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UCS Testimony on the Clean Hydrogen Production Tax Credit

Union of Concerned Scientists

Because the 45V credit has the potential to dramatically accelerate investments in hydrogen production infrastructure, it’s critical that implementation of the credit ensures that “qualified clean hydrogen” is indeed climate-aligned from the outset. Hourly matching.

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Proposed Electrolyzer Requirements for the Hydrogen Tax Credit: Strengths and Risks

Union of Concerned Scientists

Foremost among these is a legal memo from EPA regarding Treasury’s interpretation and implementation of “lifecycle greenhouse-gas emissions” in 45V. The proposed regulations require a shift to hourly matching for all hydrogen producers in 2028—including those operating before that date who are allowed to use annual matching in the interim.