(10-minute read)
Our ability to build an equitable and just energy future for all Washingtonians depends on whether we implement a Just Transition framework in all aspects of clean energy planning and development. In other words:
We must consider more than just whether we can build the infrastructure and facilities necessary to generate clean energy. We must also consider how and where we choose to build, whom we involve in decision-making, and in what types of technology we prioritize investments. Energy projects that create or exacerbate existing pollution burdens, the growing inability to afford consistent energy, or have hidden climate risks are false solutions that fail to address the root causes for our state’s energy crisis.
For too long, frontline communities have been forced to carry an unfair share of environmental and climate harms under the premise that these inequities are an inevitable part of development. We cannot allow these cycles of violence to continue in the form of clean energy policies that do not require comprehensive and accessible community engagement, the consideration of cumulative impacts of environmental harms on people’s lives, resource assessments prior to permit issuance, or consumer protections.
What do we mean by “clean” energy?
Energy is considered “clean” when it is generated by renewable sources or sources that do not emit greenhouse gases (GHG). In Washington State, the term “clean energy projects” is broadly defined, due in part to the urgent need for updated infrastructure that can meet our growing energy needs.
Front and Centered recognizes the urgency behind providing all Washingtonians with universal access to affordable, clean, and community-controlled sources of power, but including electrical transmission facilities, storage facilities, and facilities that primarily process alternative jet fuel in our state’s definition for clean energy could create serious unintended consequences for frontline communities, unless more specific requirements for energy sources used at these facilities are established.
The need for clear language is exemplified by the state’s definition for “green hydrogen,” which includes both renewable and green electrolytic hydrogen. Renewable hydrogen is when both the source of the hydrogen and the energy used in its production come from renewable resources. This aligns with national and global definitions for green hydrogen developed within similar timeframes.
However, green electrolytic hydrogen does not have a similar requirement—meaning that green hydrogen as defined in Washington State can be produced with electricity derived from fossil fuels.
Even with clean energy requirements under the Clean Energy Transformation Act (CETA) that mandate an electricity supply free of GHG emissions by 2045, this discrepancy in definitions is misleading. Many of the potential impacts of hydrogen production depend on the type of electricity source being used, and failing to use industry standards for commonplace terms like “green hydrogen” increases the likelihood that the exact same harms caused by our current dependence on fossil fuels will be replicated through improper assessment and mitigation.
All energy projects, including those that could ultimately result in net positives like cheaper energy and less emissions, must be assessed carefully with robust input from those the project will impact. But what makes an energy project truly clean, and what would make it a false solution to the climate crisis instead?
False solutions:
Because not all clean energy is built the same!
When it comes to climate change and environmental hazards, frontline communities are often presented with false solutions that do not address the root cause of an issue. False solutions are often faster and easier to implement, making them more favorable to developers and decision makers, particularly when contrasted with community-driven solutions that require intentional outreach, relationship building, and people-centered ideas that sometimes do not fit structures and processes that prioritize profit.
False solutions tell us that the institutional and structural changes favored by frontline communities are not feasible. False solutions rely on manufactured dichotomies: you can have the Working Family Tax Credit or climate funding, clean air or frequent public transit, equitable participation processes or timely agency decisions. False solutions tell us to be grateful for what we get even though what they offer us is often about as helpful as applying a band-aid to a broken leg.
As CETA implementation deadlines fast approach, it can be difficult to strike the right balance between hurriedly building new energy producing facilities and transmission lines and taking the time to understand the unique, local conditions of a community before moving forward on a project. Frontline communities can be skeptical of outsiders who promise new jobs and investments in local infrastructure, and rightfully so. Not so long ago, the same governing bodies and political systems that today promise us jobs and investment were used to disproportionately site polluting facilities in low-income communities of color like South Tacoma and the Duwamish Valley, and to mine radioactive uranium ore on Spokane Tribal land.
The harm caused by these decisions will take time to heal, and that can only happen if we ensure that our communities have a say in what their home looks like. Deliberate community engagement and decision-making processes ultimately benefit developers and the state, too: centering community input throughout all stages of a project can save time, money, and resources by providing those who are the most familiar with an area the opportunity to identify risks, suggest mitigation strategies, and create sustained project support through meaningful and long-term benefits.
It can be overwhelming to consider all of the factors that determine if an energy project is just another false solution. How do we do it?
How can we spot false solutions?
Here are several factors Front and Centered considers when assessing a proposed energy project or source:
Cumulative Impacts and Local Pollution
Even if laws regulating air and water pollution are met and relevant permits are obtained and abided by, frontline communities can still experience detrimental local pollution impacts. We know this because many communities already bear the worst effects of cumulative pollution impacts under existing laws and permitting processes; enough so that adding more pollution would cause real harm, even if that pollution on its own would not be enough to raise concern under existing laws and processes.
For example, most of the state is in compliance, or “attainment” with the national ambient air quality standards (NAAQS) established under the Clean Air Act. Despite this, Ecology has identified sixteen overburdened communities across the state where people face “a higher death rate from air pollution than the state average” because of health conditions linked to anthropogenic particulate matter 2.5 pollution. People in these communities also have higher rates of chronic respiratory and cardiovascular conditions, as well as lower-than-average lifespans than people in the rest of the state.
