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ACC comments on 45V clean H2 production tax credit proposal

The American Chemistry Council (ACC) issued the following statement after submitting comments to the Internal Revenue Service in response to the Section 45V Clean Hydrogen Production Tax Credit Notice of Proposed Rulemaking.

“The chemical sector is a primary source of H2 today and a promising sector for lower-emissions H2 production and use in the future. Chemistry companies can build on their deep process expertise, existing commercial and distribution channels, and opportunities to build new markets. As part of a diverse U.S. energy portfolio, H2 can help reduce emissions in manufacturing and beyond.

“The Inflation Reduction Act’s (IRA) 45V tax credit and the Bipartisan Infrastructure Law’s (BIL) Regional Clean Hydrogen Hubs (H2Hubs) program are essential catalysts for rapid, nationwide investment in a lower-emissions H2 economy. This build-out is important to ACC member companies and critical to achieving meaningful progress on the Biden administration’s climate goals.

“Our comments highlight principles for effective implementation of Section 45V and other IRA/BIL programs. These include support for diverse sources and processes, including all forms of lower-emissions H2 production technologies; regulatory certainty to enable timely investment decisions; access to infrastructure, feedstocks, and innovative chemistries; and complementary policies for building out a lower-emissions electric grid.

“Projects should be allowed and encouraged to refine the default assumptions in the 45VH2-GREET model with valid data, which would help incentivize innovation and emissions reduction. The administration must guard against regulatory overreach in interpreting its Section 45V tax credit authority.

“We look forward to engaging with the administration regarding ways to address industrial emissions reduction through opportunities provided by the IRA, BIL, and other authorities. The chemistry industry is an essential stakeholder and future partner in these efforts.”