Commenter Name
Signed By
Topic
Comment
Document
3Degrees Group Inc
Maya Kelty, Senior Director
45V ; pro-book-and-claim; REC
tracking systems; quarterly granularity of REC tracking;
regionality of geographic eligibility
Aaron Bergman/Resources for the
Future
Aaron Bergman
Determining lifecycle GHG emissions
from Electricity Consumption
Aaron Bergman/Resources for the Future Comments
(1)
Advanced Biofuels Association
(ABFA)
Michael McAdams, President
Endorses GREET; broad view of
produced “in the United States”
Advance Energy Economy (AEE)
Ryan Gallentine,
45W; 30C
American Fuel & Petrochemical
Manufacturers Association (AFPM)
Conner Brace, Senior Manager,
Government Relations
Definition of “facility”
for 45V as independent clean hydrogen production train and, for
45Z, portion of refinery that produces qualifying fuel;
determination of well-to-gate emissions; allocation to co-product
depends on use of co-product; credit for part-year production;
alignment with DOE CHPS; provisional emissions rates;
pro-book-and-claim; 45Z:include sales to marketer/traders;
off-highway applications; credits for negative emissions
American Fuel & Petrochemical
Manufacturers
Association (AFPM) Comments
Air Company
Natalia Sharova, Manager
SAF – coordination of 45Z and 45Q;
coordination of 45Q and 45V in the case of direct air capture;
third-party verification; annual granularity of time matching;
hydrogen carriers (methanol) for 48E; producer-specific GHG rates
for 45Z;
Air Liquide
Dave Edwards, Director
45V: alignment with DOE CHPS;
include avoided methane emissions in GHG assessment; include RECs
in GHG emission evaluation; hydrogen purity; include liquefaction
in GHG evaluation; allocation to co-products on an energy basis;
credit for part-year production; minimum monthly time matching for
granularity;
Air Products & Chemicals
Inc.
Eric Guter, VP
45V: alignment with DOE CHPS;
exclude post-hydrogen production processes such as liquefaction;
clarify that cracking of ammonia is production for 45V; elective
co-product allocation; credit for part-year production; establish
default GHG emissions rates; provisional emissions rates;
pro-book-and-claim; 45(d)(4)(B)(ii) should have no minimum dollar
threshold for capitalized expenses; 45V(d)(4) placement in service
prevents 45V(d)(2) disallowance; coordination of 45Z and 45V
Airlines for America (A4A)
Tim Pohle
Endorses GREET model; certification
of SAF;
Airports Council Int’l
Melinda Pagliarello
Signatory to SAF BTC Coalition
letter
Alder Fuels
Nancy Young, Chief Sustainability
Officer
Endorses GREET for SAF
Alternative Fuels & Chemicals
Coalition
Rina Singh, Exec VP
45V: pro-book-and-claim for RECs
from RNG or other renewable fuel sources
American Chemistry Council
Kimberly White
GREET alternatives; technologies and
accounting systems should be performance based; coordination of 45V
and 45Q; modifications needed to move to higher tier of 45V
credits; provisional rates; clarify “suitable for use as a
fuel in highway vehicles”
American Clean Power Association
Gene Grace, General Counsel
Acquired renewable power reduces
GHGs; international sale or use; endorses DOE’s CHPS;
allocation to co-products through system expansion; verification
methods; supports book-and-claim, discusses methods; losses on
sales of; ITC for types of energy storage; storage as a “use” of hydrogen; direct pay election by transferee;
components of a clean hydrogen facility; hydrogen storage
American Council on Renewable Energy
(ACORE)
48 ITC for 45V hydrogen facilities
under 48(a)(15); endorses bundled RECs; hourly matching too
granular;
American Gas Association
Allison Cunningham
Circumstances when 45Q and 45V at
same facility; 45Z should incentivize non-transportation use
American Lung Association
Only green hydrogen, not blue
hydrogen should be considered clean hydrogen
American Soybean Association
Brad Doyle, President
45Z; endorses GREET model over
CORSIA
Amp Americas
Ethan Hendricks, SVP
Dairy waste RNG; 45Z – broad
interpretation of “suitable for use as a fuel in a highway
vehicle”; tables of annual emissions rates using GREET need;
facility-specific GHG determinations needed; pro-book-and-claim;
gallon equivalent; requests express inclusion of biogas from
livestock into power within 45Z(d)(4)qualified facilities; 45Z and
other allowed credits; –
Anew Climate, LLC
Mihaly Wekler, VP
Pro-book-and-claim; displacement
method of allocation to co-products; credits for part year
production; third-party verification; monthly granularity of time
matching; provisional emissions rates; 45Z-SAF- GREET over CORSIA;
negative CI score credits
Anonymous
Anonymous
Electrolyzer power should be local
and hourly matched
Anonymous
Question as to availability of 45V
for certain process
Anonymous
Question regarding both 45E and
45V
Antora Energy
Justin Briggs
Alternating between 45Z and 45Q in
different years; RECs with hourly matched certification; no
additionality requirement; provisional pathway petitions; negative
emission results; volumetric gallon basis; coordinating 45Z and 45Q
when fuel is used to produce another transportation fuel
Apex Clean Energy
Mark Goodwin, President
45V: alignment with DOE CHPS;
pro-book-and-claim; annual time matching for granularity; clarify
sale or use internationally is permitted
API – American Petroleum
Institute
Aindriu Colgan, Director
45V: well-to-gate; allocation to
co-products; verification; alignment with DOE CHPS; provisional
rates; recordkeeping; pro-book-and-claim; coordination with 45Q;
availability of both in certain circumstances; definition of “facility” ; 45Z definition of “transportation
fuel” ; SAF emissions methodology; gallon equivalent;
Archer Daniels Midland Company
Alix Dowling, VP Global Tax
45Z: GREET is similar to CORSIA; SAF
GHG rate method should be taxpayer-specific; coordination and
availability of both 45Z and 45Q and other credits in certain
circumstances
Arkema Inc.
