On February 26, 2024 ACP filed comments expressing concern over the proposed near-term time-matching requirement that will prevent green hydrogen production from scaling up.

• A new analysis from Wood Mackenzie—submitted alongside these comments—along with many other studies, support ACP’s position that Treasury’s current time-matching proposal would severely limit the role green hydrogen will play in the economy of tomorrow.

While ACP supports much of the Proposed Rule, we encourage Treasury to consider implementing the recommendations presented herein in the final rule to ensure the green hydrogen industry can scale up to meet its potential.

On November 21 2023, ACP filed comments expressing concern about negative impacts the proposed rules are already having on clean energy tax equity.

These rules would quadruple the capital requirements for renewable tax equity investments after 2025. But since many current PTC and ITC deals would extend beyond that date, it has already essentially frozen the renewable tax equity market.

ACP is urging the administration to provide interim relief by providing that legacy clean energy tax equity investments entered into before the effective date of the rule (2025) be captured under the status quo (100% risk weight if the investments are less than 10% of a bank’s books) and to ultimately issue a final rule clarifying renewable energy tax equity investments are assigned a simple 100% risk weight (with the 10% threshold lifted). ACP is currently working on an advocacy plan with federal agencies and the Hill.