Below is the text version for the "Regulation and Permitting of Hydrogen and Natural Gas Pipelines" H2IQ Hour webinar held on August 29, 2024.
>>Kyle Hlavacek: Hello, and welcome to this month's H2IQ Hour webinar. Today, we have a presentation on the regulation and permitting of hydrogen and natural gas pipelines. My name is Kyle Hlavacek with the Department of Energy's Hydrogen and Fuel Cell Technologies Office, supporting stakeholder engagement and other outreach activities.
Please be aware that this WebEx webinar is being recorded and will be published online at our H2IQ webinar archives. If you experience technical issues today, please check your audio settings under the Audio tab. If you continue experiencing issues, please send me a direct message. There will be a Q&A session at the end of the presentation, and attendees have the opportunity to submit questions in the Q&A feature box. You can access the Q&A feature by clicking on the Panel Options or More Options button, depending on your computer's operating system. You are looking for the button with the three dots in the bottom—far bottom right corner of your window. To ensure that your questions are answered, please utilize the Q&A feature and do not add your questions to the chat. If you have trouble using the Q&A feature, please view the link in the chat for help with this issue.
Today's H2IQ Hour webinar was organized by the Hydrogen Interagency Task Force Working Group on Infrastructure, Siting, and Permitting. The Hydrogen Interagency Task Force, also known as HIT, is a collaboration among U.S. federal agencies to advance the national clean hydrogen strategy. With that, I will turn it over to Mark Richards, DOE co-lead on the HIT working group and technology manager on HFTO's infrastructure team. Mark, it's all yours.
>>Mark Richards: All right, thanks, Kyle, and I apologize for not being online at the moment. WebEx decided it didn't want to cooperate today even though everything worked fine yesterday. But moving on…
So, today we'll have a series of presentations pertaining to the permitting processes for natural gas and hydrogen pipelines. At the end of our time today, we'll share a QR code and a link for a questionnaire for participants, the audience. DOE is seeking feedback on the permitting processes used for pipelines today and we welcome your responses to the questionnaire in the coming weeks.
This webinar is also part of a two-part series. The second webinar, not yet scheduled, will occur later this fall and cover community engagement best practices and gaps associated with pipeline deployment. With that, I'll turn it over to our first speaker, Joan Dreskin, Senior Vice President, Secretary, and General Counsel at the Interstate Natural Gas Association of America. Joan, you have the floor.
>>Joan Dreskin: Terrific, next slide please. Well, I'm happy to be here and good afternoon everyone. Who is INGAA? INGAA is the Washington-based trade association representing interstate natural gas pipelines and storage providers. We are the marked blue area in that slide. We transport natural gas or provide storage services for transportation to your local gas utilities, your gas fired generators, your industrial and manufacturing plants, or gas marketers who then sell it elsewhere. We don't own the gas in our system. We don't sell natural gas, we’re transportation and storage only. Next slide please.
Next slide.
Yes, there are around 300,000 miles of natural gas pipelines in the continental U.S. Two hundred thousand miles of those are interstate natural gas pipelines regulated by the FERC. The extra mileage, the extra 100,000, is state regulated. Those are intrastate pipelines. So, while not identified, you can see that it is an integrated web of pipelines that provide customers the ability to access gas from many of our producing regions in the U.S., Canada, and move it to their homes and businesses. Next slide please.
We talked about regulation. And two of our primary regulators are on the phone with us today, and that is FERC and PHMSA.
FERC is our primary economic regulator. It also authorizes the siting and operation of new or expanded gas pipelines. It authorizes construction only if it's in the public convenience and necessity. That's the terminology under the Natural Gas Act. It prohibits overbuilding. We're not allowed to have excess—large amounts of excess capacity. We can't reserve capacity. It sets the just and reasonable cost of service rate for transportation and storage. It approves tariffs. Those are the rules of the road for how much we—how we conduct our business. And it maintains an open access transportation system, meaning that a pipeline must allow access to any customer so long as that customer is creditworthy and willing to abide by the terms of the tariff and pay the cost-of-service rate set forth in the tariff.
And then we have PHMSA. PHMSA is our safety regulator. It establishes the national safety goals and regulations for which we must abide by. Next slide please.
We are heavily regulated when it comes to building and operating interstate gas pipelines. These are just some of the federal bodies, the agencies where we have to get either permits, certifications, authorizations—the terms change—but EPA, Fish and Wildlife Service, Department of Energy authorizes the export for LNG, U.S. Army Corps of Engineers for some of our Clean Water Act certifications and permits. So, we must have all of those. It's not one-stop shopping. Next slide.
