Hydrogen is increasingly recognized as a critical component of the transition toward low-carbon energy systems in the United States. In addition to hydrogen produced through electrolysis or natural gas reforming, emerging research suggests that hydrogen may also be generated and stored in the subsurface, including within geological formations such as ultramafic rocks, saline aquifers, and depleted hydrocarbon reservoirs.
The Subsurface Hydrogen Governance Project examines the institutional and societal conditions required for the responsible development of subsurface hydrogen systems. While these systems offer promising opportunities for energy storage, renewable integration, and regional economic development, they also raise important questions regarding regulatory oversight, permitting processes, resource ownership, and workforce transitions.
This project integrates expertise in subsurface energy systems and environmental law to analyze how governance frameworks can support responsible hydrogen development. The research focuses on identifying regulatory gaps, clarifying institutional roles, and examining workforce opportunities that may emerge as hydrogen technologies evolve.
Research Themes
Institutional and Workforce Foundations of Subsurface Hydrogen
The project examines three interconnected research themes that shape the development of subsurface hydrogen systems.
Regulatory Frameworks and Permitting
The emergence of subsurface hydrogen technologies raises important governance questions. Existing regulatory systems were designed primarily for oil and gas production, carbon storage, and groundwater protection. This research analyzes how these frameworks apply to hydrogen production and storage and examines potential pathways for clearer permitting processes, regulatory oversight, and institutional coordination.
Subsurface Resource Ownership
Hydrogen generation in geological formations may occur alongside other subsurface resources, including heat and critical minerals. This raises unresolved questions regarding ownership rights, regulatory jurisdiction, and legal classification of subsurface hydrogen resources. The project examines these issues through comparative legal and policy analysis.
Workforce Transition
Many of the technical capabilities required for subsurface hydrogen development—such as drilling, reservoir management, and subsurface characterization—closely align with expertise developed in the oil and gas sector. The project explores how workforce skills and technical knowledge can transition from oil and gas to emerging hydrogen systems, supporting economic continuity in energy-producing regions.
Research Activities and Outputs
Research Activities
The project combines policy analysis, stakeholder engagement, and workforce research to examine governance challenges associated with subsurface hydrogen systems.
Key activities include:
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Comparative policy and legal analysis of regulatory frameworks governing subsurface energy resources
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Interviews with regulators, policymakers, and industry stakeholders to understand emerging governance challenges
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Analysis of workforce capabilities and transition opportunities between oil and gas and hydrogen sectors
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Organization of stakeholder workshops bringing together researchers, regulators, and industry representatives
Expected Outputs
The project will produce research outputs designed to inform both academic research and policy discussions related to hydrogen energy systems.
Expected outputs include:
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Peer-reviewed academic publications
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Policy briefs on hydrogen governance and permitting frameworks
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Analytical reports on workforce transition opportunities
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Stakeholder workshop summaries and presentations
These outputs will contribute to a growing body of research on the institutional and societal foundations of emerging hydrogen energy systems and help inform decision-making as the United States explores new pathways for low-carbon energy development.