities can make decisions on whether to host hydrogen facilities and, more broadly, on how hydrogen compares with other decarbonization choices. This analysis is explored in detail elsewhere (Makhijani & Hersbach, 2024), with important points summarized here.

Though hydrogen is not a greenhouse gas, it does have an indirect climate impact in three ways via chemical reactions in the atmosphere (Ocko & Hamburg, 2022):

Hydrogen reacts with hydroxyl radicals (OH^•), which are a highly reactive trace constituent of the atmosphere and the principal chemical cleansing mechanism of pollutants. By consuming OH^•, hydrogen reduces the amounts available for breaking down methane, which is a greenhouse gas second only to carbon dioxide in terms of its climate warming impact (Intergovernmental Panel on Climate Change, 2021). Consequently, hydrogen emissions effectively increase the atmospheric lifetime and warming impact. This effect constitutes about half the warming impact of hydrogen. A series of chemical reactions of hydrogen leads to the formation of tropospheric ozone, which is both a pollutant and a greenhouse gas. This is responsible for about 20% of the warming impact of hydrogen. When hydrogen crosses into the stratosphere, it is converted into water vapor, which is a greenhouse gas. Hydrogen-derived water vapor accounts for approximately 30% of hydrogen’s warming impact. A 20-year global warming potential of 33 can be imputed to these impacts of hydrogen (Ocko & Hamburg, 2022).

About 95% of the hydrogen in the United States is produced by using a process called steam-methane reforming (DOE, 2020). This method uses natural gas, which is almost all methane.

Figure 1 shows the warming impact of various ways of producing hydrogen in kilograms of CO₂-equivalent, compared to burning a gallon of gasoline. Note that the hydrogen-related bars represent production emissions, whereas the remaining bar represents the consumption of a gallon of gasoline. The latter bar is therefore strictly shown for illustrative purposes.

The DOE “clean hydrogen production standard” of 4 kilograms of CO₂-eq emissions per kilogram of hydrogen (DOE, 2023b) is shown in Figure 1, for reference. This is still a substantial level of emissions but far lower than present fossil-based hydrogen production methods. It is noteworthy that blue hydrogen does not meet the DOE’s clean hydrogen standard.

Hydrogen is a very flexible fuel and can replace fossil fuels in a variety of ways: it can be burned in turbines or used in fuel cells to generate electricity; it can be burned for space and water heating; it can be used in fuel cells to power trucks and buses; or it can be used in industry as a substitute for fossil fuels, most notably in steel production from iron ore. When evaluating these uses, there are some fundamental considerations about where hydrogen may be beneficial for decarbonizing the energy system and where better alternatives are available.

The first basic technical consideration is energy efficiency. Electrolysis is 50% to 80% efficient (Shiva Kumar & Lim, 2022), and each subsequent processing step (compression, transportation, and use) also involves losses (Krieger et al., 2024). As a result, the overall efficiency of storing green energy as hydrogen and then using it is between 30% and 80%. In contrast, storing and using the same electricity in lithium-ion batteries has an efficiency of 83% to 87% (National Renewable Energy Laboratory, 2022). This means that a given amount of renewable energy can be used to eliminate a significantly larger amount of fossil fuel use if by utilizing battery-centered technology than by using hydrogen-centered technology. In other words, the “opportunity cost” of using hydrogen technologies when efficient battery technologies are available is high, setting back the pace of decarbonization and increasing its cost.

Still, there are areas where the use of hydrogen for decarbonization is beneficial. Notable among these are substituting grey hydrogen by green hydrogen in present-day ammonia manufacture and displacing coking coal in reducing iron ore to make steel. Green hydrogen would slash emissions in both applications (Makhijani & Hersbach, 2024).