So, with regard to the purpose of this seminar, we talked about that FERC regulates natural gas—interstate natural gas pipelines under the Natural Gas Act. And the Natural Gas Act defines "natural gas" as either natural gas unmixed or any mixture of natural and artificial gas. So, clearly FERC has jurisdiction over interstate natural gas pipelines, which means methane pipelines, or natural gas with small amounts of other elements that are mixed in, minor amounts of other constituents. And FERC regulates that almost as if they're contaminants.
Each pipeline has a tariff and all pipeline tariffs have gas quality specifications in them, which detail how much non-methane we are required to accept. And they're usually percentage, and it's the maximum. Most if not all pipelines are allowed to waive portions of their tariff on a non-unduly discriminatory basis, assuming that we can blend greater amounts of those contaminants in with lower-contaminated gas and to get it back to the pipeline volumes and the pipeline specifications. Some pipelines identify limits for hydrogen; others don't. And no pipeline in the U.S. is transporting at this point large amounts of hydrogen.
What I talked about before is that pipelines can blend multiple gas streams from different parts of the U.S. or from different producers, and we can blend it to get back to gas quality specs. Next question—next slide please.
You'll hear from FERC shortly, but there is an open question on who regulates pure hydrogen pipelines. There's a question on whether—is it FERC? I know former Chairman Glick has told Congress that he does not believe that FERC under the Natural Gas Act regulates pure hydrogen pipelines.
We talked about that FERC does regulate blended hydrogen pipelines, blended methane pipelines with small amounts of hydrogen. Could it be the Surface Transportation Board, which regulates freight rail, for example? Is it not federally regulated? Does each state regulate it? And how much hydrogen can be blended into a natural gas pipeline before it becomes a hydrogen pipeline? Those are all open questions. INGAA, the trade association, does not have a position on these questions, but just wanted to raise them.
But what I will talk about—next slide please—is once that jurisdictional question is answered by Congress, most likely, and if others wish to look at the certification and the permitting process of interstate natural gas pipelines as a model, then let's look at how FERC certificates interstate natural gas pipelines because there's a lot of lessons to be learned. Our planning, permitting, and certification process takes on average four years. And there are opportunities for public comment and engagement throughout that process. I know we mentioned that there is a second seminar in the fall on that topic alone.
So, this is a slide—it's a linear slide that we've done. It's on the INGAA website, not chopped up. It's really around five feet long when you put it together. But let's talk about what interstate natural gas pipelines go through. We are a highly competitive business. There's relatively ease of access, meaning that you can enter in competitors, multiple competitors serve major metropolitan areas. You may have five, six, seven pipelines as choices, competitors going into the same market. But approximately 12 to 18 months pipelines spend before doing any formal filings to look at the feasibility of a proposed project: need, feasibility, and effects. And either we reach out to our customers or customers reach out to us and say, "You know what? I need some additional pipeline capacity. It's tight here. I need it for reliability. I need it for whatever reason." And we have discussions on is there a need for that pipeline, that expanded pipeline?
We look through with our customers potential corridors, and we look to identify are there EJ communities that we need to avoid, address, mitigate? What route should we take? And at this point, we're just going from point A to point F. There's no line drawn. And if anything, we start drawing a line in pencil. Could be this, but we're exploring whether there are any concerns with the route chosen. And our customers, of course, want to know how much is it going to cost? And we're doing that engineering work, preliminary work to say, "Hmm, if we size it like this, add compression here, add pipe this way, here's what it could cost." Those are not definite at all because when you add customers or change routes that all changes.
We also engage with regulators at this point with initial discussions on permitting. "Hey, we think we're going to do this. We think—we know we need these kind of permits." Those are initial discussions. And we also hold public meetings, inviting people. "Do you want to come on? Do you want to—would you like to be part of this expanded pipeline or new pipeline? We're looking for business." And as I mentioned, we're open access, so as long as a customer wants us and they're willing to pay the cost-of-service rate we must accept them and we're happy to accept them.
And we start looking at that preliminary route drawn in a very light pencil as to who are the potential landowners that are involved? And we hold, as I mentioned, open houses. We're doing outreach to local governments, to state governments, to community groups, and we're testing the waters and we're starting to do—if we think that we have customers that are interested, customers that think those rates are in line, we're starting to do our surveys or start preparing our resource reports, which I'll talk about in our environmental analyses, which talk about effects. FERC, for example, has 12 resource reports for interstate natural gas pipelines and a 13th if you're an LNG facility. They range from cultural resources to soil to birds and bats to air and noise to need. They are hundreds and hundreds of pages of environmental reviews on potential effects from that pipeline. Next slide please.