Endorses American Chemistry Council
comments
Attorneys General of Massachusetts,
11 other states and the California Air Resources Board
Numerous
Environmental justice; blue hydrogen
might not qualify for 45V
Attorneys General of Massachusetts,
11 other states and the California
Air Resources Board Comments
Australian Government
Encourages emissions accounting
methodology to be aligned with the International Partnership for
Hydrogen and Fuel Cells in the Economy (IPHE)
Bakken Energy
Chris Tillotson
Endorses DOE CHPS; recognize RSG and
avoided emissions; coordination of 45V and 45Q where facility
previously claimed 45Q
Bank of America
James Carlisle
No view on book-and-claim; recapture
of 45V when recapture of 45Q; 48(a)(15) qualified property of a
hydrogen facility
Bayer Crop Science
Leonardo Bastos, SVP
45Z: acknowledge sustainable
agricultural practices in application of GREET model
BayoTech, Inc.
45V: GREET model with RNG as
feedstock; credit for parti-year production; pro-book-and-claim;
verification; daily granularity of time matching; alignment with
DOE CPHS; provisional emissions rates;
Business Council for Sustainable
Energy (BCSE)
Lisa Jacobson, President
45V: supports well-to-gate approach;
supports alignment with DOE CHPS; pro-book-and-claim using RECS,
PPAs and environmental attributes
Bonneville Environmental Foundation
(BEF)
Evan Ramsey, Sr. Director
45V: credit for part-year
production; annual granularity of time matching; book-and-claim
considerations
Biofine Developments Northeast
Inc.
Michael Cassata
45Z definition of “transportation fuel”
Biomass Power Association
Carrie Annand, Executive
Director
Consistent with DOE CHPS; allocation
to co-products analogous to EPA’s RFS; pro-book-and-claim;
provisional rates petitions; 45Z definition of “transportation
fuel”; required “use” of fuel
Bloom Energy Corporation
Shawn Soderberg, EVP
45V – energy inputs should use
eGRIDs for carbon intensity of regional grids; annual granularity
of matching; alignment with DOE CHPS; third-party verification;
pro-book-and-claim;
BP
Downey Magallanes, Head of Policy
Advocacy
45V: allocation to co-products;
verification; annual granularity of time matching; provisional
emissions rates; pro-book-and-claim; coordination with 45Q; 45Z:
GREET model for SAF; gallon equivalents; negative emissions rates;
coordination of 45Q, 45V and 45Z; definition of “transportation fuel”;
Breakthrough Energy
45V: GHG emissions methodology
should ensure additionality, geographical matching and temporal
matching; both 45V and 45Q for independent facilities; 45Z: GREET
should be a qualifying GHG emission accounting method; provisional
emission rates
Carbon Direct
Jonathan Goldberg, CEO
45V -GHG emissions for blue hydrogen
and turquoise hydrogen should include upstream methane leakage;
allocation to co-products using market-based approach; credit for
part-year production; granularity of time-matching by hour;
monitoring for hydrogen leakage; 45Z – endorses CORSIA for SAF;
provisional rates;
Celanese Corporation
Ronnie Berry, VP Global Tax
Pro-book-and-claim; both 45V and 45Q
at certain facilities
Center for Resource Solutions
Lucas Grimes, Manager, Policy
Pro-book-and-claim, indirect book
accounting, purchases of REC and PPAs to determine hydrogen
production GHG emissions; renewable fuel certificates should be
required proof that SMR hydrogen is produced with RNG; granularity
of time matching depends on use case;
Chesapeake Utilities Corporation
45V: flexibility in definition of “qualified clean hydrogen; negative emissions from RNG; credit
for part-year production; “transportation fuel”
Clean Air Task Force
Emily Kent, US Director
45V: Global warming potential
(“GWP”) should be used to define clean hydrogen; method
of allocation to co-products dependent upon ratio of co-products to
products; credits for part-year production; hourly granularity of
input matching; alignment with DOE CHPS; provisional emissions
rates; pro-book-and-claim but only for emissions from
grid-connected electrolyzer; endorses additionality, geography
matching and temporal matching in tracking; both 45Q and 45V in
certain circumstances; 45Z: SAF – CORSIA should not be sole
method
Clean Energy Buyers Association
Priya Barua
Supports hourly timestamped energy
inputs for hydrogen production to support development of tradeable
energy attribute certificates
hourly time-stamped energy attribute certificates
Buyers Institute Comments
Clean Energy Fuels Corp
Robert Vreeland, CFO
Availability of 45Z when 48 has been
claimed; definition of “highway” vehicles; consider
avoidance of methane emissions as part of lifecycle analysis;
Clean Fuels Alliance America
Kurt Kovarik, VP
45Z: use of GREET model for SAF;
provisional emissions rates; use for non-transportation
purposes;
Clear Path
Natalie Houghtalen, Policy
Advisor
45V: well-to-gate without
post-production inputs; allocation to co-products on energy basis
or economic value basis; credit for part-year production; hourly
time matching granularity; third-party verification; minimal use of
indirect book accounting factors; hourly temporal matching and
geographic proximity; availability of both 45V and 45Q at a single
location
CNX Resources Corporation
Douglas Papa, VP Tax
Endorses GREET model; allocation to
co-products by system expansion; alignment with DOE CHPS;
provisional emissions rates; coordination of 45V and 45Q for
unrelated process trains; 45Z – GREET model should be allowed;
from biomass and landfill gas; pro-book-and-claim including
renewable thermal credits (RTCs); coordination of 45V, 45Z and 45Q
; recordkeeping; provisional rates; 45Z: unrelated persons; sale at
retail; use of GREET model for SAF; “use as a fuel in a
highway vehicle”;
Colorado Energy Office
Will Toor
Unbundled RECs vs. bundled RECS in
GHG accounting
Constellation Energy
Daniel Eggers, EVP & CFO
45V; electrolysis with nuclear
power; temporal matching; previous placed in service date; GHG
emissions rate good until change in operations; definition of “facility” to coordinate with other credits; alignment
with DOE CHPS
Covanta Energy LLC
Michael Van Brunt
Landfill gas GHG for 45V;
pro-book-and-claim
Cummins Inc.
Cathy Choi, Executive Director
45V: lifecycle GHG determination;
credit for part-year production; alignment with DOE CHPS;
pro-book-and-claim
Dimeta
Dimethyl Ether (DME); system
expansion disfavored in allocating emissions to co-products;
provisional emissions rates; pro-book-and-claim; 45Z: endorses
credit for producers of fuels used in transport or heating or
industrial sectors; encourages extending 45Z beyond 2027
Donald Crocker
Donald Crocker
Scientific comments regarding impact
of hydrogen economy on greenhouse effect
Dow Inc.
Daniel Womack, Senior Policy
Director
System expansion method for
allocation to by-products; pro-book-and-claim, regionality of
matching; coordination of 45Q and 45V when different process
streams
Earthjustice and Sierra Club
Numerous
45V: calls for rigorous carbon
accounting; endorses DOE CHPS; energy sources should have
additionality; REC retirement; hourly granularity of time matching;
disallow use of unbundled RECs; anti-book-and-claim;
Edison Electric Institute
Richard McMahon, Senior VP
Determination of lifecycle GHG;
definition of “facility”; coordination of 45V and
45Q;
with regionality and time matching; anti-requirement of
additionality or PPAs or VPPAs;
EDPR North America
Amy Carl
Definition of “qualified clean
hydrogen”; well-to-gate; tracing of part-year production;
application of GREET model; additionality; time matching; alignment
with DOE CHPS; recordkeeping; verification; book-and-claim
support;
Electric Hydrogen Co.
Beth Deane, Chief Legal Officer
45V; pro-book-and-claim with
restrictions; hourly matching; geographic matching; additionality;
fugitive emissions
Electrochaea Corporation
Allocation to co-product; annual
matching of energy inputs; align with DOE CHPS; pro-book-and-claim;
both 45Q and 45V when multiple process trains
Embassy of Brazil in Washington,
D.C.
General comments regarding 45Z as
obstacle for Brazilian exports of clean hydrogen and consistency
with WTO agreements
Enel North America, Inc.
Ryan Prescott, Head of
Development
45V: Additionality principle is
necessary; hourly granularity of time matching;
Energy Innovation
Dan Esposito, Senior Policy
Analyst
45V: tie electrolyzer operations to
emissons accounting; use electricity-based accounting scheme in the
interim; avoid loose standards; additionality;
EnergyTag
Killian Daly
Granular certificates should be
required to demonstrate clean power to electrolyzers
Environment America
Friends of the Earth, R Street
Institute, Taxpayers for Common Sense and US PIRG
Credits subsidizing ethanol may
increase GHG emissions; facilities using biomass sources should not
be considered carbon neutral
Environmental and Energy Study
Institute
Daniel Bresette, Executive
Director
45Z; need for GREET-modeled
scores
Environmental Defense Fund
45V: well-to-gate, upstream and
downstream emissions; end uses in GREET; methane emissions in
GREET; hourly granularity of time matching ; recordkeeping; deny
double benefit with 45Q; 45Z: SAF methodology should ensure food
feedstocks do not contribute to loss of natural habitats; endorse
CORSIA
Eversheds Sutherland on behalf of
Louis Dreyfus company LLC
45Z: application of GREET model;
coordination of 45Z and 45Q
Eversheds Sutherland on behalf of
Louis Dreyfus company LLC Comments
Farmer’s Business Network
Steele Lorenz, Head of Sustainable
Business
Farm-level carbon accounting policy
needed, implementing CI scoring based on fertilizer, pesticides and
fuel usage;
Fidelis New Energy LCC
45V: alignment with DOE CHPS;
allocation to co-products on a lower heating value basis with
system expansion; credits for part-year production; verification of
inputs similar to LCFS; granularity of time matching should be
hourly; provisional emissions rates; anti-book-and-claim; both 45Q
and 45V for certain facilities; 45Z: “unrelated person”
should be defined by 267; definition of “trade or
business”; flexible standard for sales “at retail”;
GREET standard for SAF;
Fortescue Future Industries
Andrew Veasey, CEO
45V: well-to-gate; use of RECs;
allocation to co-products; alignment with DOE CHPS; provisional
emissions rates; recordkeeping; coordination allowing both 48C and
45V
Friends of the earth
Numerous organizations
Anti-use of renewables to support
hydrogen production; no unbundled REC usage; anti- reduction of CI
score for biomass feedstock
Friends of the Earth
Numerous
45V: only renewably produced
hydrogen should receive credit
Fuel Cell and Hydrogen
Association
Frank Wolak, President
Definition of “qualified clean
hydrogen”; definition of “qualified clean hydrogen
production facility”; any reasonable method allocation of
emissions to co-products; GREET analysis – supports DOE’s CHPS;
certification by qualified engineers; circumstances when both 45Q
and 45V should be available; pro-book-and-claim
Fuel Cell Energy, Inc.
Jason Few
Requests guidance for existing
facility claiming 48 ITC to modify to be eligible for 45V
GE Vernova
Scott Strazik, CEO
45V: definition of “qualified
facility” should be narrow covering only property necessary
for production of hydrogen and not upstream inputs; energy inputs
need not be co-located; no additionality requirement – repowered
facilities eligible; credit for part-year production; granularity
of time matching should be flexible; coordination with 45Q;
eligibility for both in certain circumstances; 48(a)(15)
application of prevailing wage requirement;
Generate Capital
William Caesar, President
Upcycle
45Z downstream uses do not affect
credit; gallon equivalent; emissions rate calculation
Gevo
Lindsay Fitzgerald, VP Govt
Relations
Endorses GREET model for 45Z for SAF
over CORSIA; endorses annual certification; endorses
book-and-claim/RECs; requests confirmation of negative GHG for
credit rates above $1.75/gallon; annual election between 45Z and
45Q
Global Clean Energy Holdings
Amanda DeRosier, VP
Renewable diesel; coordination of
45Z with 45Q and 45V
Great Plains Institute for
Sustainable Development
Brendan Jordan, VP
45Z: granular approach including
dynamic emissions factors for farm-level emissions
Green Hydrogen Coalition
Nicholas Connell, Policy
Director
45V: well-to-gate; endorses IPHE
methodology; alignment with DOE CHPS; pro-book-and-claim with mass
balancing;
Green Peak Resources
Quinn Laws, CFO
45V: need for standardized
third-party verification process; pro-book-and-claim; need for
lifecycle GHG emission rates for feedstock natural gas
Green Plains Inc.
45Z: GREET model; coordination of
45Z and 45Q
Growth Energy
Chris Bliley, Senior VP
Endorses GREET; provisional rate
petitions; annual election between 45Q and 45Z; rounding practices
for emissions rates; gallon equivalence;
GTI Energy
Derek Wissmuller
RECs should be allowed; DOE CHPS is
murky; technical questions regarding GREET and CHPS
H Cycle, LLC
Robert Morgan CEO
Application of GREET to fuels
derived from waste biomass; coordination of 45Q and 45V for BECCS;
pro-book-and-claim;
Hgen, Inc.
45V – energy inputs should be at
hourly level of granularity
HIF Global
Endorses GREET for 45V;
pro-book-and-claim; endorses Carbon Direct’s comments; allocate
emissions to co-products using any reasonable method; annual time
matching of power inputs; provisional rates; 45V and 45Q
availability at co-located facilities
HiiROC Limited
Duncan Coneybeare, Director
45Z – thermal plasma electrolysis –
credit framework should be flexible enough to support new
processes; GREET model with new production pathways; definition of
output purity; allocation to co-products such as carbon black;
credit for part-year production; hourly granularity of time
matching; provisional emissions rates;
Hunton Andrews Kurth on behalf of
OPAL Fuels
Laura Ellen Jones
45Z: negative emissions producing
credit above $1.00; gallon equivalent; landfill gas as “biomass”; prevailing wage and apprenticeship
requirements time-restricted; definition of “qualified
facility”; availability of 48 credit; circumstances when 45Q
and 45Z both available
Hy Stor Energy LP
Definition of “facility”;
endorses DOE’s CHPS; pro-book-and-claim;
Independence Hydrogen
45V: requests clarification on the
functional unit of qualified clean hydrogen; GHG emissions
consistent with GREET; allocation to co-products on mass-basis;
chlor-alkali; credit for party-year production; verification;
alignment with DOE CHPS; provisional rates; pro-book-and-claim;
Indigo AG
Chris Harbourt
Endorses GREET model
Industrial Innovation Initiative
Zachary Byrum
Application of GREET model;
allocation to co-products; credit for part-year production; single “facility” for 45V and 45Q coordination;
Infinium Holdings, Inc./Holland
& Knight
David Zaziski, VP
Coordination of 45Q and 45V if
functionally separate processes; energy inputs from renewables or
grid
Int’l Council on Clean
Transportation
Stephanie Searle
EPA input on lifecycle analysis;
anti-RECs without additionality safeguards; endorse CORSIA for SAF;
for 45Z, use of both GREET and RFS; allocation to co-products on an
energy basis or a market-based approach; system-expansion approach;
support use of California LCFS methodology; coordination of 45V and
45Q for independent process streams;
Intersect Power LLC
45V: requests clarification
regarding application of GREET model; include marginal emissions
associated with grid-tied resources; no allocation to co-products;
careful temporal matching and hourly granularity of matching;
alignment with DOE CHPS; pro-book-and-claim;
Invenergy
45V: supports IPHE definition of
production boundaries; credit for part-year production;
verification; alignment with DOE CHPS; pro-book-and-claim; annual
time matching;
Iogen Corporation
Lori Evans, Executive VP
45V: credit for part-year
production; verification; provisional rates; recordkeeping;
Jim Bardia
Jim Bardia
Zero-emission EV charging stations
should have credit
Kolmar Americas
Elias Petersen
Supports GREET model; ability to
petition for individual determination
Koloma, Inc.
Pete Johnson, CEO
Geologic hydrogen; definition of
hydrogen should allow up to 10% non-GHG inert gases; application of
GREET model to geologic hydrogen; provisional rate petitioning;
pro-book-and-claim
Korea Int’l Trade
Association
Christopher Koo, Chairman
45V: clarification that credit is
available for clean hydrogen exported from the US; clarification of
application of GREET model
Life Cycle Associates
Stefan Unnasch, Managing
Director
45V: allocation to co-products;
GREET model usage; verification
LSB Industries
Michael Foster, Exec. VP
45V: Lifecycle GHG downstream Scope
3 should be excluded; allocation to co-products based on mass;
credit for part-year production; verification; pro-book-and-claim;
annual time matching;
Lyten, Inc.
Allocation to co-products via system
expansion; time matching on an annual basis;
pro-book-and-claim;
Maas Energy Works
Daryl Maas, CEO
45Z for RNG: separate legal entities
should constitute unrelated purchasers; confirm that apprenticeship
requirements do not apply if facility in service before 1/1/2025;
partnership special allocations of credits.
Mainstream Renewable Power
Paula Major, VP
45V: granularity of time matching
under a phased in approach to reach hourly matching
Marquis Energy
Dustin Marquis, Director
45Z: provisional emissions rates;
available of 45V when other credits “allowed”;
MIT Energy Initiative
Dharik Mallapragada
Well-to-gate analysis of GHG
emissions; possible methods of allocation to co-products; location
more important than time or vintage in indirect book accounting
Modern Electron
Tony Pan, CEO
Emissions associated with
transportation, distribution and storage of hydrogen should not be
ignored in assessing GHG; energy input matching – 5-minute level of
granularity; provisional rates; pro-book-and-claim with certain
book accounting features
Molten Industries Inc
Dr. Caleb Boyd
Incentivize use of methane pyrolysis
using RNG to produce hydrogen
Monolith Materials
Anna Wishart, Director
45V: provisional emissions rates;
LCA for life of facility; allocation to co-products under
reasonable method; pro-book-and-claim; alignment with DOE CHPS;
Mote, Inc.
Joshuah Stolaroff, CTO
45V: well-to-gate; allocation to
co-products by economic value; credit for part-year production;
provisional rates; carbon removal facilities should be an exception
to the 45Q exclusion;
Nacero Inc.
Tom Tureen, Chairman
SAF/RNG; 45Z; endorses GREET model
for SAF GHG emissions determinations; facility-specific
determinations of GHG emissions needed; pro-book-and-claim
system
National Corn Growers
Association
Tom Haag
45Z; endorses GREET over CORSIA;
negative emissions rates
National Energy & Fuels
Institute
James Collura, VP
Definition of “transportation
fuel” as relating to space and water heating
National Farmers Union
Rob Larew, President
45Z: SAF use of GREET model;
coordination with other tax credits
National Grid
Emily Duncan, VP Govt Relations
45V: use of GREET model for power
sector; 45Z: availability when RNG used for heating, cooking but
not transportation
National Hydropower Association
Michael Purdie
Production of hydrogen with
hydropower should qualify; pro-book-and-claim
National Sorghum Producers
John Duff
45Z: GREET method; coordination of
45Q and 45Z
NATSO Sigma
David Fialkov
Travel Centers and truckstops-
retail fuel industry; 45Z: clarify that GREET model is not
permitted for SAF; 45V: RECs should count in determining CI score
of hydrogen
Natural Resources Defense Counsel
(NRDC)
Rachel Fakhry
45V: GREET model; book-and-claim
implementation through successor model; additionality is key;
regionality; temporal matching hourly;
Nature Energy US LLC
Gaurav Parikh, SVP
Definition of 45Z “qualified
facility”; “use” as a fuel; use GREET scores only as
default scores; coordination of 45Z and 45V; downstream credit
availability; availability in the event of a 45Q(f)(3) transfer of
a credit
Neste US
Leslie Bellas, Federal Regulatory
Affairs Manager
45Z: renewable diesel and SAF;
meaning of “produced” in US; foreign feedstocks; SAF
Emissions Rate determinations; provisional emissions rates;
traceability; RFS;
NextEra Energy, Inc.
45V: pro-book-and-claim;
permissibility of international “sale or use” ; endorse
well-to-gate; allocation to co-products using system expansion
approach; credit for part-year production; verification; annual
time-matching granularity; alignment with DOE CHPS; provisional
emissions rates; additionality requirement would be uneconomic;
coordination with 48 for mechanical, thermal and chemical (ammonia)
storage of hydrogen; storage as a “use” of hydrogen;
hydrogen storage ITC
Nikola Corporation
Alana Langdon, Head, Government
Affairs
45V: definition of “qualified
clean hydrogen” – implementation of new technologies;
alignment with DOE CHPS; recordkeeping; coordination with 45Q
Nordex Group
Vestas American Wind; Steelhead
Americas; Intersect Power; Electric Hydrogen Co.; Synergetic LLC;
Rondo;
GREET model; eligibility for
part-year production; granular time matching; RECs and
additionality, regionality and granular time-matching
NovoHydrogen, Inc.
Manka Khanna, Chief of Staff
Endorses geographical and temporal
correlation of RECs; no allocation of emissions to co-products;
endorse DOE’s CHPS;
NW Natural
Nels Johnson, Federal Affairs
Manager
45V: well-to-gate should exclude
construction of energy source; credit for part-year production;
annual granularity of time matching; pro-book-and-claim;
coordination of 45V and 45Q – both available in certain
circumstances
NYU School of Law Institute for
Policy Integrity
Meredith Hankins
Rigorous carbon-accounting
principles when calculating carbon intensity of hydrogen
production
NYU School of Law Institute for
Policy Integrity (supplemental comments)
Matthew Lifson
45V: use temporal and spatial
granular marginal-emissions approach rather than GREET
annual-average approach; pro-book-and-claim but with rigorous
carbon accounting principles; additionality;
Oberon Fuels, Inc.