There are also a number of hydrogen uses that should be avoided for technical, cost, safety, and environmental justice reasons (Makhijani & Hersbach, 2024). Prominent among these is mixing hydrogen with natural gas to supply buildings. Hydrogen has a far lower energy density per unit volume relative to natural gas (less than 30%). As a result, a volumetric mixture of 80% natural gas and 20% hydrogen only has 86% of the energy of the same volume of 100% natural gas. Consequently, pipeline pressure must increase to maintain the same rate of energy flow, risking increased natural gas leaks (Martin et al., 2024). This risk is further exacerbated because hydrogen molecules are smaller than natural gas molecules and leak at roughly four times the rate of natural gas (Penchev et al., 2022). Hydrogen can also create safety issues by embrittlement of steel pipes and degradation of polyethylene pipes (Penchev et al., 2022). Finally, burning hydrogen creates nitrogen oxides, perpetuating air pollution (Cellek & Pınarbaşı, 2018; Leicher et al., 2022).

Hydrogen has considerable resource and environmental justice considerations (Makhijani & Hersbach, 2024). Notably, all methods of hydrogen production require large amounts of water; that will continue to be the case unless large natural underground reservoirs of hydrogen are found and exploited. Figure 2 shows the water requirements for various methods of hydrogen production. The most water-intensive approach is when thermal electricity generation, such as nuclear power, is used for electrolyzing water. Apart from that, the water requirements for green and blue hydrogen production are similar, and somewhat larger than for the present dominant grey hydrogen.

These water consumption numbers can be large when considered on an economywide scale (Grubert, 2023). For example, the DOE’s “optimistic” hydrogen scenario estimates 50 million metric tons of hydrogen production by the year 2050 (DOE, 2023a). Supplying this hydrogen as 40% blue and 60% green hydrogen would require about 220 billion gallons of water per year (Makhijani & Hersbach, 2024). This would rapidly increase if nuclear electricity is used to make pink hydrogen: a mix of 10% pink, 30% blue, and 60% green hydrogen would increase water consumption to about 350 billion gallons per year (Makhijani & Hersbach, 2024). Siting large-scale hydrogen production therefore presents major issues, notably in water-stressed areas. Hydrogen also raises issues of water rights, as decarbonized societies decide how to reallocate water that is freed up by replacing water-intensive fossil fuel thermal generation by wind and solar energy (Grubert, 2023).

In addition, hydrogen production requires scarce minerals, especially the metal catalysts used to produce hydrogen. These materials include nickel, platinum, and iridium, which are predominantly obtained from the Global South. In these areas, mining often relies on exploited labor, and causes severe environmental degradation. Indeed, platinum mining is paired with high water, conservation, community, land use, and social vulnerability risks (Lèbre et al., 2020). Illustrating this point: a 1-MW proton-exchange membrane electrolysis plant requires 0.75 kg of iridium and 0.075 kg of platinum (Bareiß et al., 2019). In total, mining this quantity of platinum and iridium takes 224,000 liters of water (approximately a tenth of an Olympic swimming pool) in South Africa, which is the main origin of these metals (Buchspies et al., 2017). Being an already water-strained country, South Africa is now seeing conflict between mining companies and frontline communities, to the extent that “platinum belt communities are at risk of becoming green sacrifice zones to satisfy the climate ambitions of Global North countries” (Matsabu, 2022).

There are also environmental benefits when hydrogen displaces fossil fuels. For example, producing coking coal to make iron is a hazardous and polluting industry (Allen et al., 2019). Replacing this coal with hydrogen would produce large health and environmental benefits. Likewise, replacing oil and gas with hydrogen reduces fracking and its serious impacts on water and land resources such as water pollution (Bonetti et al., 2021) and induced seismicity due to reinjection of produced water (Atkinson et al., 2020). These positive impacts would generally occur in places other than those experiencing the negative impacts of hydrogen. For instance, it is of little comfort to South Africans or Indonesians if hydrogen reduces fracking in North Dakota or Texas. Thus, both local and global environmental, resource, and justice impacts need to be evaluated to fully assess the costs and benefits of using hydrogen as an energy source. These include the aforementioned benefits of improved air quality, less seismicity, and reduced pollution that occur when phasing out fossil fuel extraction. Such benefits need to be weighed against local and global drawbacks, such as high local water usage for platinum production (Matsabu, 2022) and pollution from mining, and air pollution from hydrogen combustion.

