The following commentary was written by Bill Hayes, a finance executive who focuses on
electricity and environmental markets, and Joe Tedino, a Chicago-based writer focusing on the environment and sustainability. See our commentary guidelines for more information.
Last month, 13 senators — including the two representing our state of Illinois — sent a strongly worded letter to Treasury Secretary Janet Yellen calling out rules around the proposed tax credits for the green hydrogen industry as “inconsistent with the intent and requirements” of the legislation they approved.
They noted that the tax credits can be vital for incentivizing the production and market-viability of renewable hydrogen power, but the current proposed guidance could undermine the intent of the Inflation Reduction Act and hinder the green hydrogen economy.
We applaud this Senate effort and are pleased to see Illinois Democrats Dick Durbin and Tammy Duckworth were onboard in calling for revising the Treasury’s overly stringent rules. Both have been strong advocates of the Midwest’s MachH2 clean hydrogen hub, and they recently secured $1 billion in federal funding for this project.
The green hydrogen production tax credit in the IRA — the largest investment to reduce carbon dioxide emissions in U.S. history — has the potential to secure a significant role for clean, zero-carbon hydrogen energy in the U.S. by providing a tax credit of up to $3 for each kilogram of fuel produced.
Yet as the Treasury Department grapples with how to implement rules for awarding the tax credit to hydrogen producers, there are warning signs that overly restrictive regulations may stifle the growth of what had been projected to be a $515B global market by 2035, according to global consultant Research Nester.
We support the position led by Sen. Alex Padilla (D-Calif.) that asked for a host of changes to the rules in the interest of boosting a burgeoning energy supply that will achieve the intended carbon reduction in a less burdensome way.
At issue are the so-called “Three Pillars,” which are the standards adopted by the Treasury Department for determining whether hydrogen producers are entitled to receive the tax credit. The standards specify how, when, and where renewable electricity must be added to the grid to match the electrical load drawn to power the hydrogen electrolysis operations.
One of these pillars requires that hydrogen producers add renewable generation to the grid that matches their hydrogen load on an hourly basis, instead of an annual basis. The other two add specific location and facility requirements that further limit the flexibility for how and where hydrogen producers add renewable generation to the grid.
Here’s the problem: the standards are overly restrictive, leading to unnecessarily excessive costs for achieving the targeted carbon reduction impacts in the hydrogen sector, according to new research published in response to the Treasury guidelines.
With regard to the extra costs, energy data analytics firm Wood Mackenzie analyzed the impact of just one of the pillars — hourly matching — and found that this requirement alone would raise the total costs of green hydrogen by 68 to 175%, compared to annually matched generation.
Other researchers found that there is no additional carbon reduction benefit to this fine-tuned hourly matching. Comprehensive research by the consulting firm Energy and Environmental Economics, also known as E3, found that both annual and hourly matching have similar impact on CO2 emissions, across a wide range of scenarios and geographies. The Open Energy Outlook Initiative of Carnegie Mellon has come to the same conclusion. It’s not surprising, since both annual matching and hourly matching lead to identical increases in new renewable generation, and hydrogen producers have a clear incentive to generate their new renewable electricity in times and locations that maximize the amount of displaced fossil fuels.
In short, the hydrogen industry and the good jobs it will support will simply not grow as planned by the U.S. Energy Department if their costs double unnecessarily.
We hope the Treasury Department will look at this research and feedback closely, in order to achieve the targeted carbon reduction in the hydrogen sector at a competitive cost with environmental concerns in mind. Growth in the hydrogen sector is needed to clean up hard-to-abate sectors like steel and airlines, and it is also vital to address climate change.
There’s a global consensus that we need to urgently decarbonize to address the impacts of climate change. The Biden Administration’s goal to reduce GHG’s by 50% by 2030 and become net-zero by 2050 requires robust incentives to develop green energy industries as fast as possible. Without a viable hydrogen sector, we run the risk of being unable to fully decarbonize our economy.
Business leaders and individuals should call or write to the White House and to their representatives in Congress, urging them to revise the tax credit eligibility rules for hydrogen production to ensure the economic viability of this vital emerging industry.