Document Type

Response or Comment

Publication Date


Research Center

Energy Policy Center


The Midwest Hydrogen Center of Excellence submitted comments in support of efforts to draft language defining what forms of clean hydrogen production will be eligible for tax credits under IRS Section 45V. The need to transition our energy economy to clean hydrogen is urgent. If we rely primarily upon electrolysis and other renewable sources for hydrogen, it will take too long to develop. Accordingly, the 45V tax credit rules should be written to encourage clean hydrogen generation from steam methane reformation. Tax credits for generation of clean hydrogen from renewable natural gas, in particular, should phase in Scope 3 emission charges to enable RNG to be eligible for the credits.