David Mann, VP
Dimethyl ether (DME); 45V: avoided
emissions; credit for part-year production; provisional emissions
rates; annual third party auditing to verify; pro-book-and-claim;
45Z: provisional emissions rates; negative emissions rates
affecting credit amounts; definition of “transportation
fuel”
Olin Corporation
Mike Meenan
When is overhauled equipment “new” equipment – 80/20 rule; use of any reasonable
method of allocation to co-products; pro-book-and-claim and use of
RECs
Onward Energy
Rob Witwer, SVP
Power running electrolyzers should
count as zero-carbon if (i) occurs when renewable energy otherwise
curtailed or (ii) hydrogen burned as fuel when not displacing
renewable power; alignment with DOE CHPS
Orsted
Melissa Peterson, Head of P2X
Americas
45V: well-to-gate; credit for
part-year production; alignment with DOE CHPS;
Pattern Energy
45V: endorses American Clean Power
Association’s (ACP) comments; hourly matching desirable;
additionality is critical.
Pinion, LLP
45Z: permit GHG reducing farm
practices to be included in the CI score for biofuels; annual
election of 45Q or 45Z
Plug Power
Definition of “facility” ;
determination of lifecycle GHGs; part year production; matching
requirements for energy inputs; DOE CHPS standard; recordkeeping;
pro-book-and-claim; modification of existing facilities
POET, LLC
Matthew Haynie, Regulatory
Counsel
Incorporation of CI Reduction
practices in emissions rates; provisional rate petitions; gallon
equivalent definition; negative GHG emissions for credit rates
above $1.75/gallon; “transportation fuel” use; denaturant
blending; sales to unrelated persons; annual election between 45Q
and 45Z; sale date of fuel
POSCO Holdings
45V: make clear credits are
available for hydrogen produced for export; extend credit longer
than 10 years
Prelude LLC
Monetization of tax depreciation
Princeton University ZERO Lab
45V: hourly temporal matching;
additionality; deliverability;
Project Canary, PBC
John Westerheide, Senior
Director
45V: importance of measurement
accuracy for GHG emissions; hourly granularity enables highest
accuracy; provisional emissions rates; certification of verifiers
of production
Purefield Ingredients
Brad Kelley, CEO
45Z pathways; negative emissions
rates; provisional emissions rates; definition of “qualified
facility”; other credits “allowed” but not claimed
do not preclude 45Z claim; annual election between 45Z and 45Q
Red Rock Biofuels Holdings
Jeff Manternach
Hydrogen in syngas as qualified
clean hydrogen; recordkeeping; verification; anti-book-and-claim
system;
Renewable Fuels Association
Geoff Cooper
Unrelated purchasers; sales at
retail; endorses GREET; provisional emissions rates; 45Q and 45Z in
different years; default values for common production pathways
Renewable Hydrogen Alliance
Michelle Detwiler, Executive
Director
45V: Endorses GREET model; annual
granularity of temporal matching of grid resources; re-evaluate
additionality requirement for energy input; pipelines
Resources for the Future
Aaron Bergman
Determination of lifecycle GHG
emission from electricity use
REsurety
Use granular hourly marginal
emissions rates to measure CI; pro-book-and-claim; annual
matching
RFS Power Coalition
Carrie Annand
45Z definition of “transportation fuel”; gallon equivalence; “use” requirement;
RMI
John Coequyt
45V: emissions pathways for
grid-connected electrolysis and methane-based hydrogen production
are needed; credit for part-year production; verification;
pro-book-and-claim; additionality; regionality; marginal emissions
accounting; coordination with 45Q;
Ron Alverson
Ron Alverson
Carbon intensity calculations should
be granular
Rondo Energy, Inc.
John O’Donnell, CEO
45Z- emissions for grid sourced
power or book-and-claim accounting mechanisms should be based on
hourly average emissions factors
SAF Blender’s Tax Credit (BTC)
Coalition
Numerous
Endorses GREET model; provisional
emissions rates needed; third party certification; confirm negative
GHG for credit rates above $1.75/gallon; coordinating 45V and 45Q;
foreign feedstocks permissible; pro-book-and-claim
Santa Maria Renewable Energy,
LLC
Patricio Sanchez, CEO
45Z: provisional emissions rates;
upstream agricultural practices; annual election between 45Z and
45Q
Shell USA Inc.
John Miso, VP & General Tax
Counsel
System expansion difficult in
practice; credit for part-year production; monthly granularity of
time matching; provisional rate petitioning; pro-book-and-claim;
coordinate 45V and 45Q by treating unrelated process trains as
separate facilities
Sierra Energy
Mike Hart, Chairman
45V: definition of “qualified
clean hydrogen” should include syngas mixtures of hydrogen
with CO and CO2.
