Comments in response to the Internal Revenue Service (IRS) request for comments on credits for clean hydrogen and clean fuel production (Notice 2022-58)

CRS’s comments in responses to questions in the Stakeholder Feedback section of the Draft Guidance include general support for DOE’s Clean Hydrogen Program and detailed recommendations on the use of Renewable Energy Credits (RECs) for hydrogen produced by electrolysis, and Renewable Thermal Credits (RTCs) for hydrogen produced by steam methane reforming (SMR) for clean hydrogen production.