For a number of pipelines, particularly those major pipelines, we consider engaging with FERC in a pre-filing process. It's voluntary. It's mandatory if you're an LNG facility, but it's voluntary for pipelines and it's something that many pipelines agree to do because we find a lot of benefit from it. It's a process that takes around 12 months, depending on the size and complexity of a project. You commit to a minimum of six and FERC has to accept you. In other words, they have a right to say, "This is not appropriate." But we find that we get a lot of benefit and I think FERC gets a lot of benefit, as does others. It's a process where we narrow—we identify environmental issues associated with a project or potential concerns, routing concerns, environmental concerns, and we try to work through those concerns so by the time the pipeline files its certificate application, the formal process, that we've hopefully narrowed and identified what issues need to be addressed.
At this point, as I mentioned, we're doing our field services—field surveys. We have a preferred route but we also have alternative routes, which is also required by NEPA. And we are providing and looking at "Do you go through Mrs. Jones' property or do you go through an alternative route? Do you go through a critical habitat facility? Do you go—." Those are the tensions that pipelines are weighing and—but as we go through this process, we narrow down what we think is for us the best route. We're conducting our field surveys, as I mentioned. We're looking at alternatives. We're starting to file these draft resource reports. And we're consulting with interested stakeholders. We're reaching out at this point to landowners that we believe—affected landowners on our, we're holding some—FERC is trying to hold some NEPA scoping meetings and say, "What do you have concerns about with regard to this project?" And there is a public comment period. So, next slide please.
Once we are done with that pre-filing process, we've hopefully identified what the issues are and we actually file our formal certificate with FERC and that's under Section 7 of the Natural Gas Act. Once FERC notices it, everyone, all stakeholders have an opportunity to intervene or just file comments. Intervening can be very, very easy. There is a dockless opportunity that FERC has set up. You don't need a lawyer. You don't need fancy—you just get on. And also, FERC regulations require pipelines to notify all affected landowners of—that we have filed a certificate application and make it available for them to review.
As I mentioned, a lot of access, a lot of opportunity for public engagement, and we at the same time, both by requirement, by regulation, and by best practice are reaching out, explaining about our project and meeting with affected landowners and answering their questions and concerns.
This is FERC's job now. It is a lengthy process where they—as a lead federal environmental regulator under NEPA, the National Environmental Policy Act, they conduct their NEPA analysis on the effects of the project. They either do an environmental assessment or environmental impact statement. Both have an opportunity for public comment. And to give you a frame of mind, some of FERC's EISs, which deal with significant environmental impacts or potential environmental impacts, could be 700, 800, over 1,000 pages. It's going to address all of the concerns, all the comments, the environmental comments about, as I mentioned, the bugs, the bunnies, the bats, the soil, the air, the noise. That's all within that document. And for EISs the public has typically 45 days minimum to comment on that.
Other parts of FERC deal with other areas, such as the rate, the accounting issues, but the bulk of this work is FERC Office of Energy Projects staff. Those are the engineers, those are the environmentalists, the botanists, the air experts that understand all of these issues. And this is typically an 18-month process. Next slide.
There is no deadline, statutory deadline for FERC to issue a certificate, yet I'd argue that FERC tries to act responsibly. Once the environmental work is done it's now for the five FERC commissioners to act. It typically—as I said, FERC will typically act on a certificate 6 to 12 months after the environmental—the final environmental review document is done, the EIS or the EA, and then it's time for FERC to issue a certificate. All FERC certificates have numerous conditions that attach with them and a pipeline cannot begin to construct until FERC authorizes construction, which can take up to 9 months later. And it makes sure that all outstanding permits and authorizations are within the pipeline's hand and everything's ready to go. So, next slide please.
There are a number of challenges facing natural gas pipelines. Many, or not most, of our interstate natural gas pipeline authorizations, whether it's FERC, whether it's Clean Water Act 401 certifications, many are challenged in a court of appeals. And they're done for different reasons, for different authorizations. They're often challenged on NEPA grounds. And the challenge is against the federal agency. But the challenges facing interstate natural gas pipelines are not unique. They are, I think, typical of what we shall see for hydrogen pipelines and other linear infrastructure. It's difficult to build a transmission line. It's difficult to site a solar field. Those are all difficult. And more frequent litigation increases the delay, the cost, and the uncertainty for all linear infrastructure.