The Hydrogen Environmental Justice Framework developed by Just Solutions draws from the 17 Principles of Environmental Justice created at the 1991 First National People of Color Environmental Leadership Summit (1991), foundational texts like Robert Bullard’s The Quest for Environmental Justice(2005), and the evolving insights of environmental justice organizers as expressed in contemporary environmental justice frameworks.¹ This framework applies principles such as ecological unity, mutual respect, and community self-determination to ensure that the development of hydrogen energy does not worsen inequities. The framework is rooted in intersectional analysis, acknowledging that environmental injustice disproportionately impacts communities marginalized by race, class, and gender, as outlined by Kimberlé Crenshaw (1989).

As the United States faces the urgent need to transition away from fossil fuels, hydrogen has emerged as a potential solution to the climate crisis. However, the implications of hydrogen production and use are complex and carry significant risks, particularly for historically marginalized communities. Recognizing this, Just Solutions initiated a comprehensive analysis of hydrogen energy, utilizing an environmental justice framework to ensure that the deployment of this technology does not exacerbate existing inequities. The resulting Hydrogen Environmental Justice Framework was developed through a rigorous, community-driven process involving a diverse group of stakeholders. This framework, available in both English and Spanish, is a critical tool for communities navigating the evolving landscape of hydrogen energy.

The research collaborative was carefully designed to prioritize inclusivity, transparency, and shared leadership from the outset. Just Solutions initially outlined a framework that established the project’s purpose, objectives, and resource commitments, setting a clear foundation for collective engagement. A key feature of this approach was the commitment to consensus-based decision-making, significant resource-sharing, and a facilitation process that remained transparent and responsive to members’ needs. As groups joined, they were encouraged to further refine the collaborative’s goals, with assurances of explicit consent before any public association with the project and the freedom to withdraw or express dissent at any stage. To form the collaborative, Just Solutions selected groups recommended by trusted environmental justice partners and staff, with two primary criteria in mind: the technical capacity to conduct a nuanced analysis of hydrogen energy, and a neutral or open stance on hydrogen as an energy source. This thoughtful selection process allowed for a collaborative effort that was both rigorous and responsive to the unique concerns of each community involved.

The foundation of the Hydrogen Environmental Justice Framework lies in the work of the Just Solutions Research Collaborative, a group of nine community-based climate and environmental justice organizations. Just Solutions was deliberate in selecting organizations with relevant experience and a keen interest in hydrogen energy and its societal impacts. The groups were selected based on (1) being recognized as a trusted environmental and climate justice leader; (2) technical capacity to engage in a scientific analysis of hydrogen energy and climate impacts; (3) neutrality or openness to hydrogen energy as a possible solution or part of a just transition; (4) interest or active engagement in a prospective federal hydrogen hub; and (5) geographically representative of prospective federal hydrogen hubs. These organizations were not only knowledgeable about the environmental challenges faced by their communities but also committed to deepening their understanding of hydrogen technology to produce a comprehensive review. Additionally, participating organizations are located in areas where hydrogen hub projects are proposed to be sited. These projects are intended to kickstart a national network of hydrogen producers, consumers, and pipelines to transport hydrogen, and vary widely among factors including geographic footprint, feedstock, and end uses.

The Research Collaborative included representatives from Air Alliance Houston, Communities for a Better Environment, Fenceline Watch, Front and Centered, Ironbound Community Corporation, Just Transition Northwest Indiana, Ohio River Valley Institute, Physicians for Social Responsibility–Los Angeles, and New Mexico No False Solutions. Each organization brought a unique perspective, ensuring that the framework would reflect the diverse experiences and needs of communities across different geographies and sectors. Each group was credited for their contributions in the final framework and identified on the project webpage.

