Kilogram-by-kilogram approach for determining the carbon intensity of qualified clean hydrogen

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The Clean Air Task Force proposes a two-step method for section 45V tax credits to prevent producers from losing top-tier credits due to brief periods of grid electricity use during maintenance or supply disruptions.

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  • Annual averaging of carbon intensity disproportionately penalizes hydrogen producers who must temporarily use grid electricity to maintain stable operations for customers during maintenance or clean electricity interruptions.
  • Under current proposed Treasury guidance, using grid electricity for as little as 4 to 11 days (1-3% of the year) can cause all hydrogen produced throughout the year to drop out of the top tier of section 45V tax credits.
  • The Clean Air Task Force proposes a two-step approach: first, a facility must meet an annual average of no more than 4 kg CO2e/kg H2 to be a "qualified clean hydrogen production facility," and second, credits should be calculated and awarded for each hour of production separately.
  • A hypothetical scenario illustrates that for a supplier producing 10,000 kg/hour, using grid electricity for 6.6 days (1.8% of the year) would result in a loss of $170.4 million in tax credits under proposed guidance compared to the proposed kilogram-by-kilogram approach.

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APA
Hunt, K. (2024). Kilogram-by-kilogram approach for determining the carbon intensity of qualified clean hydrogen. Clean Air Task Force. https://www.catf.us/2024/04/treasury-should-award-section-45v-tax-credits-based-carbon-intensities-qualified-clean-hydrogen-kilogram-by-kilogram-basis/
Chicago
Hunt, Kara. Kilogram-by-kilogram approach for determining the carbon intensity of qualified clean hydrogen. Clean Air Task Force, 2024. https://www.catf.us/2024/04/treasury-should-award-section-45v-tax-credits-based-carbon-intensities-qualified-clean-hydrogen-kilogram-by-kilogram-basis/.
Wikipedia
{{cite report |last1=Hunt |first1=Kara |title=Kilogram-by-kilogram approach for determining the carbon intensity of qualified clean hydrogen |publisher=Clean Air Task Force |date=5 April 2024 |url=https://www.catf.us/2024/04/treasury-should-award-section-45v-tax-credits-based-carbon-intensities-qualified-clean-hydrogen-kilogram-by-kilogram-basis/ |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{hunt2024kilogrambykilogram, author = {Hunt, Kara}, title = {{Kilogram-by-kilogram approach for determining the carbon intensity of qualified clean hydrogen}}, institution = {Clean Air Task Force}, year = {2024}, month = apr, url = {https://www.catf.us/2024/04/treasury-should-award-section-45v-tax-credits-based-carbon-intensities-qualified-clean-hydrogen-kilogram-by-kilogram-basis/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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