So, here the facts speak for themselves. This is EIA data, and it says since 2023 the U.S. added the least amount of new interstate natural gas pipeline capacity since it started collecting its data. In 2023—so, even a reduction from 2022, and that is because, while EIA did not identify, it is the challenges with building interstate natural gas capacity. It is the continued litigation and opposition. It's not because this capacity isn't needed. We have growth with AI centers. We have growth with natural gas generation to back up renewables. We have LDC, continued need for natural gas. So that's not it. Much of the new capacity in pipelines is being built in the intrastate market, and that is because the intrastate market is governed by the states and is not subject to the many—the much-litigated NEPA analyses.
So, let's talk about—we need more natural gas pipelines. We talked about the problems associated with delay. And it's delay, it's uncertainty, it's higher cost to consumers, and it's the risk that certain projects failed. And we have had several interstate natural gas projects that have failed, not because they weren't needed, not because they couldn't address all of the impacts from their projects, but it was the protracted litigation that I'd argue killed those projects.
So, where do we see some areas that could make the interstate natural gas permitting process more efficient, more reliable? And that is what we believe is some greater understanding and discipline over the scope of NEPA and the scope of the Clean Water Act, particularly 401 certifications, and we believe that the development of predictable agency permitting timelines and enforceable judicial review provisions are going to be extremely important as all linear infrastructure—whether it's electric transmission, natural gas pipelines, and some renewable infrastructure—all of us need these things, and we'd argue that we're looking to Congress for that predictability.
So, thank you very much, and I'm happy to take questions after all the presentations.
>>Thomas Pinkston: Thank you, Joan. Very informative presentation. So, good afternoon, everyone. And we appreciate the opportunity to share our views on jurisdictional issues related to the commission and hydrogen. Next slide, please.
This is a staff product and does not necessarily reflect the views of the Commission or any individual commissioner. I'll begin with a brief background of our natural gas authority and then proceed to specifics with regard to hydrogen. Next slide, please.
To begin, the Commission's jurisdiction under the Natural Gas Act of 1938 is limited to the transportation and sale of natural gas in interstate commerce. The Commission has no jurisdiction over the production, gathering, intrastate transmission, or local distribution of natural gas. Next slide, please.
Under Section 7 of the Natural Gas Act, the Commission reviews applications for construction, operation, and abandonment of interstate natural gas pipelines. The Commission is authorized to issue certificates of public convenience and necessity for the construction or extension of any such interstate facilities. In addition, the Energy Policy Act of 2005 designates the Commission as a lead agency for coordinating environmental review and compliance in pipeline certificate applications. The Natural Gas Act also requires that rates charged for interstate pipeline services be just and reasonable. Under Section 4 of the Natural Gas Act, the Commission approves the rates, terms, and conditions by which interstate pipelines provide service. The Commission's statutory responsibility is to ensure that these items are just and reasonable and not unduly discriminatory or preferential. Next slide, please.
So, a little bit broader perspective on the Natural Gas Act. The impetus behind the Natural Gas Act was a 1935 Federal Trade Commission report finding that interstate pipelines exercised—at that time—abusive market power. The Commission has—in determining what constitutes natural gas, the Commission has emphasized the goals and purposes of the Natural Gas Act over the chemical makeup of a given substance. The Commission has only assumed jurisdiction over pipelines under the Natural Gas Act when doing so would advance the purpose of encouraging the orderly development of natural gas supplies at reasonable practices—at reasonable prices.
Based on this analysis, the Commission has found that a pipeline transporting predominantly carbon dioxide, the Cortez Pipeline, in interstate commerce was not within its jurisdiction. Next slide, please.
The Natural Gas Act does not define natural gas to include hydrogen, and the Commission has previously, as noted, disclaimed jurisdiction over the interstate transportation of non-methane gases. Moreover, recently, in 2020 the Commission vacated in part a certificate for four natural gas storage caverns so that two of the caverns could instead be used for non-jurisdictional purposes, specifically hydrogen storage. Next slide, please.
Before proceeding further, it's important to note, and I think everyone's aware—for the most part aware of this—that the commission has no jurisdiction over pipeline safety or security, but actively works with other agencies with safety and security responsibilities. The Commission's regulations require pipelines to certify that they will adhere to PHMSA's pipeline safety regulations. Next slide, please.
So, within this context, the three primary topics for which the Commission has received questions regarding our regulations and their applicability to hydrogen include blending of hydrogen into existing natural gas pipelines, repurposing natural gas pipelines for hydrogen transportation, and the construction of new hydrogen pipelines. Now, my co-presenter, Terry Turpin, the director of the Commission's Office of Energy Projects, will discuss each of these in more detail.