The development of the Hydrogen Environmental Justice Framework was a meticulous six-month process. Just Solutions facilitated and coordinated this effort, ensuring a structured and collaborative environment where all voices were heard. We utilized deep one-on-one sessions with prospective and selective groups, comments and suggested edits through shared documents, periodic collaborative and individual evaluation discussions, sharing regular collaborative notes within a week of meetings, monthly email invitations for feedback, questions, or concerns. The organizations involved were compensated for their time and expertise, underscoring the value of their contributions and the importance of equitable collaboration.

The process began with collaborative members completing a comprehensive content review and compilation of existing environmental justice frameworks (San Francisco Planning Department, 2023; Van Horne et al., 2023). This step was crucial in grounding the collaborative’s thinking in established principles and practices. By building on these foundations, the group ensured that the new framework would be both innovative and deeply rooted in the values of the environmental justice movement.

The next phase involved building a shared understanding of hydrogen technology among Research Collaborative members. Just Solutions worked with research experts Dr. Arjun Makhijani, President of the Institute for Energy and Environmental Research (IEER) and a Senior Fellow at Just Solutions, and Dr. Thom Hersbach from SLAC National Accelerator Laboratory and the Stanford University Woods Institute for the Environment. These experts provided a detailed technical analysis of hydrogen and its proposed applications, outlining the scientific and technological aspects of hydrogen energy, its potential role in a clean energy transition, as well as production methods and applications where its use might be harmful or counterproductive for climate.

One of the most critical aspects of the framework development was the series of learning and discussion sessions facilitated by Just Solutions. These sessions were designed to be interactive and inclusive, allowing Research Collaborative members to engage deeply with the technical analysis provided by the experts. The sessions served as a platform for members to share their questions, concerns, and perspectives, creating a rich dialogue that informed the final framework.

During these 10 two-hour virtual sessions facilitated by lead consultant Joseph Santos-Lyons, participants grappled with the complexities of hydrogen technology, including the different methods of hydrogen production—such as grey, blue, pink, and green hydrogen—and their respective environmental and social impacts. The collaborative also explored the potential risks and benefits initially proposed by our technical research team of hydrogen deployment in various contexts, particularly in communities that have historically been overburdened by pollution and other environmental hazards.

The learning and discussion sessions were instrumental in ensuring that the Hydrogen Environmental Justice Framework would be not just a technical document, but a tool grounded in the lived experiences of frontline communities. As one participant noted, “This process was more than just a collaboration; it was a learning journey. We were able to bring our community’s voice to the table and ensure that the framework reflected our realities and our needs.”

The Hydrogen Environmental Justice Framework is the product of true co-creation and co-authorship. Through the iterative process of learning, discussion, and analysis, Research Collaborative members played a central role in shaping the framework. Just Solutions established and revisited our consensus written agreement with co-authors detailing our developmental timeline of meetings, research and feedback deadlines, regular full group and individual check-ins, and explicit permission for the published framework. Co-authors had input into our group agenda setting, facilitated workgroups that created the framework concepts, and had regular access to our research team and project facilitator. This approach ensured that the final document would be relevant, actionable, and reflective of the diverse communities it was designed to serve.

The framework provides explicit recommendations for evaluating hydrogen energy projects and determining its impact on environmental justice communities. It focuses on key considerations such as the methods of hydrogen production, the potential environmental and health impacts, and the degree of community involvement in decision-making. It also emphasizes the importance of evaluating hydrogen projects at various geographic scales, recognizing that while hydrogen may offer global benefits in reducing greenhouse gas emissions, the local impacts can be significant, particularly in environmental justice communities.

A representative from Fenceline Watch (personal communication, March 1, 2024) highlighted the importance of this approach: “Working with Just Solutions and the Research Collaborative in developing the Hydrogen Environmental Justice Framework allowed us to craft a tool that can be used to advocate for our communities while counterbalancing the prevailing narratives led by industry. This framework gives us the tools we need to engage with the hydrogen industry and ensure that our communities are not subjected to further harm.”

