Tell the IRS: Don’t Let Dirty Hydrogen Derail Clean Energy

What if a hundred billion dollars in taxpayer money meant to help speed up the clean energy transition went and increased climate pollution instead?

Pretty bad, right?

The problem is that guidance from the IRS may not go far enough to require that hydrogen fuel is produced and used in a way that makes it truly "clean."

So power plants could end up using hydrogen to meet key EPA climate rules while actually increasing climate pollution—badly eroding the climate and public health benefits of those rules.

Unfortunately, the fossil fuel industry is currently dominating the conversation on this, which is why we need you to add your voice.

Call on the IRS to stop dirty hydrogen from derailing the clean energy transition.

Dear Commissioner Werfel:

I’m writing about docket IRS-2022-0029 because I have grave concerns about the potential for climate investments from the Inflation Reduction Act to go toward standing up a hydrogen industry that may be bad for our climate. The IRS must not channel billions of dollars in public funds to hydrogen produced with fossil-fueled power plants. I urge you to ensure that the 45V guidance clearly links all new publicly-funded hydrogen production to clean energy only, by requiring applicants to adhere to all of the "three pillars" needed to track electricity.

Additionality, deliverability, and hourly-matching should all apply immediately to all applicants. As the Clean Air Task Force and the Natural Resources Defense Council noted in their detailed comments(1), these three pillars are not only supported by the text of the IRA legislation but are in fact required to fulfill its purpose.

Weaker guidance would undermine the goals of the Inflation Reduction Act, and weaken EPA's carbon pollution standards for power plants by causing potentially hundreds of millions of tons of excess power sector emissions. That would be a disaster for public health and for the climate. IRS should follow the science and the clear letter of the law and require the three pillars to ensure hydrogen production drives forward clean energy, not more fossil fuel emissions.

Thank you for your time and consideration.

(1) https://www.nrdc.org/sites/default/files/2023-04/nrdc-catf-memo-ira-45v-legal-necessity-3-pillars-20230410.pdf

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