Document Type

Response or Comment

Publication Date


Research Center

Energy Policy Center


The Midwest Hydrogen Center of Excellence submitted detailed comments on implementing tax credits for clean hydrogen production under section 45V of the U.S. tax code as established by the Inflation Reduction Act. Clean hydrogen has the potential to play an important role in decarbonizing the U.S. economy by reducing emissions in some of the most difficult-to-decarbonize sectors. The adoption of clean hydrogen will depend on driving down not just the cost of production, but also on lowering the cost to deliver and dispense hydrogen so that the total cost per kilogram reaches an amount that end users are willing to pay. Electrolytic hydrogen pathways will be challenged to deliver hydrogen at a price that early adopters such as medium and heavy-duty vehicle fleet operators are willing to pay. Steam methane reforming pathways for hydrogen production, combined with carbon capture and sequestration, could meet market-based price targets while helping to realize national net zero emissions goals and also drive economies of scale that benefit all clean hydrogen production pathways. For this to happen, Scope 3 emissions in accounting for the 45V production tax credit should be phased in similar to how the U.S. Securities and Exchange Commission is phasing in reporting this category of indirect emissions for publicly traded companies in their financial statements.