>>Terry Turpin: Thanks, Tom. And thanks to everyone for having us today for this discussion. As Thomas had said, there are these three areas we've gotten recent questions on from multiple parties. And on this first one of blending, I think it's—as even Joan indicated, it's very likely the Commission would have jurisdiction to regulate a natural gas hydrogen blend. The question really is, what is the exact mix of the blend that then takes it from being a natural gas pipeline into a hydrogen pipeline? From internal staff reviews and discussions, we see there's two ends of the spectrum. At the one end, where you're principally methane, as it is today, with hydrogen being a very minor component, no question that's a natural gas pipeline. No question FERC would have jurisdiction. At the other end of the spectrum, where it's 100 percent hydrogen, we don't think much question that FERC does not have jurisdiction under the current statutory constructs. The space between there is very, very gray, and there is really no set definition for where the breakpoint would become that a pipeline would leave natural gas jurisdiction and enter some sort of hydrogen jurisdiction. Next slide.
So, let's talk a little bit about that gas quality aspect of FERC regulation. The commission has a policy statement on natural gas quality and it sets forth terms that have to be met for the transportation of that gas. Each of the tariffs—this is what defines the tariffs—set the maximum amount of a non-hydrocarbon substance that may be delivered to the pipeline, as well as a maximum amount that the pipeline may deliver to its customers. So, in the current constructs of a natural gas pipeline, where pipelines want to make changes to its gas quality provisions to accommodate hydrogen at higher levels, they would need to follow the Commission's policy statement on gas quality and interchangeability. Those five requirements of that statement are listed on this slide.
The case-by-case approach the Commission uses in looking at this, then, is to identify all the characteristics that are unique to each pipeline, including configuration and location to processing or gas pressure, temperature requirements, requirements of the end users, and the needs of interconnecting facilities. So, with respect to blending from a pipeline perspective, important issues to keep in mind are pipelines will almost certainly require testing and may need modifications to some of their integrity management systems that would fall under PHMSA's regulations. And including greater quantities of hydrogen in the natural gas stream could require revision to the gas quality provisions and the tariffs, and likely would require coordination between shippers and other gas pipelines.
And acceptable levels of hydrogen are going to vary from operator to operator. It's really going to be dependent upon what the end users can accommodate. And, as well, hydrogen really isn't segregated out like other liquid fuels in the stream. So, shippers in the system that would have a hydrogen blend will all need to receive the blend, meaning that they all have to accommodate whatever effect it has on the various gas quality. Hydrogen is about three times less energy dense than methane, and so that will affect the heating content through the pipeline flow. So, blending on a pipeline that's fully subscribed could impact the pipeline's ability to deliver its currently contracted levels. And all of that as an aspect of gas quality is something that has to get looked at by the pipeline operator and brought to the Commission for consideration. Next slide.
So, I won't spend much time on this slide, but wanted to show an example of the guidelines typical in a natural gas pipeline tariff. You've got the Wobbe Index, which considers both the heating value of the gas composition, and it's usually the most frequently used indicator for the interchangeability of different types of gas. For hydrogen blending, this would be affected with higher percentages of hydrogen, and that leads to the heating value.
There are also guidelines in the gas quality on what kinds of heavier hydrocarbons and what kinds of inert gases could be in the transportation stream. Those tariffs are going to be very pipeline-specific. And at the moment, when we reviewed the tariffs that are on file with the Commission, very few pipelines mention hydrogen in their tariffs. And when they are included, it's—as Joan said, the volumes are very small and it's—because it's looked upon in the commercial stream today as more of a contaminant or more of just a small byproduct that isn't being commercialized. Next slide.
So, just takeaways on this discussion about the blending issue. First off, the tariff proposals that the Commission reviews and has to approve before they can go into effect, they're really most effective when they're worked out between the natural gas providers, the pipeline transportation company, and the end-use customers. There's not something the commission really can set on behalf of all those folks. Those parties typically get together, design a tariff and a quality standard for the gas that they're either moving or receiving that works for all of them, and that's what they all agree to. That tariff would need to be filed with the Commission, and the Commission would then establish the gas quality provisions if someone were wanting to have hydrogen blending at higher levels in there.
The evaluation of the tariff revisions, as I described on a few slides ago, would be in accordance with the Commission's policy statement on natural gas quality. Again, that's done on a case-by-case review. And it is done on a legal, sort of a public legal proceeding based on the record that's developed in the Commission's docket and with input from parties and stakeholders, such as shippers or anyone else that wants to file comments in support or opposition of such a proposal. OK, next slide.
So, then, moving on to the next topic that we often hear about is FERC’s role—potential role in looking to repurpose existing interstate natural gas pipelines for use in pure hydrogen. So, to talk about that, we first have to go through sort of the basis for, I guess, the Commission's role in natural gas. As Tom had highlighted, it's—our jurisdiction is specific to natural gas, so we've never received an application for anything to transport something other than natural gas. We have received applications and processed them for a project to stop natural gas service so that they could enter into some other product service. But that product service is then outside of the Commission's jurisdiction. Under the Natural Gas Act, if a company wishes to stop a natural gas service, it has to seek an abandonment authorization from the Commission under the Natural Gas Act Section 7B. And I listed out some of the regulations that we've got that cover the applications for that, and you can look them up at your leisure. Next slide.
So, this slide details some of the information required for such an abandonment application. Crucially, the exhibits W and X speak to the impact of an abandonment on existing customers and tariffs. So, that's really what the Commission's main focus is in an abandonment activity—understanding the impact to the existing natural gas customers if that service is terminated. Also note that the applications and some of these exhibits must address the environmental impacts of the abandonment of the pipeline. Often, they are left in place. Many times, they are also removed from the pipeline right of way. But we are not—we don't have jurisdiction of the environmental impacts of the later non-jurisdictional use of the pipeline. Next slide.
So, as I said, the importance of—or the impact on natural gas customers is the principal consideration for the Commission in determining if an abandonment is warranted. And it's the continuity and stability of existing services that are primary considerations when the Commission assesses whether a pipeline can abandon its natural gas service. The Commission has looked at this occurrence, not with hydrogen pipelines, but the most recent example is with a pipeline called the Trailblazer Pipeline—again, transporting natural gas in the 1980s in Colorado and Nebraska. Late last year, we issued an order that allowed that to leave natural gas service. The owner of the pipeline wanted to take it to a future use for carbon dioxide transportation. So, that effort looked through that impact to the existing natural gas customers and then looked at the environmental impacts of if there were any removal of the pipeline from the right of way, or if there were any other modifications to other natural gas systems to keep that service going for the customers through alternative paths, that's what we maintain jurisdiction over. Once the pipeline has been—has left that natural gas service, then the Commission did not—will not have jurisdiction over that CO2 pipeline when it develops. Thanks. Next slide.
And so, the last one, of course, the last topic of the three is what about brand new hydrogen pipelines? Next slide.
And as previously mentioned, the NGA, the Natural Gas Act, does not include hydrogen among FERC's authorities. So, the end point for a pure hydrogen pipeline is outside of the FERC authority at this time. In order to get FERC authority, Congress would need to take some sort of legislative action as it stands. The Natural Gas Act is—as with any other products by pipeline, FERC's jurisdiction only extends to that natural gas.
Thanks very much.
>>Mark Richards: OK, thanks, Terry. And thank you, Tom. Next up, we have Mary McDaniel, acting director of the Engineering and Research Division, and Kandi Barakat, R&D Operations Supervisor, both at DOT's PHMSA—Pipeline and Hazardous Materials Safety Administration. So, Mary, I think you're up, and if we could get the slides.
>>Mary McDaniel: Good morning, afternoon, everybody. I'm going to talk a little bit about PHMSA's role in the transportation of hydrogen and hydrogen blending. I think that's one of the questions we've been asked a lot. PHMSA's mission is a safety mission. It's the advance of safe transportation of energy and other hazardous materials. And so, I think as part of that, if you look at what PHMSA does, over 3.3 million miles of pipelines are up through the United States, and of that, hydrogen is just a small portion of that. But our role at PHMSA is to conduct inspections, set policies, and do training in regards to the safety of pipeline transportation. Next slide.
So, hydrogen as a whole is—right now, our current network of hydrogen pipelines is a little over 1,600 miles. And it's a little hard to tell on the map there, but of the 1,600 miles, a little over half of that is interstate mileage. And so, what PHMSA does is PHMSA has a pipeline safety inspection program for interstate pipelines, but we also partner with states to do inspections of intrastate pipelines. So, of the hydrogen mileage, most of it, as I mentioned, was—or, over half of it is interstate and under PHMSA's direct inspection authority.
But if you look very—hard to see on the map, but there are some individual states – Utah, Kansas, Oklahoma, Alabama—there are a few that have intrastate hydrogen pipelines that are under the state's regulation. The fluctuation, there has been a little fluctuation in the mileage for hydrogen. They're talking about conversion projects, pipelines that might have been in pure natural gas service or other service that may be converted to hydrogen. So, the mileage has had a slow increase over the years, but not a major increase since then. Next slide.
