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IRSRulemakingIRS-2023-0066

Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property (REG-117631-23)

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Natural Resources Defense Council (NRDC) filings
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Activity

Natural Resources Defense Council (NRDC) filed 3 comments on this docket between Feb 27, 2024 and Mar 5, 2024. 157 other organizations filed here. The comment window closed 883d ago.

What Natural Resources Defense Council (NRDC) filed (3)

Mar 5, 2024· Comment from Natural Resources Defense Council· IRS-2023-0066-29875

Request to TESTIFY in Person at Hearing for REG-117631-23 Good Afternoon, My name is Erik Kamrath, federal Hydrogen Advocate for the Natural Resources Defense Council (NRDC), and I'd like to testify in person for REG-117631-23 regarding the 45V clean hydrogen production tax credit. Below is an outline of my comments: •Intro to NRDC (1 min) •The proposed guidance for electrolytic H2 has robust legal basis, adheres to best available evidence, and delivers on Congressional intent to scale a clean hydrogen market effectuating the Inflation Reduction Act's stated purpose to reduce U.S. GHG emissions. (4 min) •Broad loopholes for existing clean power resources will support hydrogen production with induced grid emissions that far exceed section 45V's lifecycle greenhouse gas emissions thresholds. (3min) •NRDC proposed targeted flexibilities for existing clean energy to qualify as incremental without violating section 45V's statutory requirements and that meet EPA's threshold of "appropriately stringent criteria" for determining no to minimal induced emissions. (2 min) Thank you for your consideration. -Erik ERIK KAMRATH, MPA Hydrogen Advocate Climate & Clean Energy Program NATURAL RESOURCES DEFENSE COUNCIL

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Feb 27, 2024· Comment from Natural Resources Defense Council· IRS-2023-0066-29690

Attached please find Comments on the Natural Resources Defense Council on the proposed rule implementing the Clean Hydrogen Production Credit under Section 45V.

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Feb 27, 2024· Comment from Natural Resources Defense Council· IRS-2023-0066-29696

Comments by the Natural Resources Defense Council (NRDC) on the NPRM relating to electrolytic hydrogen production and biomethane-derived hydrogen production. Legal comments by the Natural Resources Defense Council (NRDC) and the Clean Air Task Force (CATF) regarding the Legal Necessity of the three-pillars of incrementality, deliverability and hourly matching; submitted on April 18, 2023 to Document (IRS-2022-0029-0001). NRDC- CATF Response Letter to NEI Commentators on the legal necessity of incrementality requirements for all electrolytic hydrogen projects- both behind-the-meter and grid-connected; submitted on June 13, 2023 to Document (IRS-2022-0029-0001).

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Abstract

This document contains proposed regulations relating to the credit for production of clean hydrogen (clean hydrogen production credit) and the energy credit, as established and amended by the Inflation Reduction Act of 2022, respectively.

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Co-filers (157)

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