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DateDocumentOrganization and type
Systemwide emissions and the importance of the three pillars
The document explains that section 45V's requirement to evaluate lifecycle greenhouse gas emissions necessitates a systemwide approach to electricity sourcing for hydrogen production. It warns that without strict guardrails, electrolytic hydrogen could produce 10–40 kg CO2e/kg H2 due to grid impacts. To achieve near-zero systemwide emissions, the author advocates for the 'three pillars': incrementality, hourly matching, and deliverability.
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Document type: Statement
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