OK. So, PHMSA's current regulations, we have been regulating the transportation of hydrogen for many years. And here's a set of all the different regulations that we use in PHMSA to regulate pipelines. Of these regulations, we have enforcement procedures, reporting criteria, regulations for hazardous liquid pipelines, and then the one that applies here is 49 CFR Part 192. So, it's the transportation of natural and other gas by pipeline. So, hydrogen, as of right now, as I mentioned, we are regulating pure hydrogen. Hydrogen falls in under Part 192. It's all gases that are flammable, toxic, and corrosive. Hydrogen, being a flammable gas, does fall under our Part 192 regulations. So, next slide.
OK, for this one, I just want to point out what is some of the things, since I mentioned on the left side, is that we've been regulating hydrogen since 1970. And there's very limited differences between the hydrogen and natural gas transportation and what we have in our regulations. And right now, through this blending question, they're not currently defined or captured in our data. And so, right now, regardless of the—if a pipeline is blended with hydrogen, it would still fall under the category of flammable, toxic, or corrosive, and still will be subject to our Part 192 regulations.
We do have two specific regulations, I think, that we could say are specific just for hydrogen. It's, one, for odorization of when gas needs to be odorized. And if hydrogen is being used for feedstock, then it does not have to be odorized in the Class 3 or 4, which are populated areas, if it's in that manufacturing process. And the other is—a question that we get a lot is the materials that are used for the transportation of hydrogen. And that's where we use under our design criteria, under the 192.53, that says that your pipe has to be chemically compatible with the gas that they transport. So, that is something that we take into consideration when we inspect hydrogen pipelines. So, next slide.
One of the things to answer the question for blending is we don't have, like I said, it's not defined, specifically defined. So, earlier this year in March, PHMSA issued a Federal Register—in the Federal Register a notice asking for information on the blending of hydrogen. It was to collect data on practices, procedures, or things that people may be doing in terms of blending hydrogen with natural gas. And so, it's something that has been out. It was—we had an initial comment period and then it was extended through June. And one of the things I think is important, obviously, that we do have quite a few comments out on this docket. If you'd be interested in seeing some of the comments that we're receiving regarding the transportation of hydrogen and the blending of it, you could find it on that docket. Next slide.
So, I wanted to talk a little bit, if I could, about the safety of the hydrogen pipelines. Since 2010, we've had five incidents that have been reported to us regarding the hydrogen. And none—I guess we have the statement: None were attributed to the direct transportation of hydrogen gas. I think we have two that did involve a failure of the pipe itself for internal corrosion. And then, another specific question we've had about embrittlement in a weld. And so that's, I think, in the next part of our presentation, Kandi Barakat will talk about some of the research we're doing in that area. So far, though, we do not have any of the incidents were involved—included blended hydrogen gas.
And most importantly, there have not been any injuries or fatalities reported with the transportation of hydrogen. For that, also, we have our pipeline safety inspection program. Since the inception of our inspection program, we've had—we do conduct routine inspections of our hydrogen pipelines. And to date, we've had one, only one incidence where we've assessed a penalty to an operator, and that was failure to follow a new construction report for a new pipeline project. But we haven't had any that have involved a specific detail on a safety concern regarding the hydrogen pipeline. So, our inspections continue on that and do get planned in our routine planning for inspections of all pipelines throughout the United States. Next slide.
So, with that, I think we have a lot of questions that have come up about new issues that we might have in regards to blending and if we need to make changes to our regulation. One of the things that we just recently did that was important is PHMSA is working on a leak detection rule. And as part of that, we'll include hydrogen and—so, to reduce emissions from pipelines. So, that's one initiative that's underway. But a big part of it, again, as I mentioned, was some of the research that we have planned for hydrogen. So far, we've actually funded 11 projects, $10.5 million dollars of investment, and have addressed some of the questions: materials and welding, leak detection, the repurposing of pipeline. That seems to be a very big question about, can I use this pipeline that was designed to transport this for hydrogen or blended hydrogen?
And so far, I think one of the big things that we have, we've had knowledge transfer and new technologies that are coming on as part of the transportation, but another is working with the industry and industry standards for the safe transportation of hydrogen and hydrogen blends. So, with that, I think this hydrogen R&D initiative that we've been working on is very important. And I think I'll turn it over to Kandi and let her talk about the R&D projects that are underway.
