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Time-matching regulations require hydrogen producers to coordinate their production with when clean energy generation is available

Time-matching regulations require hydrogen producers to align their production schedules with the availability of clean energy. To comply, producers must buy Energy Attribution Credits (EACs) from clean energy generators for every unit of electricity they use.1 An EAC is a certificate that proves one unit of electricity was generated from a renewable source and added to the power grid.2 Without time matching, producers could buy EACs when clean energy is abundant but produce hydrogen when clean energy is scarce.

Time matching can be enforced on a yearly basis, where producers ensure that their total annual energy consumption matches their annual EAC purchases, or on an hourly basis, where producers synchronize their energy use with the availability of clean energy each hour.3 There is significant debate within the hydrogen industry over the merits of different time-matching measurements.4

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Footnotes​

  1. Sanders, M. J., & August, C. (2024, April 1). The ‘Three Pillars’ of EAC Use and the Proposed Regulations for Clean Hydrogen Tax Credit. Morgan Lewis. https://www.morganlewis.com/pubs/2024/04/the-three-pillars-of-eac-use-and-the-proposed-regulations-for-clean-hydrogen-tax-credit ↩

  2. Department of Energy. (2023, December 19). Assessing Lifecycle Greenhouse Gas Emissions Associated with Electricity Use for the Section 45V Clean Hydrogen Production Tax Credit. https://www.energy.gov/articles/clean-hydrogen-production-tax-credit-45v-resources ↩

  3. Bergman, A. (2023, August 2). 45V Hydrogen Tax Credit in the Inflation Reduction Act: Comparing Hourly and Annual Matching. Resources for the Future. https://www.rff.org/publications/issue-briefs/45v-hydrogen-tax-credit-in-the-inflation-reduction-act-comparing-hourly-and-annual-matching/ ↩

  4. Weiss, T., Piper, A., Iyer, N., Krause, T., Molloy, P., Janzow, N., & Lozano, M. (2023). Calibrating US Tax Credits for Grid-Connected Hydrogen Production: A Recommendation, a Flexibility, and a Red Line. RMI. https://rmi.org/insight/calibrating-us-tax-credits-for-grid-connected-hydrogen-production/ ↩