Recognizing the importance of accessibility, Just Solutions has made the Hydrogen Environmental Justice Framework available in both English and Spanish. This decision reflects the organization’s commitment to ensuring that the framework is accessible to a broad audience, including Spanish-speaking communities that are often disproportionately affected by environmental injustices. By providing the framework in multiple languages, Just Solutions aims to empower more communities to engage in the conversation about hydrogen energy and advocate for their rights.

The development of the Hydrogen Environmental Justice Framework is a powerful example of how community-driven processes can lead to more equitable and effective outcomes in the clean energy transition. By bringing together a diverse group of community leaders, technical experts, and environmental justice advocates, Just Solutions has created a framework that is not only technically sound but also deeply rooted in the values and experiences of frontline communities. The process of developing the framework and technical resources leverages the movement’s collective knowledge to achieve just climate outcomes and highlight equitable models that accelerate the ability to address the climate crisis. This work highlights how the leadership of community-based organizations in engaging communities and building collective power and voice is crucial for shaping impactful policy solutions. This framework serves as a tool to foster engagement in our democracy, allowing advocates to self-determine what they want for themselves and their communities.

As the United States moves forward with its clean energy goals, the Hydrogen Environmental Justice Framework provides a critical tool for ensuring that hydrogen energy is developed in a way that is just and sustainable. It challenges us to rethink how we approach new energy technologies and to prioritize the voices of those who have historically been marginalized in the decision-making process.

Our Hydrogen Environmental Justice Framework offers community-based organizations (CBOs) a scientifically grounded tool for evaluating hydrogen projects and claims in the clean energy sector. This framework serves as a practical guide, presenting key facts, highlighting problematic practices, and debunking overstated claims about hydrogen’s potential. Recommendations are structured to help CBOs exercise informed judgment, pinpoint crucial areas for further scrutiny, and weigh both the promises and pitfalls of hydrogen technology. Recognizing that some areas require additional analysis, the framework equips CBOs to critically assess hydrogen’s role in environmental and climate justice work. This tool emerged from a rigorous development process, addressing the challenges and ambiguities surrounding hydrogen, and was created to empower advocates with credible information and guidance.

The growing urgency to address the climate crisis has led to the exploration of various clean energy technologies, with hydrogen being touted as a potential key player. However, hydrogen’s role in mitigating climate change is fraught with complexities, particularly regarding its production methods, environmental impacts, and implications for environmental justice communities. This community-created and collaborative resource aims to support climate and environmental justice advocates in advancing the most effective clean energy technologies while guarding against false solutions that could harm their communities. The analysis, developed through a community-directed process, pairs an environmental justice framework with a technical review of hydrogen energy’s environmental impacts and benefits. It equips communities with the values and criteria needed to evaluate hydrogen energy projects critically, ensuring decisions that protect marginalized communities and promote just solutions to the climate crisis.

The Research Collaborative outlined 10 key criteria and considerations in the Environmental Justice Hydrogen Framework for siting and implementing hydrogen energy projects. They include: 1. Ban New Hydrogen From Fossil Fuels; 2. Produce Only Green Hydrogen; 3. Require “Additionality” for Hydrogen Produced Using Decarbonized Electricity Sources; 4. Safeguard Water Resources; 5. Ensure Safety; 6. Protect Against Risks From Feedstock Uses in Fuels; 7. Demand Transparency; 8. Ensure Green Hydrogen Uses Are Essential and Beneficial; 9. Take Into Account the Climate Impact of Hydrogen Leaks; and 10. Promote Global Environmental Justice Metrics and Standards. These considerations provide a comprehensive evaluation of hydrogen energy’s potential environmental and health repercussions that are essential to avoid perpetuating environmental injustices.

Hydrogen is increasingly presented by both industry and policymakers as a major tool for mitigating climate change by reducing greenhouse gas emissions across a broad spectrum of end uses. Research Collaborative members scrutinized the assumptions underlying this surging support for hydrogen and responded by developing the criteria and considerations discussed below to establish the minimum standards that hydrogen proposals must meet. These criteria are in no specific order as they each should be considered to ensure the safety of proximal communities. Proposals that fail to protect communities and effectively combat climate change should be rejected.