>>Kandi Barakat: Thank you, Mary. And good afternoon, everyone. Next slide, please. So, I would like to highlight some of the ongoing research PHMSA is funding on hydrogen. There are 11 active projects on hydrogen, totaling in $10.6 million of PHMSA funding. The research topics cover various research focus areas, like Mary mentioned: leak detection, materials, climate change, threat prevention, anomaly detection and characterization, and underground storage. For the sake of time, I won't discuss each one. This presentation will be provided after the webinar and you can read about each project and follow up with questions as needed.
But I would like to cover two projects that are related. One is on codes and standards and the other one is on hydrogen underground storage. So, the first one listed here is on steel weld qualifications and performance for hydrogen pipelines. The topic of this project was derived from the 21 R&D forum and seeks to address stakeholders' concerns, industry and manufacturers' concerns, on the transportation of hydrogen by pipelines. The objective of this project is to review current codes and standards for gaps in qualification requirements for welds in pipelines intended for hydrogen transportation and provide weld qualification requirements for new steel pipelines, performance evaluations for varying steel grades, assessment parameters for evaluating the integrity and existing and vintage pipelines. This is an ongoing project and anticipated to be completed in 2024. And I know there was a comment in the chat about the impacts of pipeline embrittlement due to hydrogen pipelines and some of the blending. So, some of these projects will address these concerns. Next slide.
And it's actually the one after that where I want to talk about the underground storage. Next. Next slide, please.
No, the one before that. Two before that.
Before that. There was one on the underground storage.
Looks like we are having some technical difficulties. Can you go back two more slides?
Well, I'll just talk about it. So, the other project is the technical basis for enabling safe and reliable underground hydrogen storage and operations. This one is an interagency agreement with the Department of Energy Office of Fossil Energy and Carbon Management. And this project will aim to establish the technical criteria for storing pure and blended hydrogen in underground storage and geologic reservoir. The project will identify potential resources of hydrogen loss and acid degradation, assess the suitability of existing storage facilities, and characterize operational expectations. The findings will be used to develop guidance for assessing the suitability of existing engineered systems, quantify potential operational risks, and forecast transient operational behavior. This is an ongoing project and is anticipated to be completed in February 2025. Next slide, please.
Next. There is one after this one.
>>Mark Richards: I think that's all the slides that are in here.
>>Kandi Barakat: No, there was one after that. It showed up a minute ago. There was one on the ASME. No, before that.
>>Neha Rustagi: Kandi, I think it's not showing up on your screen. The ASME slide is up on the screen now. Go for it.
>>Kandi Barakat: Well, I can talk about it. There is another—so, we participate in various work. This one, it's actually this one. So, we participate in various working groups on hydrogen, such as the HIT that was mentioned before, which stands for Hydrogen Interagency Task Force with the Department of Energy, and PHMSA holds a hydrogen internal working group among PHMSA staff. One here I would like to highlight is we have a working group on updating the American Society of Mechanical Engineers standards, specifically B31.12 and B31.8, for gaseous hydrogen. This is an effort that's initiated and led by the Pipeline Research Council International and seeking to migrate some of the existing technical requirements for ASME B31.12 to ASME B31.8. The proposed changes are still being worked on and anticipated to be completed sometime in 2026.
And next slide is just I want to share some of our R&D links about our program. And I highly recommend you join our distribution list. That's the first link. This way you stay informed on all of our R&D correspondence, whether it's a briefing on a project or awarded projects and forums, et cetera.
And back to you. I think that was the last slide.
>>Mark Richards: Thank you, Kandi. Unfortunately, we have a fair amount of questions and only a few more minutes. So, it's—I'm not looking good to try and get through more than even one or two. So, unfortunately, we—but we will review all the questions we receive and make sure that all the panelists have access to that as well. Just a reminder that we will have a follow-up to this webinar covering environmental justice and community concern issues sometime in the fall.
And I also want to mention that the questionnaire will—is available right now. There's a link there and a QR code. So, however you want to manage that, you can go answer those questions pertaining to permitting and such. And I guess maybe I'll hand it back to Kyle to talk about the logistics of—and my video does finally work—the logistics of when things will be available from today and the recording up on the Internet.
>>Kyle Hlavacek: Sure, thanks, Mark. And that concludes our H2IQ Hour for today. I'd like to thank Mark, Neha, and all of our presenters. The slides and a link to the recording of this webinar will be available within the coming weeks in the H2IQ Hour archives. Be sure to subscribe to HFTO news to stay up to date. And be on the lookout for the part two webinar that will be coming out later this fall. Thank you for attending and we look forward to seeing you at our next H2IQ Hour. Thank you.
>>Mark Richards: Thanks to all the panelists for helping out. We really appreciate the participation.
[End of audio]