Singularity Energy, Inc.
Wenbo Shi, Founder
45V: definition of “qualified
clean hydrogen”; adopt most granular time and location-based
data; use attributional carbon accounting; assemble a technical
advisory group;
SkyNRG Americas
John Plaza, CEO
Eligibility for book-and-claim for
SAF produced from RNG; confirm negative GHG for credit rates above
$1.75/gallon ; coordination of 45Z with 45V and 45Q
StormFisher Hydrogen, Ltd.
Brandon Moffatt, Co-Founder
45V: chlor-alkali production;
allocation on an economic basis; credit for part-year production;
hourly granularity of time matching; provisional emissions rates;
both 45V and 45Q when green hydrogen uses captured carbon to
produce fuels
Strategic Biofuels
Victor Filatov, Financial
Advisor
45Z: negative emissions rate;
coordination of 45Z an
Sun Gas Renewables
Robert Rigdon, CEO
Definition of “qualified clean
hydrogen” may include other constituents; allocation to
co-products by mass; credit for part-year production; no temporal
matching standard should be required; provisional emissions rate;
certification by third-party licensed engineer; coordination of 45Q
and 45V – BECCS facility separation; 45Q and 45V in different
years
Taxpayers for Common Sense
Steve Ellis, President
45Z: Anti-tax credits for
ethanol
TC Energy
Omar Khayum, VP
45V: availability when 45Q is
allowed; storage as affecting “sale or use”;
pro-book-and-claim; RNG should lower CI for hydrogen production
Tenaska Inc.
Tiim Hemig, Senior VP
Application of GREET model to RNG;
pro-book-and-claim
Third Way LLC
Ryan Fitzpatrick, Director
45Z: endorses GREET model;
permissibility of both 45Z and 45Q at same facility; definition of “qualified facility”; negative emissions rates affecting
credits
Thyssenkrupp Nucera
Juergen Grasinger, Managing
Director
45V: alignment with DOE CHPS;
recordkeeping; chlor-alkali; time-matching granularity;
Twelve Company
Nicholas Flanders, CEO
45V: definition of “qualified
clean hydrogen” should include hydrogen used in the process of
production of another product; should include hydrogen in any form;
many circumstances in which facility should be eligible for both
45V and 45Q; pro-book-and-claim; verification of production amounts
by both direct observation and derivation from inputs and outputs;
circumstances in which both 45V and 45Z should be available;
United Association of Union
Plumbers
Geraid Waites
General endorsement of IRA
provisions
Valero
Mandy Garrahan, Executive
Director
45V: well-to-gate definition;
allocation to co-products; credit for part-year production;
verification; granularity of time matching; alignment with DOE
CHPS; provisional rates; pro-book-and-claim; coordination of 45V
with 48; circumstances in which both 45Q and 45V should be
available; 45Z: use of GREET in lieu of CORSIA; multiple credits
for 45Z and 45Q or 45V; concentration of environmental
attributes;
Voice of the People
Steven Kull, Founder
General support for clean energy tax
credits
Wabash Valley Resources LLC
45V; GHG emissions from hydrogen
feedstocks; waste petcoke as feedstock;
Wabash Valley Resources LLC Comments (1)
Wabash Valley Resources LLC Comments (2)
Wabash Valley Resources LLC Comments (3)
Washington State Dept of
Commerce
Glenn Blackmon, Manager Energy
Policy Office
45V: endorses GREET model;
pro-book-and-claim; monthly granularity of energy input matching;
third party verification
World Energy
Scott Lewis, President
45V: provisional rates;
pro-book-and-claim; 45Z: use of GREET for SAF; certification
options for supply chain traceability; negative emissions increase
credit amount; permissibility of sourcing SAF feedstocks outside
US; allow 45Z and 45Q at same facility
World Resources Institute
Zachary Byrum
45V: endorses comments of Industrial
Innovation Initiative; hourly granularity of time matching;
recordkeeping
World Wildlife Fund
Marty Spitzer, Senior Director
45V: well-to-gate approach is
insufficient; use RECs for reporting and verifying; allow indirect
book accounting with hourly time matching; 45Z: for SAF, defer to
COSIA over GREET; certification
XTS Energy LLC
Robert Kelly, Managing Director
45V: coordination with 45Q ;
definition of “qualified clean hydrogen” covering
hydrogen produced in syngas; pro-book-and-claim
Yosemite Clean Energy
Thomas Hobby
Time matching; verification; pro
book-and-claim; coordination of 45V and 45Q in certain
circumstances;
ZeroAvia
45V; supports well-to-gate emissions
determination, including co-products
Source: news.google.com
