Natural Resources Defense Council (NRDC) filed 3 comments on this docket between Dec 6, 2022 and Jun 15, 2023. 76 other organizations filed here. The comment window closed 1333d ago.
RE: Notice 2022-58 Request for Comments on Credits for Clean Hydrogen and Clean Fuel Production –Hydrogen (IRC Section 45V) NRDC- CATF Response Letter to NEI Commentators on the legal necessity of "new clean supply" requirements for all electrolytic hydrogen projects- both behind-the-meter and grid-connected.
Attached please find a memo on the Inflation Reduction Act's Section 45V from the Clean Air Task Force (CATF) and Natural Resources Defense Council (NRDC) regarding the Legal Necessity of the three-pillars of additionality, deliverability and hourly matching. The memo explains why the three pillars are legally required in order to effectuate the statute's purpose in reducing greenhouse gas emissions and to accurately determine whether hydrogen producers meet the IRA's threshold to receive the subsidy. Crucially, the "new supply" additionality pillar is legally necessary for all projects—grid-connected and behind-the-meter.
Comments by the Natural Resources Defense Council to Notice 2022-58- Request for Comments on Credits for Clean Hydrogen and Clean Fuel Production
This notice requests general comments on the clean hydrogen production credit under § 45V of the Code (§ 45V credit) and the clean fuel production credit under § 45Z (§ 45Z credit), as well as specific comments described in section 3 of this notice.
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