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TEN-T and CO2 to permanent storage – a positive step for Europe’s industrial decarbonisation plan
Nearly all pathways towards EU climate neutrality by 2050 highlight the need for the deployment of CO2 capture, transport, and storage to reach our climate goals. The recent EU Industrial Carbon Management Strategy and 2040 Climate Target Communication further highlight the essential role of carbon capture and storage (CCS) for…
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D.C. Circuit reaffirms a critical and longstanding component of the Clean Air Act, allowing California to move forward with program to reduce emissions and air pollution from cars and trucks
A D.C. Circuit panel unanimously dismissed and rejected challenges to the U.S. EPA’s decision to reinstate its waiver to California’s Advanced Clean Car Program.
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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.
