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1,265 documents from Clean Air Task Force
COMMENTS OF CLEAN AIR TASK FORCE
The document argues that Section 45Z should prioritize low-carbon aviation fuels and avoid over-subsidizing biofuels with high indirect emissions. It recommends modifying the GREET model to align with CORSIA standards for indirect land use change (ILUC) and cautions against using negative emissions values or fugitive methane from oil and gas as feedstocks. Additionally, it advocates for the eligibility of synthetic sustainable aviation fuel (SAF) and the independent application of tax credits across the fuel value chain.
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Document type: Statement
NEPA Recommendations for Regional Clean Hydrogen Hubs
The Clean Air Task Force (CATF) recommends that the U.S. Department of Energy (DOE) use a programmatic NEPA analysis with tiered analyses for individual projects within each hydrogen hub to manage varying project schedules and cumulative impacts. CATF advises the DOE to build internal capacity, coordinate early with federal and state resource agencies, and provide consistent technical guidance and templates to applicants. To ensure transparency and environmental justice, the document suggests implementing public dashboards, regional scoping meetings, and accessible communication strategies to engage local communities.
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Document type: Statement
Beyond NEPA: Understanding the complexities of slow infrastructure buildout
The document challenges the narrative that the National Environmental Policy Act (NEPA) is the main cause of infrastructure delays, citing research that points instead to lack of agency resources and poor coordination. It suggests that rather than dismantling NEPA, policymakers should focus on increasing agency funding, harmonizing state and federal processes, and improving community engagement.
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Document type: Statement
Carbon capture and storage: What can we learn from the project track record?
The report analyzes 13 large-scale CCS projects across various industries, including natural gas processing, hydrogen production, power generation, steel, and cement. It finds that while many projects have met high technical standards, others have faced significant operational hurdles, often due to a lack of climate-focused incentives or unexpected geological challenges. The document argues that transparent reporting and robust climate-driven policies are essential to ensure future projects maximize their emissions reduction potential.
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Document type: Report
Climate-Beneficial Bioenergy: Opportunities and Challenges
The document introduces "climate-beneficial bioenergy," a concept developed by the Clean Air Task Force (CATF) to distinguish modern, climate-positive bioenergy from conventional systems that may cause deforestation or disrupt food supplies. To be climate-beneficial, systems must couple biomass with engineered processes to permanently store carbon, potentially achieving net carbon dioxide removal (CDR). The author argues these systems are essential for hard-to-decarbonize sectors and for counterbalancing residual emissions in sectors like agriculture. Key attributes include using waste streams, non-food crops on marginal land, or forest thinnings, and employing technologies such as gasification or pyrolysis with carbon capture and storage (CCS). The document emphasizes the need for lifecycle assessments and policy safeguards to prevent detrimental environmental and social impacts.
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Document type: Research paper
Two key ways EPA can fast track air permitting reforms to advance cleaner, low-carbon technologies
The Clean Air Task Force proposes two specific regulatory changes to EPA air permitting to advance cleaner industrial technologies. First, it urges the EPA to end the "redefining the source" policy, which currently allows permitting authorities to exclude zero-emission technologies from Best Available Control Technology (BACT) evaluations if they are deemed to change the project's fundamental nature. Second, it calls for a formal rulemaking process to ensure that "alternatives" presented during public hearings are fully evaluated, providing a mechanism for community engagement and the consideration of cleaner options outside the BACT analysis.
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Document type: Statement
Testimony Before the United States House Natural Resources Subcommittee on Energy and Mineral Resources H.R. 8665 – Supercritical Geothermal Research and Development Act and H.R. 7053 – Orphaned Well Grant Flexibility Act
The Clean Air Task Force (CATF) advocates for the passage of H.R. 8665 to accelerate the development of supercritical geothermal energy, which it describes as a high-density, 24/7 carbon-free power source capable of meeting significant energy demands. CATF argues that while the bill's structure is sound, its current $5 million annual allocation is insufficient to cover even a single deep geothermal well. Additionally, the testimony supports H.R. 7053 to provide states with more flexibility in using Bipartisan Infrastructure Law funds for plugging orphaned wells by reducing mandatory, costly methane measurements. CATF emphasizes that the U.S. can leverage its existing oil and gas workforce and subsurface expertise to lead in next-generation geothermal innovation, competing with countries like China, New Zealand, Japan, and Iceland.
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Document type: Statement
Waste Clinics: A practical approach to identify challenges and solutions for solid waste management
The document outlines the 'Waste Clinic' methodology, where local government representatives (patients) and waste management experts (doctors) collaborate to address solid waste challenges. It details a structured process involving planning—such as selecting decision-makers and regional experts—and a five-session execution phase including expert presentations, challenge identification, and solution development. Based on experience in Colombia, Mexico, and Ecuador, the Clean Air Task Force (CATF) recommends a two-day format and the use of hypothetical city scenarios to encourage more open problem-solving.
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Document type: Guide
Advocating for climate and clean air rules after a Supreme Court power grab
The document argues that recent Supreme Court rulings have shifted power from subject matter experts in federal agencies to the judiciary, creating regulatory instability and making it harder to defend environmental protections. It specifically analyzes the blocking of the Good Neighbor Rule, the elimination of Chevron deference, the expansion of statutes of limitations for challenging regulations, and the restriction of agency-led civil penalty enforcement. The author contends that these changes will lead to a 'tsunami of lawsuits' and a patchwork of conflicting legal interpretations, necessitating more rigorous technical and legal justifications for new agency rules.
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Document type: Legal commentary
Joint CATF-EDF principles on methane reporting for 45V
The Clean Air Task Force (CATF) and Environmental Defense Fund (EDF) argue that the 45V Clean Hydrogen Production Tax Credit must use accurate, granular, and verified methane emission data rather than a national average to ensure the incentive drives truly clean hydrogen production and incentivizes upstream methane reductions.
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Document type: Statement
With Good Neighbor Rule ruling, it’s the Supreme Court’s world now. We’re just trying to breathe in it.
The author critiques the US Supreme Court's 5-4 decision to temporarily block the EPA's Good Neighbor Rule, which aimed to limit nitrogen oxide emissions from power plants and industrial sources in 23 states. The commentary argues that the Court disregarded significant public health benefits—including the prevention of 1,300 premature deaths in 2026 alone—and bypassed the standard judicial process by acting as a 'court of first view' rather than review. The author contends that the Court is inappropriately assuming a regulatory role ('Super-EPA') by making rushed assessments of highly technical environmental records without full briefing from lower courts.
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Document type: Legal commentary
How the Alliance for Renewable Clean Hydrogen Energy Systems (ARCHES) Hydrogen Hub benefits California
The Alliance for Renewable Clean Hydrogen Energy Systems (ARCHES) Hydrogen Hub is projected to create 220,000 direct jobs in California, including 130,000 in construction and 90,000 permanent positions. The initiative encompasses 35 major projects located across the Los Angeles Basin, Bay Area, Central Valley, and Inland Empire. The hub is supported by an extensive network of partners spanning government agencies, labor unions, academic institutions, and private sector companies across the energy, transportation, and technology industries.
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Document type: Fact sheet
How the Midwest Alliance for Clean Hydrogen (MachH2) benefits Illinois, Indiana, Iowa, and Michigan
The Midwest Alliance for Clean Hydrogen (MachH2) is projected to create 13,600 direct jobs, including 12,100 in construction and 1,500 permanent positions, through eight major projects in Illinois, Indiana, Iowa, and Michigan.
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Document type: Fact sheet
Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program, Attention: AMS–LP–24–0012 (89 Fed. Reg. 46,335)
The Clean Air Task Force (CATF) urges the USDA to implement a high bar for quality when listing carbon credit protocols under the Greenhouse Gas Technical Assistance Provider and Third-Party Verifier Program. CATF argues that low-quality credits undermine market integrity and financial returns for landowners. They propose a framework based on four core competencies: non-permanence risk reduction, additionality and baseline establishment, quantification and monitoring, and leakage accounting. CATF specifically warns against listing soil carbon protocols due to durability and monitoring issues and suggests that the USDA provide information on non-offset mechanisms for climate-smart practices.
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Document type: Statement
Last call for Europe’s climate plans: EU countries’ final submission for 2030 goals nears
The Clean Air Task Force (CATF) asserts that current draft National energy and climate plans (NECPs) are insufficient for meeting the EU's 2030 targets. The organization calls for Member States to adopt technology-neutral strategies, increase financial transparency, and provide detailed roadmaps for carbon capture, methane mitigation, and nuclear energy before the June 30, 2024, submission deadline.
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Document type: Statement
Laws in Order: An Inventory of State Renewable Energy Siting Policies
The report provides a comprehensive inventory of state-level renewable energy siting policies in the United States and Puerto Rico. It details which government entities hold jurisdictional authority for permitting large-scale wind and solar projects, examines established timelines for these processes, and outlines requirements for public involvement. Additionally, the document assesses the availability of model ordinances and permitting guides intended to support local jurisdictions.
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Document type: Report
From Bonn to Baku: Finding success in a geopolitically challenged year for climate action
The briefing outlines key priorities for COP29, including climate finance, methane abatement, and technology partnerships, while warning that the cancellation of 2024 regional climate weeks necessitates increased climate action outside the formal UNFCCC process.
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Document type: Briefing
Ecosystem Carbon Management: A Paradigm Shift
The Clean Air Task Force (CATF) proposes 'ecosystem carbon management' to encompass both conventional biological carbon storage and novel technological approaches. Conventional methods, such as sustainable forestry and agricultural practices, provide immediate mitigation potential but face risks of reversal. Novel approaches, including enhanced rock weathering, ocean alkalinity enhancement, and biochar, aim for permanent storage over centuries or millennia. The document argues for a balanced deployment of these tools and the development of policy structures to provide financial incentives and safeguards for these emerging technologies.
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Document type: Fact sheet
Hydrogen in the Power Sector: Limited Prospects in a Decarbonized Electric Grid
The report finds that while burning hydrogen in power plants is technically feasible, it is likely not a cost-effective solution for bulk power production or load following. The authors highlight significant inefficiencies, such as a 24% round-trip efficiency for electrolytic hydrogen, and high costs for necessary geological storage and transport infrastructure. Lifecycle emissions reductions for hydrogen derived from natural gas with carbon capture are limited (averaging 50%) due to upstream methane leaks. The report concludes that clean hydrogen production should be prioritized for heavy industry and transportation rather than the power sector, where clean firm generation (e.g., nuclear, geothermal) or other storage options (e.g., pumped storage hydropower) are generally more economical.
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Document type: Report
Economic Indicators Report The Ironbound Community Newark, New Jersey
The Ironbound community in Newark, New Jersey, is a vibrant immigrant neighborhood facing significant economic distress, characterized by low median household incomes, high housing cost burdens, and a job market dominated by low-paying service and logistics roles. While employment and average wages have grown since 2015, the community suffers from a mismatch where high-paying jobs are largely filled by non-resident commuters, and residents often work in low-barrier 'Tier 3' occupations that do not provide a living wage. The area also faces environmental burdens from chemical contamination and diesel truck traffic, compounding the social and economic isolation of its residents.
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Document type: Report