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I spoke to experts about why the nascent industry is nothing like other climate solutions.
Is hydrogen really that different from an electric vehicle or a heat pump?
This is the provocative question raised by a letter sent to the U.S. Treasury Department last week by a hydrogen industry group, the latest salvo in an ongoing debate over the rules for a new tax credit for clean hydrogen that was created by the Inflation Reduction Act.
I’ve been covering this debate since December, when the public comment period for the rules first closed, and it has only grown fiercer as everyone awaits the Department’s decision. Clean hydrogen is essential to reduce emissions from fertilizer production, and likely a number of other industries, such as aviation, shipping, and steelmaking. But climate advocates and clean energy experts warn that producing hydrogen using electricity, a method incentivized by the tax credit, could actually increase greenhouse gas emissions unless the electricity comes from new wind, solar, or other carbon-free generators.
Industry groups say the opposite is true. Last week’s letter, penned by the Fuel Cell & Hydrogen Energy Association argued that this so-called “additionality” rule would “stifle the clean hydrogen market by adding unreasonable costs and delays,” thereby hurting the United States’ climate goals. The letter was signed by more than 50 companies and organizations, including Plug Power, Constellation Energy, Baker Hughes, the Chamber of Commerce, and General Motors,
When the government hands out subsidies for electric vehicles and heat pumps, it doesn’t require recipients to erect solar arrays, the letter points out. “It would be arbitrary and unfounded to presume hydrogen to have any more detrimental impact to the efforts to decarbonize than any other electric load,” it says.
On the surface, the comparison is compelling. But when I ran it by proponents of additionality, the logic broke down very quickly. And it’s worth talking about why hydrogen plants are, for a number of reasons, nothing like those other climate solutions, because the answers get to the heart of some of the risks and trade-offs of scaling up this new industry.
The Inflation Reduction Act explicitly says that hydrogen companies must meet certain emission thresholds to qualify for the tax credit, taking into account the “lifecycle greenhouse gas emissions” of production. It does not say that for electric vehicles or heat pumps.
The law establishes a tiered system, where hydrogen producers can earn more money depending on how low their emissions are. But researchers like Jesse Jenkins, a macro-scale energy systems engineer at Princeton University, have calculated that without additionality, electrolysis, an electricity-intensive method of making clean hydrogen, will induce so much new carbon pollution that it won’t even meet the minimum threshold to qualify for the credit.
That’s because when you add demand to the grid without adding any new energy supply, it’s almost guaranteed to cause a natural gas or coal plant to run more. Those are the only power plants we have right now that are capable of increasing their output to meet demand — especially at times of day when wind and solar are not available.
If companies are allowed to sign contracts with existing wind farms or nuclear power plants to qualify for the tax credit, this would simply rearrange the paperwork about who “owns” these resources. It wouldn’t change the outcome in the real world, where more coal would be shoveled into a power plant, spewing more carbon into the atmosphere. Jenkins’ lab modeled the long-term effects on energy markets and found that coal and natural gas plants that might have otherwise closed could even be kept open longer because of the increased demand for power.
“The letter does not even attempt to argue that a lack of additionality would be compatible with the emissions thresholds established by the law,” he said in an email.
Jenkins added that the law references a section of the Clean Air Act which defines “lifecycle greenhouse gas emissions” as “including direct emissions and significant indirect emissions.” (Emphasis added by Jenkins.) “This is simply the letter of the law,” he said. “Take it up with Congress!”
There’s a good reason Congress made this distinction.
Yes, the new electric load from EV charging and heat pumps will also often be met by firing up more fossil fuel power plants in the near term. However, electric vehicles and heat pumps are so much more efficient than the combustion engines and natural gas furnaces they replace, that they almost always reduce emissions regardless of where the electricity comes from.
The Department of Energy estimates that in Wyoming, for example, where more than 75% of electricity comes from coal, an electric vehicle’s annual carbon footprint would be less than half that of a gas-powered vehicle. And homeowners who replace their gas furnaces with heat pumps would reduce their emissions in at least 46 states, according to a 2020 study by the clean energy research organization RMI.
Electrolysis, on the other hand, is not more efficient than the reformation of natural gas, which is the carbon-intensive way most hydrogen is made today. Jenkins and others estimate that hydrogen plants would produce twice as many emissions as that process if they just plug into the grid, without bringing any new, clean electricity online.
Additionality proponents argue that it would be a huge mistake to subsidize the production of a fuel that does not have lower emissions than what it replaces. “If that is the final outcome,” said Jenkins, “the hydrogen subsidy will go down in history as a costly policy disaster, and the whole concept of ‘green hydrogen’ will become a farce.”
Conceptually, producing hydrogen is totally different from buying an electric car. “An electrolyser is not an end use appliance like an EV or a heat pump – it’s an intermediate step in the energy supply chain,” said Morgan Rote, director of U.S. climate policy at the Environmental Defense Fund.
Reaching this intermediate step requires so much energy that the benefits of producing hydrogen depend as much on what we use it for as how it’s made. Rote said that using hydrogen as a fuel for home heating or road transportation would require three to seven times more energy than switching to heat pumps and EVs. Many climate advocates argue that it should be reserved for applications that can’t otherwise run directly on electricity.
Danny Cullenward, a climate economist and research fellow at American University, said concerns about how hydrogen is made and used are “all the more pronounced given the extremely generous subsidy levels” in the tax credit. “Basically, [the tax credit] points a giant funnel of money at a technology that has a critical role, but one that must be carefully tailored to produce short- and long-term benefits.”
Cullenward suggested another reason the government should hold hydrogen producers to a higher standard than EV and heat pump buyers when doling out subsidies: Because it can.
“It's not unreasonable or infeasible to ask projects at the $100 million or $1 billion scale to procure clean energy,” he said. “In contrast, it would be administratively infeasible to ask homeowners to procure clean energy.”
He pointed to a recent analysis by the nonprofit Energy Innovation, which found that subjecting hydrogen producers to tight standards, like an additionality requirement, would not result in “unreasonable costs and delays” as the industry claims. By contrast, the report found that the tax credit is so generous that even with stringent emissions accounting rules like additionality, projects in many parts of the country will be able to sell their hydrogen at or below $1 per kilogram, outcompeting conventional hydrogen.
There are a lot of uncertainties about what it will take to successfully scale up clean hydrogen in the U.S., and disagreement about what the biggest near-term priorities should be.
But one thing that is clear: Clean hydrogen is a unique climate solution with specific risks and tradeoffs that can’t be ignored.
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Rob and Jesse digest the Ways and Means budget bill live on air, alongside former Treasury advisor Luke Bassett.
The fight over the Inflation Reduction Act has arrived. After months of discussion, the Republican majority in the House is now beginning to write, review, and argue about its plans to transform the climate law’s energy tax provisions.
We wanted to record a show about how to follow that battle. But then — halfway through recording that episode — the Republican-controlled House Ways and Means Committee dropped the first draft of its proposal to gut the IRA, and we had to review it on-air.
We were joined by Luke Bassett, a former senior advisor for domestic climate policy at the U.S. Treasury Department and a former senior staff member at the Senate Committee on Energy and Natural Resources. We chatted about the major steps in the reconciliation process, what to watch next, and what to look for in the new GOP draft. Shift Key is hosted by Jesse Jenkins, a professor of energy systems engineering at Princeton University, and Robinson Meyer, Heatmap’s executive editor.
Subscribe to “Shift Key” and find this episode on Apple Podcasts, Spotify, Amazon, or wherever you get your podcasts.
You can also add the show’s RSS feed to your podcast app to follow us directly.
Here is an excerpt from our conversation:
Jesse Jenkins: Let’s come back to this as a negotiation. This is the first salvo from the House. What does this tell you about where we go from here? Is this a floor? Could it get worse? Is it likely to get better as the lobbying kicks off in earnest by various industries threatened by these changes, and they try to peel things back? What do you think happens next?
Luke Bassett: If you run with the horror movie analogy here, this is scary. I think a lot of people, especially in any energy startups or folks who have been penciling out deals, to start really lining up new projects — or even folks looking for a new EV to buy are suddenly going to have to totally rethink what the next few years look like.
And, you know, whether or not they want to build a factory, buy a car, or have to switch from an electric heat pump to a whale oil burning stove. Who knows? That said, there are champions for each of these in very different ways in the Senate. There are lobbyists who —
Jenkins: — in the House, too.
Bassett: Exactly. There will be lobbyists weighing in. And I think it matters to really think through … I think we’ve been faced with gigantic uncertainty since January. And there’s a part where companies all across the energy sector are looking at this text as we speak and thinking, whoa, I didn’t sign up for this. And to combine this with tariffs, to combine it with the cuts to other federal programs in the other committees’ jurisdictions, it is just a nearly impossible outlook for building new projects. And I bet a bunch of people, CEOs and otherwise, are thinking, I wish Joe Manchin were back in the Senate. But you know, it is what it is.
Robinson Meyer: I will say that it could get worse from here because they will be negotiating with the House Freedom Caucus and with various other conservative House members. And they’ll also be negotiating against the president’s wishes, which is that this move and get done as soon as possible. And so when I talked to Senator John Curtis, Republican of Utah, who’s a supporter of the IRA, or wants to see it extended in large part, and I asked him questions like, what happens if Republicans really go to work in the House on the IRA and then it gets sent to the Senate? One dynamic we’ve already seen during this Congress is that te House Republican Caucus in this Congress is unusually functional and unusually strategic, and has been unusually good at passing relatively extreme and aggressive policy and then jamming the Senate with it.
And unlike what has happened in the past, which is the House Republican Caucus can’t really do anything, so the Senate passes a far more moderate policy, sends it to the House and dares the House to shut things down. This time the House, if folks remember back in March, the House passed a fairly aggressive budget and kicked it to the Senate and then dared the Senate to shut down the government, and ultimately the Senate decided to keep the government open.
I asked Curtis what happens if they do the same with the IRA. What happens if they really go to task on the IRA? They pass fairly aggressive cuts to it and they send it to the Senate. And his answer was, well, I don’t think the House is going to do that. I don’t think a bill that really savages the IRA could pass the House.
We’ll see, but I just don’t think there’s any floor here. I think there’s no floor for how bad this gets. And I think I just don’t, you know … Before we went into the administration, there was a lot of confidence that the Trump administration and the new Republican majority and the Congress was not going to do anything to substantially make the business environment worse. We’ve discovered there does seem to be a degree of tariffs that will make them squeal and pull back, but we actually haven’t found that in legislature yet.
Music for Shift Key is by Adam Kromelow.
The Ways and Means Committee released its proposed budget language, and it’s not pretty for clean energy.
The House Ways and Means Committee, which oversees tax policy, released its initial proposal to overhaul the nation’s clean energy tax credits on Monday afternoon. These are separate and in addition to the extensive cuts to Inflation Reduction Act grant programs proposed by the Energy and Commerce Committee, Transportation Committee, and Natural Resources Committee in the past few weeks.
Here’s a rundown of the tax credit proposal, which, at first glance, appears to amount to a back-door full repeal of the climate law. There’s a lot that could change before we get to a final budget, let alone have a text head to the Senate. We’ll have more analysis on what these changes would mean in the days and weeks to come.
The text proposes ending the tax credit for new EVs (that is, 30D) on December 31, 2025 — with one exception. The credit would remain in effect for one year, through the end of 2026, for vehicles produced by automakers that have sold fewer than 200,000 tax credit-qualified cars between 2010 and the end of this year. That means that no Teslas would qualify for the tax credit next year, as the company has sold far more than 200,000 tax credit-eligible vehicles. A new entrant to EVs, like Honda with its Prologue model, will likely still qualify.
The committee also proposes ending the tax credit for used EVs (25E) and commercial EVs (45W) by the end of this year. This would effectively end the “leasing loophole” that allowed Americans to redeem the tax credit on vehicles that didn’t qualify for 30D because they didn’t meet domestic content requirements, meaning consumers could get discounts on leases of a wide range of makes and models.
Lastly, the draft proposes terminating the tax credit for residential EV chargers (30C) at the end of this year.
The GOP has proposed an early phase-out of the technology-neutral production and investment tax credits, which subsidize zero-emissions power generation projects including wind, solar, energy storage, advanced nuclear, and geothermal. It also proposed significant changes for the years they remain in effect.
Currently, new clean electricity projects can earn a 2.75 cents for every kilowatt-hour they produce for the first 10 years under section 45Y of the tax code. Alternatively, project developers can get a 30% investment tax credit (48E) on new projects. The Inflation Reduction Act scheduled both of these programs to phase out beginning in 2032, and expire at the end of 2035. It included a major caveat, however: that this phase-out would only happen if greenhouse gas emissions from U.S. power generation fell below 25% of 2022 levels. Otherwise, the tax credits would be maintained at their initial amounts until this target was met.
Under the GOP proposal, both credits would start to phase down in 2029, and new projects would no longer be eligible for either credit beginning in 2032. The proposal also cuts out a key provision that would have grandfathered many more projects into the tax credit. Under current law, a project only has to start construction within a certain year to qualify for that year’s tax credit amount. The draft text changes this, requiring a project to be “placed in service” before 2032 in order to qualify.
A separate tax credit for existing nuclear power generation (45U) would also phase down on the same timeline, despite Trump and other Republicans’ interest in boosting nuclear energy.
“Transferability” supercharged the nation’s clean energy tax credits by allowing project developers with low tax liability to sell their credits to another entity that stood to benefit from them. Previously, developers could only monetize their unusable tax credits through complicated tax equity deals.
Recipients of a wide range of tax credits, including those for clean manufacturing, clean fuels, carbon capture, nuclear power, and hydrogen, can all take advantage of transferability. The provision channeled new capital into the climate economy as corporations looking to reduce their tax liability began scooping up tax credits, indirectly helping to finance clean energy projects. It also helped lower the cost of wind and solar, as developers could earn a premium on tax credits compared to what they got for tax equity transfers, because the whole transaction was cheaper to do.
The proposal would get rid of this option across all of the tax credits beginning in 2028.
The proposal would also impose new sourcing requirements across all of the tax credits, prohibiting developers from using components, subcomponents, or critical minerals sourced from “foreign entities of concern,” a term that applies to companies based in China, Russia, North Korea, or Iran. The consequences would be huge, as China dominates global markets for refined lithium, cobalt, graphite, and rare earths — key materials used in clean energy technologies.
The draft text would also terminate the clean manufacturing credit (45X) in 2032 — one year earlier than under existing law. Wind energy components such as blades, towers, and gearboxes would lose their eligibility sooner, in 2028.
The text proposes repealing three tax credits for residential energy efficiency improvements at the end of 2025. Starting next year, homeowners would no longer be able to claim the Energy Efficiency Home Improvement Credit (25C), which provides up to $3,200 per year for home energy audits, energy-saving windows and doors, air sealing and insulation, heat pumps, and new electrical panels.
It also proposes killing the Residential Clean Energy Credit (25D), which offered homeowners 30% off the cost of solar panels and battery systems to store energy from those solar panels. This credit also subsidizes geothermal home heating systems.
Both of these tax credits have existed in some form since the Energy Policy Act of 2005.
The third credit that would end this year is an up to $5,000 subsidy for contractors who construct new, energy efficient homes (45L).
The proposal would not repeal the energy efficiency tax deduction for improvements made to commercial buildings (179D).
The Inflation Reduction Act created a technology-neutral tax credit for low-carbon transportation fuels, like sustainable aviation fuel and biodiesel (45Z). It operates on a sliding scale, depending on how carbon-intensive the fuel is. The credit is set to expire after 2027, however the GOP proposal would extend it for four years, through the end of 2031.
That said, it would also make a significant change to how the credit is calculated, making it much easier for projects with questionable emissions benefits to qualify. Under the Biden administration, the Treasury Department issued rules that said producers had to account for the emissions tied to indirect land use changes resulting from fuel production. That meant that corn ethanol producers, for example, had to account for the expansion of croplands resulting from the increase of biofuel production and use — which would, in most cases, disqualify corn ethanol from claiming the tax credit. But under the GOP proposal, producers would explicitly not have to account for indirect land use changes.
The GOP proposal would deal a rapid and ruthless death blow to the 45V clean hydrogen production tax credit, requiring developers to begin construction before the end of this year if they want to claim it.
Other than ending transferability, the text makes no changes to the 45Q carbon capture and sequestration tax credit.
Most of the tax credits have provisions that allow project developers to qualify for higher amounts if they pay prevailing wages, hire apprentices, build in a qualified “energy community” or a low-income community, or use a certain percentage of domestically-produced materials. This initial draft from the GOP would not change any of those provisions.
The Energy and Commerce Committee dropped its budget proposal Sunday night.
Republicans on the House Committee on Energy and Commerce unveiled their draft budget proposal Sunday night, which features widespread cuts to the Inflation Reduction Act and other clean energy and environment programs.
The legislative language is part of the House’s reconciliation package, an emerging tax and spending bill that will seek to extend much of the 2017 Tax Cuts and Jobs Act, with reduced spending on the IRA and Medicaid helping to balance the budgetary scales.
The Energy and Commerce committee covers energy and environmental programs, while the Ways and Means Committee has jurisdiction over the core tax credits of the IRA that power much of America’s non-carbon power generation. Ways and Means has yet to release its draft budget proposal, which will be another major shoe to drop.
The core way the Energy and Commerce proposal generates budgetary savings is by proposing “rescissions” to existing programs, whereby unspent money would be yanked away.
The language also includes provisions to auction electromagnetic spectrum, as well as changes to Medicaid.Overall, the Congressional Budget Office told the committee, the recommendations would “reduce deficits by more than $880 billion” from 2025 to 2034, which was the target the committee was instructed to hit. The Sierra Club estimated that the cuts specifically to programs designed to help decarbonize heavy industry would add up to $1.6 billion.
The proposed rescissions would affect a number of energy financing and grant programs, including:
And that’s just the “energy” cuts. The language also includes a number of cuts to environmental programs, including:
Lastly, the proposal would also repeal federal tailpipe emission standards starting in the 2027 model year. These rules, which were finalized just last year, would have provided a major boost to the electric vehicle industry, perhaps pushing EV sales to over half of all new car sales by the beginning of the next decade. The language also repeals the latest gas-mileage standards, which were released last year and would have applied to the 2027 through 2031 model years, eventually bumping up miles-per-gallon industry-wide to over 50 by the 2031 model year.