On February 26, 2024, NASEO submitted comments in response to the Notice of Proposed Rulemaking (NPRM) regarding the credit for production of clean hydrogen (45V). NASEO encouraged the IRS to consider the availability of state-level data and differences among states’ existing clean energy resources when developing the final guidance. Specifically, NASEO recommended that taxpayers be allowed to input more granular, state-level data into the 45VH2-GREET model; that existing nuclear energy and hydropower facilities be eligible; and to exempt states with substantial amounts of existing renewables or other qualifying resources from aspects of the additionally requirement. The NASEO comments can be viewed here.