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Accounting for soil organic carbon for section 40B eligibility is neither aligned with statute or technologically feasible
CORSIA and the current version of Department of Energy’s GREET model do not align on crediting changes in organic carbon in cultivated soils.
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GREET underestimates indirect land use change, undermining the climate benefits of section 40B
GREET underestimates indirect land use change compared to the Carbon Offsetting and Reduction Scheme for International Aviation.
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Alternative incrementality compliance pathways for section 45V hydrogen production tax credit
A 5% exemption to incrementality is too broad and will increase systemwide emissions, contrary to the text and intent of section 45V.
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Systemwide emissions and the importance of the three pillars for section 45V hydrogen production tax credit
The text of section 45V requires an evaluation of systemwide emissions impacts when assessing lifecycle greenhouse gas emissions.
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Carbon intensities of qualified clean hydrogen for 45V tax credits should be determined on a kilogram-by-kilogram approach
The section 45v tax credit should be awarded using a two-step approach for determining lifecycle emissions.
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Fixed upstream emission rates undermine the climate benefits of section 45V hydrogen production tax credit
U.S. Treasury Department’s proposed fixed rates are both over- and under-inclusive of true upstream emissions.
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Hydrogen can play a role in decarbonization, but Treasury needs to get 45V right
Hydrogen itself may be critical to our ability to reach net-zero because of its potential to decarbonize hard-to-abate sectors.
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Evidence-Based Recommendations for Overcoming Barriers to Federal Transmission Permitting
This report establishes a comprehensive evidentiary record of permitting challenges faced by electric transmission projects and offers fact-based insights into: What prevents the transmission buildout needed to achieve federal and state policy goals; The levels (federal, state, local) and/or nexuses (e.g., developer-community relations) at which transmission permitting faces critical hurdles;…
