Implementation of the IRA 45V clean hydrogen tax credits as it relates to guidelines for emissions accounting of grid-connected electrolyzers

A coalition of organizations argues that weak guidelines for the 45V clean hydrogen tax credit could lead to increased net emissions and wasteful subsidies. They advocate for a 'three-pillar' system—additionality, deliverability, and hourly matching—to ensure hydrogen is truly low-carbon. The authors assert that these requirements are technically and economically feasible, citing existing tools like M-RETS and EnergyTag, as well as similar standards already adopted in the EU and UK.

• Insufficiently rigorous guidance for grid-connected electrolyzers could result in the U.S. Treasury spending over $100 billion in subsidies for projects that actually increase net emissions, potentially producing at least twice the carbon emissions of traditional gas-derived hydrogen.
• The coalition advocates for a three-pillar emissions accounting system consisting of additionality, deliverability, and hourly matching to ensure compliance with the IRA's requirement to reduce 'effective GHG emissions'.
• Hourly matching is presented as a feasible and available requirement, supported by existing infrastructure such as M-RETS, which has over 100 million hourly RECs, and EnergyTag. The document notes that regional registries can implement these tools in 12 to 18 months, which is faster than the 24-month timeline for large-scale electrolyzer deployment.
• International policy trends support the three-pillar approach, with the European Union's Hydrogen Delegated Act requiring hourly matching from 2030 onwards and the U.K. hydrogen standard already requiring it.

APA

Clean Air Task Force (2023). Implementation of the IRA 45V clean hydrogen tax credits as it relates to guidelines for emissions accounting of grid-connected electrolyzers. https://cdn.catf.us/wp-content/uploads/2023/02/23171218/joint-letter-45v-implementation.pdf

Chicago

Clean Air Task Force. Implementation of the IRA 45V clean hydrogen tax credits as it relates to guidelines for emissions accounting of grid-connected electrolyzers. 2023. https://cdn.catf.us/wp-content/uploads/2023/02/23171218/joint-letter-45v-implementation.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Implementation of the IRA 45V clean hydrogen tax credits as it relates to guidelines for emissions accounting of grid-connected electrolyzers |date=23 February 2023 |url=https://cdn.catf.us/wp-content/uploads/2023/02/23171218/joint-letter-45v-implementation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2023implementation, author = {{Clean Air Task Force}}, title = {{Implementation of the IRA 45V clean hydrogen tax credits as it relates to guidelines for emissions accounting of grid-connected electrolyzers}}, publisher = {Clean Air Task Force}, year = {2023}, month = feb, url = {https://cdn.catf.us/wp-content/uploads/2023/02/23171218/joint-letter-45v-implementation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }