The Massachusetts Medical Society (MMS) is a professional association of over 25,000 physicians, residents, and medical students across all clinical disciplines, organizations, and practice settings. The MMS is committed to advocating on behalf of patients
for a better health care system, and on behalf of physicians, to help them to provide the best care possible. Over the past many years, through leadership of the Medical Society’s physician Committee on Environmental and Occupational Health, the Society
has increased its policymaking and advocacy on issues at the critical intersection of environmental justice and public health. MMS has passed policy on environmental health issues including climate change, air pollution, water quality, and a broad
list of energy policies, including recognizing the health, safety, and climate risks of fossil fuel-derived hydrogen. The City of Boston and more than one-hundred leading public health groups – including the American Medical Association and the American
Academy of Pediatrics – agree that the climate crisis is a health emergency and thus it is imperative that physician community engage actively on the matter.
The MMS applauds the state’s aggressive goal of net zero emissions by 2050 and acknowledges the enormous undertaking of the Department of Public Utilities in investigating the future of the natural gas industry in Massachusetts and local gas distribution
companies (LDCs) role in ensuring a low-carbon future to help the Commonwealth to achieve its 2050 climate goals. In exploring strategies to enable the Commonwealth to move into its net-zero greenhouse gas (GHG) emissions energy future, we recognize
the simultaneous and competing challenges of safeguarding ratepayer interests while also ensuring access to safe, reliable, and cost-effective gas service. We write today to caution again some of the proposals contained in the 20-80 docket. While
we support many of the proposals, for example expanded use of heatpumps – we are concerned about certain LDC proposals that rely on the use of “renewable hydrogen” as a key pathway to decarbonization, especially when blended with natural gas. Indeed,
the Independent Consultant Report that offered a technical analysis of decarbonization pathways specifically recommended that LDCs pursue pilot programs to investigate to what extent hydrogen can safely be added to the existing network without the
need for customer equipment or pipeline upgrades.
The Medical Society has serious concerns about the climate risks of fossil fuel-derived hydrogen and particularly the health and safety risks of adding hydrogen to natural gas. Hydrogen (H2) is misleadingly portrayed as a “carbon-free” fuel because combustion
of hydrogen yields water (H2O), and not carbon dioxide (CO2). As such, increasing the use of hydrogen as an energy source is being promoted as a means to reducing carbon emissions and therefore combat climate change, which we believe to be disingenuous.
However, the majority (98.5 percent) of hydrogen is currently derived from fossil fuels (mostly methane from natural gas), which generates high greenhouse gas (GHG) emissions.” In fact, current fossil fuel-based production of hydrogen is responsible
for CO2 emissions of around 830 million tons of carbon dioxide per year, equivalent to the CO2 emissions of the United Kingdom and Indonesia combined. Moreover, hydrogen is particularly corrosive to bare steel and cast iron pipes, which are common
in Massachusetts, and the addition of hydrogen could therefore cause further leakage from the Commonwealth’s natural gas infrastructure that is already documented to have over 14,000 gas leaks.
Hydrogen is also more explosive than methane and burns at a higher temperature. Moreover, hydrogen blends cannot be burned safely in current gas appliances that have not been retrofitted to handle hydrogen. Experiments burning hydrogen and methane show
that the more hydrogen mixed with methane, the more nitrogen oxides (NOX) is produced; burning 100 percent hydrogen emits six times more NOX than burning natural gas, which in cooking stoves can have significant deleterious effects on household air
pollution and health. In terms of the associated health risks, according to the Environmental Protection Agency, exposures to high concentrations of nitrogen dioxide (NO2) can irritate airways in the human respiratory system and contribute to the
development of or exacerbate respiratory diseases, particularly asthma, with increased risks for emergency department visits and hospital admissions. In Massachusetts, about half of households cook with gas13 and current natural gas appliances were
not built with technology to reduce the NOX produced by burning hydrogen. The average life of a gas stove is 15 years and replacement before end of life is not an affordable option for many. The proposed exploration of adding hydrogen to methane gas
will increase the incidence of indoor air pollution with NO2 which is a social determinant of health that contributes to health disparities.
The MMS would strongly caution the DPU to consider the deleterious health effects of proposed uses of hydrogen in pathways to decarbonizing the natural gas system. Increasing the production of fossil fuel–derived hydrogen, whether used on its own or so
that it can be mixed with methane in the natural gas infrastructure, will necessarily increase greenhouse gases and worsen the climate crisis. We already know that climate-sensitive health hazards are disproportionately experienced by our most vulnerable
and underprivileged, including women, children, ethnic minorities, poor communities, migrants or displaced populations, elder populations, and individuals already experiencing health conditions. As we endeavor to achieve the Commonwealth’s goal of
net zero emissions by 2050, we encourage you to instead focus on safer pathways to decarbonize our future.
View a PDF version of this testimony here.
