Comments to the EPA on Clean Air Act (CAA) Section 111 Proposed Rule

CRS proposes that Section 111 of the Environmental Protection Agency’s Clean Air Act require retirement of energy attribute certificates (EACs) to demonstrate use of low-GHG electrolytic hydrogen and that renewable fuel certificates be obtained and retired for low-GHG hydrogen produced by steam methane reforming with biomethane or renewable natural gas to avoid double counting.  Low-GHG electrolytic hydrogen should be permitted to use both grid-connected and off-grid renewable and low-GHG electricity. CRS supports facility age restrictions for generators of EACs and expects geographic and temporal alignment of EACs with hydrogen production will likely be available in 2032. Finally, we strongly support independent third-party verification for qualifying low-GHG hydrogen production.