Air pollution impacts are almost entirely dependent on the source of electricity being used to generate energy. The entire life cycle of clean energy processes, from material extraction to distribution, must include assessing air pollution impacts caused by different production methods. For example, if green hydrogen generated by electrolysis is produced using energy from a carbon-intensive grid, this technology can result in high CO2 emissions. Any additional emissions in areas where green hydrogen facilities are being considered, such as Yakima and South King Counties, will only compound the health impacts already being felt by communities who live and work near a multitude of air pollution sources.
Affordability
This legislative session, there are talks of a bipartisan push to pursue nuclear power as a way to meet our energy goals. House Bill 2090 would direct the Department of Commerce to create a nuclear power strategic framework for the state. This aligns with a surge in conversations about small modular nuclear reactors (SMRs), a type of nuclear technology that is favored by tech companies like Amazon due to their lower upfront costs and smaller facility size.
Yet these features do not address one of the main issues with nuclear energy: production cost. Even if we were to ignore the costs borne by frontline communities when it comes to the siting of nuclear energy facilities and nuclear waste storage, the cost of nuclear production is $160 per megawatt hour, four times the cost of utility-scale solar and wind, and some projections anticipate that SMRs in particular will be “the most expensive source per [kilowatt] of electricity generated when compared with natural gas, traditional nuclear, and renewables.” These costs will not be paid by the tech giants building these facilities in the first place, but by local consumers as costs are passed off by utilities.
Climate Impacts
Another bill that is active during this legislative session is House Bill 2285. HB 2285 would allow CETA’s clean energy obligations to be satisfied by using electricity from natural gas systems if they are coupled with certain technologies like carbon capture and utilization.
Carbon capture, usage, and storage (CCUS) is often framed as a form of emission reduction by storing carbon emissions from facilities and repurposing it for other products like fuel. While the potential for carbon emission reductions can sound appealing, the effectiveness of this technology remains to be seen. One study found that adding CCUS to power plants led to a 44% increase of nitrogen oxides, a 33% increase of particulate matter, and a staggering nearly 3000% increase in ammonia.
Ammonia isn’t just toxic; it has serious climate impacts. While ammonia in itself is not a greenhouse gas, its natural conversion into nitrous oxide can have a warming impact that is seventy-five times greater than carbon dioxide over a 100-year period.
Ultimately, CCUS also allows our biggest polluters to continue with business as usual, which is inconsistent with Front and Centered’s energy justice framework, which in part aims to eliminate fossil fuels in our energy systems.
Water Usage
All of the emerging “clean” technologies discussed earlier are incredibly water intensive. CCUS has been found to exacerbate water scarcity in areas already experiencing scarcity prior to implementation. Depending on green hydrogen production methods, the state’s Department of Ecology acknowledged that a single facility could use over 293 million gallons of water.
Given existing stressors on water resources already being felt across Washington State and future climate trends indicating that our region will likely “see longer and more severe droughts in the future,” it is deeply inequitable and irresponsible to build these facilities in areas where communities are already concerned with not having enough water to fulfill existing needs.
So, what are the solutions our communities really need?
The solutions frontline communities really need do not present us with false choices. Our communities require clean energy and equitable engagement. They need affordable utility bills and emission reductions.
The clean energy siting and development policies we adopt now will impact communities across the state for decades to come. When environmental justice principles and community leadership are at the core of decisions made regarding clean energy, there is potential for positive local impacts and technological advances in energy generation that are necessary to achieve a carbon-free energy future. Washington State has been a national leader in environmental justice through groundbreaking initiatives like the Clean Energy Transformation Act and the Healthy Environment for All Act. It has the opportunity to build upon this legacy by creating equitable and comprehensive frameworks for clean energy implementation.
Policy Solutions
- Lawmakers and agency staff must proactively consider the cumulative impacts of a new energy facility on nearby communities. This should include looking at existing sources of air and water pollution, potential changes in local water availability and demand, planning for other types of clean energy facilities in the region, and how safety concerns could be exacerbated by the unique characteristics of each host community.
- Lawmakers and agency staff must engage with impacted communities from the outset and use their input to shape decisions. This should include robust exploration of Community Benefit Agreements, mitigation strategies, and statewide best practices for meaningful community engagement. Project-specific engagement must then be tailored to each community. While general requirements can be applied statewide, truly meaningful engagement is dependent on transparency and accessibility, which can look different to different communities.
- Lawmakers and agency staff must consider the complete energy supply chain in order to accurately assess impacts and avoid the use of fossil fuels. A true assessment of the harms of a new facility is not possible unless the entire supply chain from extraction to distribution is scrutinized. This includes transparency around electricity sources, which must come from new, renewable sources and should not use fossil fuel-derived energy.
- Lawmakers must regulate energy demand drivers at the source. For example, the need for more clean energy is due in part to the spread of data centers. Maintaining sustainable load growth can reduce the urgency to build out new facilities at whatever cost, allowing for more equitable siting and development to occur. Data centers should be required to bear the full financial burden of new and expanded facilities, be prohibited from using fossil fuel generated power, and publish sustainability and resource management assessments on water and energy use prior to permit issuance. Current proposed legislation on data centers (HB 2515 and SB 6171) should incorporate these equity-based policy elements to be as protective as possible of Washington’s frontline communities.