In considering hydrogen as an energy alternative, we must be aware of the opportunity costs associated with its adoption, especially when hydrogen is chosen over more effective options like direct electrification. Hydrogen’s climate benefits vary significantly depending on the specific application. Careful analysis is necessary to avoid diverting billions of dollars into less efficient hydrogen technologies and applications, which could limit investment in more promising renewable solutions. The environmental impacts of hydrogen production and use depend heavily on the production methods, inputs, and end-use. These impacts can range from perpetuating environmental injustices and fossil fuel dependency to offering net environmental and environmental justice benefits, particularly when green hydrogen replaces fossil fuels.

Hydrogen’s impacts must be evaluated at multiple geographic scales, as its production and use can have different effects depending on the location. Key areas to evaluate by regional hub are: 1) the type of feedstock energy source utilized to produce hydrogen, optimally renewable energy; 2) end-use purposes for hydrogen energy, optimally hard to decarbonize sectors. Even if hydrogen offers net global benefits, localized negative impacts could still be significant, particularly in already vulnerable communities. Therefore, it is crucial to assess hydrogen projects for net global, site-specific, and application-specific impacts, including the consideration of alternative technologies that may offer lower overall environmental impacts or more substantial climate mitigation benefits. Community consent is always essential, even when global benefits are apparent.

Inter-agency Regional Hydrogen Hubs should categorically reject the use of fossil fuel–derived hydrogen, including any hydrogen produced from coal, natural gas, or other fossil sources. This includes hydrogen produced with carbon capture and sequestration (CCS), as such methods continue to rely on fossil fuels and often fail to meaningfully reduce greenhouse gas emissions. Methane leaks, especially when calculated at a 20-year warming potential, reveal that “blue hydrogen” (produced from natural gas with CCS) does not meet climate standards and undermines environmental justice by contributing to water pollution and other harms associated with fossil fuel extraction, particularly fracked gas.

The federal and state Departments of Energy, which oversee the Regional Hydrogen Hubs, must ensure transparency in all decision-making processes. This includes a commitment to clear public disclosures about project evaluations and funding criteria. Additionally, due to the current fossil fuel dependency of the U.S. electricity grid, hydrogen produced from grid-connected electricity should also be scrutinized to prevent indirectly supporting fossil fuel use.

Among the various methods of hydrogen production, only green hydrogen should be considered. Green hydrogen is defined as hydrogen produced from water using dedicated new solar and wind power plants or renewable energy that would otherwise be curtailed. It is also crucial to assess the optimal mix of hydrogen production and other long-duration storage methods, such as seasonal thermal storage, to benefit the energy transition, system resilience, and economic and environmental justice.

Producing hydrogen with electricity from existing grid-connected sources does not eliminate carbon emissions. The original electricity demand must still be met, likely through increased climate-warming emissions from the grid. Therefore, hydrogen production should only be powered by demonstrably additional decarbonized energy sources, to prevent increasing carbon emissions through induced demand for fossil fuel-generated electricity. This approach is vital to upholding climate and environmental justice principles, particularly given the disproportionate impacts of fossil fuel production and use on frontline and environmental justice communities.

Hydrogen production requires significant water resources, and water management must prioritize human rights and community needs. Water policy should uphold the Public Trust Doctrine, the principle that safeguards the public’s use of navigable waters, and serve the broader community rather than specific interest group (State of California, 2025). Proposals for water use must respect the sovereignty and the free, prior, and informed consent of Indigenous communities, in line with doctrines such as the Winters Doctrine, which establishes water rights for Indigenous tribes (Winters v. United States, 1908), and Prior and Paramount Water Rights, which states that the first person to use water for a beneficial purpose has a right to continue using it (Sanchez, 2007).

