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The document warns that loosening the 'three pillars' of 45V rules—additionality, deliverability, and hourly matching—will lead to higher consumer electricity costs. It explains that because electrolyzers are massive electricity users, expanding their use without corresponding new clean generation forces markets to use more expensive generators. The author draws parallels to cryptocurrency mining in Texas and New York, where increased demand raised wholesale prices. Citing studies from Princeton University's ZERO Lab and TU Berlin, the briefing suggests that failing to enforce these rules could result in double-digit percentage increases in electricity prices, with specific projections of 8% in California and 10% in Colorado.

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  • Failure to implement the three pillars of additionality, deliverability, and hourly matching for 45V credits could lead to significant electricity price hikes. A Princeton University ZERO Lab study indicates potential price increases of 8 percent in California and 10 percent in Colorado, while a TU Berlin study found a 43 percent increase in power prices due to weak hydrogen production rules.
  • Electrolyzers act as large electricity users; without new clean generation to match their demand, they push markets toward more expensive generators, raising wholesale prices. The scale of this impact is expected to be greater than that of cryptocurrency mining, as meeting the DOE's 10 MMT annual clean hydrogen goal via electrolysis would use 12% of current U.S. electricity usage, compared to crypto-assets' 0.9% to 1.7%.
  • The document uses cryptocurrency mining as a proxy for the price impacts of new electrolyzer demand. In Texas, wholesale power prices increased by 2 percent for every gigawatt (GW) of extra load from cryptominers. In Upstate New York, increased consumption from cryptominers resulted in annual costs of $204 million for households and $92 million for small businesses.
  • Annual matching is insufficient to protect consumers because electrolyzers operate 24/7 while clean generation is intermittent. Due to the increasing slope of the supply curve, the price increases caused by steady electrolyzer use will outweigh the price suppression effects of clean generation that is concentrated during specific periods.

Cite the original document

APA
Gimon, E. (2023). Consumer Cost Impacts of 45V Rules. Energy Innovation. https://energyinnovation.org/wp-content/uploads/Consumer-Cost-Impacts-of-45V-Rules-2.pdf
Chicago
Gimon, Eric. Consumer Cost Impacts of 45V Rules. Energy Innovation, 2023. https://energyinnovation.org/wp-content/uploads/Consumer-Cost-Impacts-of-45V-Rules-2.pdf.
Wikipedia
{{cite report |last1=Gimon |first1=Eric |title=Consumer Cost Impacts of 45V Rules |publisher=Energy Innovation |date=November 2023 |url=https://energyinnovation.org/wp-content/uploads/Consumer-Cost-Impacts-of-45V-Rules-2.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{gimon2023consumer, author = {Gimon, Eric}, title = {{Consumer Cost Impacts of 45V Rules}}, institution = {Energy Innovation}, year = {2023}, month = nov, url = {https://energyinnovation.org/wp-content/uploads/Consumer-Cost-Impacts-of-45V-Rules-2.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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