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Policy Integrity Recommendations Reflected in Treasury’s Hydrogen Tax Credit Proposal

On December 22nd, the Treasury Department issued a notice of proposed rulemaking to implement the Inflation Reduction Act’s (IRA) 45V tax credit for clean hydrogen production. The proposal would establish rules for how electrolyzers can demonstrate compliance with the IRA’s lifecycle greenhouse gas limits—and thus demonstrate their eligibility for the tax credit. The proposed rule includes robust requirements to avoid greenhouse gas emissions: new clean power, annual matching with a transition to hourly matching in 2028, and contracting within the same regional grid. The approach in this proposal aligns with many of the recommendations the Institute for Policy Integrity made in comments to the Treasury Department