Water use considerations are particularly critical in regions like the Southwest, where water resources are already stressed. Hydrogen production should not exacerbate these vulnerabilities, especially as climate change further strains water availability. Local water use priorities must be evaluated on a site-specific basis when selecting hydrogen production sites, and water use for hydrogen production should be limited to avoid harming human health and the environment.

Hydrogen presents several safety hazards, including risks of fire and explosion during its production, transportation, storage, and usage. Consistent safety protocols and oversight infrastructure are necessary, but such measures currently lack the robustness required for the widespread adoption of hydrogen technology. The precautionary principle should guide the development of safety regulations to prevent harm due to insufficient knowledge or systems.

Strong safety standards must be maintained across all levels, from global to local, to protect communities equally, regardless of their socioeconomic status. Special attention is required for frontline communities that are already disproportionately impacted by the energy industry. These communities must be meaningfully involved in all decision-making stages, from assessment and planning to implementation and enforcement. Establishing mechanisms for ongoing enforcement, monitoring, and reporting safety incidents is crucial to holding industry and regulators accountable.

It is vital to enforce strict hydrogen safety standards consistently, regardless of the production and transportation scale. This includes pipeline safety, especially if aging natural gas pipelines are repurposed for hydrogen transportation. These pipelines are prone to failure when used for hydrogen, because hydrogen is known to embrittle steel. When combined with stress on steel pipelines due to hydrogen pressure changes, vibration, soil movement, or temperature changes, this hydrogen embrittlement can cause “hydrogen-accelerated fatigue cracking” that leads to pipeline failure (Martin et al., 2024, p. 3995).

Hydrogen may be used as a feedstock, combined with CO₂ to produce synthetic fuels, including jet fuel, to which toxic chemicals like toluene are added. Ammonia, another hydrogen-derived product, has also been proposed as a fuel. However, ammonia emissions contribute to air pollution, including NO_x and PM2.5, and may result in climate-warming impacts greater than burning coal. Exposure to other chemicals involved in producing such fuels presents significant health hazards and environmental risks (Makhijani & Hersbach, 2024).

Preventing and managing emissions from ammonia and other pollutants is essential to protect communities, especially those already overburdened by environmental hazards. Using hydrogen to produce such fuels should be avoided where it would add to the toxic burden on these communities.

Transparency is crucial to realizing the foundational environmental justice principles of self-determination and meaningful involvement in decision-making. Hydrogen project proposals must be based on scientifically validated methodologies and factually accurate, publicly accessible information. This includes comprehensive disclosures of inputs, outputs, and the long- and short-term health, safety, and environmental impacts, particularly those that could increase risks or harm neighboring communities.

Disclosures should include:

• Health, safety, and environmental impacts of all infrastructure directly associated with hydrogen projects, including storage, transportation, and refining.

• Comprehensive reporting of all water and air emissions, including accidental releases from all sources, both stationary and mobile.

• Detailed information on feedstock, additives, and catalysts used in hydrogen production.

• Publicly accessible reports on emissions and chemical hazards.

• All hydrogen projects must implement transparent, timely, and reliable multilingual communications during emergencies, along with early warning systems once the project is implemented.

Hydrogen use proposals should be evaluated and compared to other feasible options, such as energy conservation, efficiency improvements, transmission upgrades, and direct electrification. Green hydrogen should only be considered essential after thorough exploration of other methods. Some hydrogen uses, even when produced as green hydrogen, may be counterproductive or offer marginal climate benefits compared to other renewable energy uses. For example, mixing hydrogen with natural gas for heating could perpetuate environmental and economic injustices and pose safety and leak-related issues.

Hydrogen burning is generally inadvisable from an environmental justice perspective, especially considering air pollution impacts. Direct electricity use is often more efficient than hydrogen in many applications. However, in certain cases, hydrogen could have a positive local and global impact, such as replacing coking coal in steel production. This application could reduce water pollution and increase energy efficiency while significantly lowering greenhouse gas emissions. Even in such cases, alternative approaches, like increasing recycling, should be considered first.

