Hydrogen can play a role in decarbonization, but Treasury needs to get 45V right

The Clean Air Task Force (CATF) argues that the U.S. Department of the Treasury must implement strict guardrails for the Section 45V Clean Hydrogen Production Tax Credit to prevent increased greenhouse gas emissions. Key recommendations include requiring project-specific upstream emissions data for natural gas feedstocks, prohibiting negative emissions values from biomethane or fugitive methane, and awarding credits on a kilogram-by-kilogram basis rather than annual averages. CATF strongly supports the 'three pillars' of electricity-based production—incrementality, hourly matching, and deliverability—to avoid systemwide grid emissions, while opposing a blanket 5% incrementality exemption, which Rhodium Group analysis suggests could increase cumulative emissions by 1.5 billion metric tons through 2035.

• CATF recommends that hydrogen producers using natural gas feedstocks be required to use verifiable, project-specific upstream emissions data from the EPA-administered Greenhouse Gas Reporting Program (GHGRP) Subparts C and W, rather than the current fixed nationwide average methane leak rate of 0.9%.
• The document argues against allowing negative emissions values from biomethane or fugitive methane as inputs for 45V lifecycle analyses, as this could allow producers using polluting methods without carbon capture and storage to qualify for the highest credit tier.
• CATF proposes that the 45V tax credit be awarded on a kilogram-by-kilogram basis (potentially tracked hourly) once a facility meets an annual average lifecycle emissions rate of no more than 4 kg CO2e/kg H2, rather than using a simple annual average for all production.
• To prevent systemwide grid emissions, CATF supports the 'three pillars' for electrolytic hydrogen production: incrementality (using new clean power), hourly matching (matching production and consumption hours), and deliverability (regional matching).
• CATF opposes a blanket 5% exemption to incrementality for existing clean generators, citing Rhodium Group analysis that such an exemption could lead to 1.5 billion metric tons of increased cumulative emissions by 2035.
• The document supports a 2028 phase-in for hourly matching, stating that U.S. registries could transition to hourly certificates within two years according to a Center for Resource Solutions study.

APA

Han, H., Saltzman, V., Kent, E., & Starr, R. (2024). Hydrogen can play a role in decarbonization, but Treasury needs to get 45V right. Clean Air Task Force. https://www.catf.us/2024/04/hydrogen-play-role-decarbonization-treasury-needs-45v-right/

Chicago

Han, Hagan, Veronica Saltzman, Emily Kent, and Rachel Starr. Hydrogen can play a role in decarbonization, but Treasury needs to get 45V right. Clean Air Task Force, 2024. https://www.catf.us/2024/04/hydrogen-play-role-decarbonization-treasury-needs-45v-right/.

Wikipedia

{{cite press release |last1=Han |first1=Hagan |last2=Saltzman |first2=Veronica |last3=Kent |first3=Emily |last4=Starr |first4=Rachel |title=Hydrogen can play a role in decarbonization, but Treasury needs to get 45V right |publisher=Clean Air Task Force |date=5 April 2024 |url=https://www.catf.us/2024/04/hydrogen-play-role-decarbonization-treasury-needs-45v-right/ |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{han2024hydrogen, author = {Han, Hagan and Saltzman, Veronica and Kent, Emily and Starr, Rachel}, title = {{Hydrogen can play a role in decarbonization, but Treasury needs to get 45V right}}, publisher = {Clean Air Task Force}, year = {2024}, month = apr, url = {https://www.catf.us/2024/04/hydrogen-play-role-decarbonization-treasury-needs-45v-right/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }