In this white paper, we provide comments on each of the EAC Criteria proposed by the Treasury and in some instances propose alternative approaches for each criteria where we believe they will be helpful in achieving the goal of reducing GHG emissions from hydrogen production. In general, our proposed alternatives are meant to help align the Section 45V Rule with real-world operation of the power system, with specific focus on power system operations in the Western Electricity Coordinating Council (WECC).

View Report