In the longer term, significant amounts of green hydrogen could serve as a method of long-duration energy storage for later use in fuel cells for meeting peaking power needs, when the electricity grid is powered primarily by solar and wind energy. Such hydrogen should be produced using renewable electricity that would otherwise be curtailed, with a focus on water recovery and reuse.

The following hydrogen applications should be avoided (Makhijani & Hersbach, 2024):

• Mixing hydrogen with natural gas, which is a hydrogen use that introduces safety risks and does little or nothing to address climate change.

• Using hydrogen as a fuel for light-duty vehicles or other vehicles where electric vehicle use is feasible, because direct electrification of vehicles is more energy-efficient than using hydrogen, enabling the same amount of renewable energy to accomplish far more decarbonization.

• Short-term hydrogen use for peaking power production when solar and wind energy plus storage can generally meet the need, because short-term storage is more energy-efficient when using batteries than using hydrogen.

• Water-intensive hydrogen production in areas facing water security issues.

Although hydrogen is not a greenhouse gas, it has a significant indirect warming impact. The indirect climate impact of all hydrogen leaks—occurring during production, transportation, storage, and use, especially when combusted or used as a feedstock—must be included in assessing hydrogen projects’ overall climate impact. For implemented projects, leaks must be closely monitored and minimized. Comprehensive system design, including leak prevention and detection measures, is essential to accurately account for the full climate warming impacts of potential leaks.

Hydrogen production requires scarce materials like iridium, platinum, and nickel, depending on the production method. The mining and processing of these materials disproportionately affect the Global South and Indigenous lands. Even when global impacts are positive due to fossil fuel displacement. Global standards are needed; they should be created and enforced.

Throughout the development process, the principles of transparency, equity, and community consent were at the forefront. The Research Collaborative was committed to ensuring that the Hydrogen Environmental Justice Framework would promote transparency in the hydrogen energy industry, particularly regarding the potential environmental and social impacts of hydrogen projects.

One of the core tenets of the framework is that community consent is always essential, even when global benefits are at stake. This principle challenges the often top-down approach to energy infrastructure development, where decisions are made without the meaningful involvement of the communities most affected. The Hydrogen Environmental Justice Framework seeks to change that by centering community voices in the decision-making process.

“Our collaboration with Just Solutions was more than a partnership; it was a dialogue,” said Alex Jasset of Physicians for Social Responsibility–Los Angeles (personal communication, March 2, 2024), “We listened, learned, and co-designed a community-centered framework that prioritized the health and well-being of those on the frontlines of climate change. Our collaborative work will inform communities about new energy technologies and provide vital information on their risks and benefits.”

The Hydrogen Environmental Justice Framework is a vital tool for navigating the complex landscape of hydrogen as a clean energy solution. Developed through a community-driven, collaborative process, this framework ensures that the pursuit of hydrogen technology does not perpetuate environmental injustices or create new ones. As hydrogen is poised to play a significant role in the U.S. clean energy transition, this framework provides essential criteria for evaluating hydrogen projects, with a focus on safeguarding vulnerable communities.

Key principles of the framework include banning fossil fuel–derived hydrogen, promoting green hydrogen for demonstrably beneficial uses, avoiding harmful uses and uses where better alternatives are available, safeguarding water resources, ensuring safety, and demanding transparency. It emphasizes the importance of considering local and global impacts, the necessity of community consent, and the need for stringent safety standards. The framework also calls for transparency in project proposals and the careful assessment of hydrogen’s true benefits versus potential harms.

By prioritizing green hydrogen and rejecting false solutions like fossil-based hydrogen, the framework advocates for a just and sustainable energy future. It empowers communities, particularly those historically marginalized, to engage in decision-making processes and protect themselves from the adverse impacts of energy infrastructure.

As the federal government invests heavily in hydrogen hubs, this framework serves as a guide to ensure that these developments lead to positive environmental and social outcomes. It is a call to action for policymakers, industry leaders, and communities alike to prioritize environmental justice in the clean energy transition.