Allow hydrogen storage to receive credits under 48E regardless of ultimate end use
Summary
The Clean Air Task Force contends that Treasury's proposed guidance for the section 48E investment tax credit (ITC) incorrectly limits eligibility to hydrogen storage used solely for energy, contradicting the statute's plain text. The author argues that restricting credits based on end use is administratively difficult because storage operators cannot easily track hydrogen after it leaves their facilities. Expanding eligibility is presented as vital for decarbonizing hard-to-abate sectors like refining, steel, and heavy-duty trucking by providing a reliable supply of clean hydrogen and mitigating the variability of renewable energy.
Key insights
- The Clean Air Task Force asserts that Treasury's proposed guidance for the section 48E investment tax credit (ITC) improperly limits eligibility to hydrogen storage used solely as energy, which contradicts the statute's plain text that only requires hydrogen storage property to "store[] energy" without requiring conversion to electricity.
- Restricting 48E credit eligibility based on the end use of hydrogen is difficult to administer because storage operators lack the mechanisms to track hydrogen once it exits their facility, requiring unlikely ownership of transportation infrastructure or problematic access to transportation data.
- Widespread and affordable hydrogen storage is described as essential for decarbonizing hard-to-abate sectors such as steel, refining, and heavy-duty trucking, as it ensures a reliable supply of clean hydrogen and helps manage the variability of renewable energy.
Cite the original document
- APA
- Firth, S. (2024). Allow hydrogen storage to receive credits under 48E regardless of ultimate end use. Clean Air Task Force. https://www.catf.us/2024/08/allow-hydrogen-storage-to-receive-credits-under-48e-regardless-of-ultimate-end-use/
- Chicago
- Firth, Sammie. Allow hydrogen storage to receive credits under 48E regardless of ultimate end use. Clean Air Task Force, 2024. https://www.catf.us/2024/08/allow-hydrogen-storage-to-receive-credits-under-48e-regardless-of-ultimate-end-use/.
- Wikipedia
- {{cite press release |last1=Firth |first1=Sammie |title=Allow hydrogen storage to receive credits under 48E regardless of ultimate end use |publisher=Clean Air Task Force |date=19 August 2024 |url=https://www.catf.us/2024/08/allow-hydrogen-storage-to-receive-credits-under-48e-regardless-of-ultimate-end-use/ |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @misc{firth2024allow, author = {Firth, Sammie}, title = {{Allow hydrogen storage to receive credits under 48E regardless of ultimate end use}}, publisher = {Clean Air Task Force}, year = {2024}, month = aug, url = {https://www.catf.us/2024/08/allow-hydrogen-storage-to-receive-credits-under-48e-regardless-of-ultimate-end-use/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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