Category
Transportation
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The most efficient use of funds: DOE can and should use hydrogen hubs funding to build out transportation corridors
DOE should use its authority under the IIJA to allocate hubs money to hydrogen distribution and delivery infrastructure along transportation corridors that will receive clean hydrogen from hubs.
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Negative emissions rates should not be allowed for biomethane
Negative emissions from biomethane would allow non-innovative, carbon-intensive hydrogen production to qualify for the 45V tax credit.
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What’s good and what’s missing from biofuel safeguards in California’s updated Low Carbon Fuel Standard
California’s Air Resources Board (CARB) is on the verge of major updates to its Low Carbon Fuel Standard (LCFS).
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Allow hydrogen storage to receive credits under 48E regardless of ultimate end use
The Issue Limiting 48E eligibility to hydrogen storage used for power applications is not required by the statute and is difficult to administer. Hydrogen storage should qualify for the section 48E investment tax credit (ITC) irrespective of the ultimate end use of the stored hydrogen. Treasury’s proposed guidance limits the…
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Synthetic SAF can, and should, qualify for 45Z
Synthetic SAF will be an essential component of aviation decarbonization Synthetic sustainable aviation fuel (SAF) will be essential to decarbonizing aviation, especially as the sector’s demand for low-carbon energy carriers continues to grow. CATF analysis has shown that biofuel supply will not be able to keep pace with this demand…
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Carbon intensity of vegetable-based oils must full account for cross-market substitution effects
Carbon intensity calculations for vegetable oil-based fuels must fully account for the effects of cross-market substitutions, in line with Congress’ restrictions on palm fatty acid distillates Diverting certain vegetable oils toward the energy sector can create supply gaps that may be filled by carbon intensive palm oil Congress sought to…
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Negative emissions rates: potential for extreme, unintended fiscal and environmental consequences
Treasury must not include negative emissions values in the published table of emissions rates or allow 45Z credits for blending fossil natural gas with biomethane or captured fugitive methane Negative emissions rates could have extreme, unintended fiscal and environmental consequences Assigning negative emissions rates to certain fuels––such as compressed biomethane…
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Properly accounting for indirect land use change
If Treasury uses GREET to model SAF lifecycle greenhouse gas emissions, it must modify it to be both similar to CORSIA and to fully account for indirect land use changes Statutory overview Section 45Z requires that lifecycle greenhouse gas (GHG) emissions for SAF be determined using either “(I) the most…
