December 9, 2022

December 9, 2022 Re: Comments to the Department of the Treasury and the Internal Revenue Service (IRS) on Credits for Clean Hydrogen and Clean Fuel Production in the Inflation Reduction Act (IRA) Docket No.: IRS-2022-58 (November 3, 2022) Notice: 2022-58 Dear Acting Commissioner O’Donnell: Environment America, Friends of the Earth, R Street Institute, Taxpayers for Common Sense, and U. [...] PIRG provide the following comments to the Department of the Treasury and the Internal Revenue Service (IRS) related to “Credits for Clean Hydrogen and Clean Fuel Production” (Notice 2022-58), particularly the creation of new tax credits in the Inflation Reduction Act (IRA). [...] Question 2 Specifically, regarding Question 2 in the request for comments, entitled “Establishment of Emissions Rate for Sustainable Aviation Fuel,” the lifecycle GHG emissions rate calculation for sustainable aviation fuel should utilize the Carbon Offsetting and Reduction Scheme for International Aviation methodology. [...] If an emissions rate does not currently exist under the International Civil Aviation Organization (ICAO) Carbon Offsetting and Reduction Scheme for a particular fuel, then a lifecycle GHG emissions rate should be determined under a “similar methodology” – through the existing § 211(o)(1)(H) of the Clean Air Act – that would result in the same lifecycle GHG emissions rate as if it was determined th. [...] For consistency purposes, the Secretary should work with the Environmental Protection Agency (EPA) and the International Civil Aviation Organization (ICAO) to ensure that GHG emissions rates of new fuels meet the methodology and GHG reduction requirements outlined in IRA (and detailed in the paragraph above).