Hydrogen Under 45V: Analyzing Electricity Availability Under Proposed Rules for the Hydrogen Tax Credit

This report by RMI analyzes the availability of Energy Attribute Certificates (EACs) required to qualify for the US Inflation Reduction Act's 45V Clean Hydrogen Production tax credit. The analysis focuses on the 'three pillars' of the proposed rules—new, nearby, and hourly matched power—and evaluates whether these requirements can be met across seven Regional Clean Hydrogen Hubs (H2Hubs). RMI finds that while there is sufficient projected clean electricity capacity to meet current hub goals, the primary obstacles to scaling the industry are underdeveloped EAC markets, data infrastructure, and physical grid bottlenecks rather than a lack of available clean energy attributes.

• The proposed 45V Clean Hydrogen Production tax credit offers a 10-year incentive of up to $3 per kilogram of hydrogen, contingent on three 'pillars': power must be from facilities placed into service no more than 36 months before the project starts, must be from the same Transmission Needs Region, and must be hourly matched by 2028.
• Preliminary analysis indicates that there are enough projected tax credit-qualifying EACs to meet the stated electrolytic hydrogen production goals for each of the seven Regional Clean Hydrogen Hubs.
• By 2035, if all forecasted eligible clean attributes were dedicated to hydrogen production, the US could potentially produce an average of 24 million metric tons of hydrogen per year using approximately 210 GW of electrolyzers.
• Regional availability of qualifying electricity varies; the Plains and Midwest regions could support hydrogen production levels significantly higher than current hub proposals, whereas the Northwest region has more limited qualifying electricity and faces higher competition for EACs.
• The primary near-term bottleneck for the 45V credit is not the physical availability of clean power, but the lack of mature markets, contracts, and data infrastructure needed to trade and verify hourly EACs.
• Competing demand for hourly EACs, particularly from the data center sector—which is projected to grow from 17 GW to 35 GW by 2030—could reduce the market depth available to hydrogen producers and increase pricing.
• The ultimate barriers to the green hydrogen economy are physical infrastructure constraints rather than accounting issues, specifically citing siting, permitting, interconnection, and regional transmission.

APA

RMI (2024). Hydrogen Under 45V: Analyzing Electricity Availability Under Proposed Rules for the Hydrogen Tax Credit. https://rmi.org/resources/hydrogen-under-45v-analyzing-electricity-availability-under-proposed-rules-for-the-hydrogen-tax-credit/

Chicago

RMI. Hydrogen Under 45V: Analyzing Electricity Availability Under Proposed Rules for the Hydrogen Tax Credit. 2024. https://rmi.org/resources/hydrogen-under-45v-analyzing-electricity-availability-under-proposed-rules-for-the-hydrogen-tax-credit/.

Wikipedia

{{cite report |author=RMI |title=Hydrogen Under 45V: Analyzing Electricity Availability Under Proposed Rules for the Hydrogen Tax Credit |date=12 April 2024 |url=https://rmi.org/resources/hydrogen-under-45v-analyzing-electricity-availability-under-proposed-rules-for-the-hydrogen-tax-credit/ |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{rmi2024hydrogen, author = {{RMI}}, title = {{Hydrogen Under 45V: Analyzing Electricity Availability Under Proposed Rules for the Hydrogen Tax Credit}}, institution = {RMI}, year = {2024}, month = apr, url = {https://rmi.org/resources/hydrogen-under-45v-analyzing-electricity-availability-under-proposed-rules-for-the-hydrogen-tax-credit/}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }