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30,000 times 45V

Halcyon has been pounding a very specific drum since the start: we are awash in energy transition and decarbonization information, and of a type and volume that overwhelms any human information capability to index, classify, or rank. As we put it internally: the well-meaning methods of disclosing a torrent of information amount to a denial of service attack on those building the energy and infrastructure future. 

Since well before our first post, we have encoded knowledge into software. Today we’re ready to share an example. It also goes back to our first post: the Internal Revenue Service’s rules on the so-called Section 45V credit for clean hydrogen, created by the Inflation Reduction Act. 

The rule is nearly 40,000 words long, which is a lot to read to begin with. What’s more (or, depending on your perspective, what’s worse), there are also 30,000 public comments on the rule. Even if a small team of humans could magically read these comments instantaneously, they would still struggle with classifying and categorizing the comments in an easily accessible and comparable way.

So, we did it using Halcyon’s AI-assisted capabilities. 

We analyzed all 30,000 comments, evaluating commenters' positions, concerns, and requests for changes to the proposed regulations on clean hydrogen. Here is a sketch of how we did it:

45v PNG 1

There are a few initial takeaways that an expert might intuitively sense, but would have a very hard time confirming.  Almost 96% of the comments (more than 29,000) are from individuals, and not companies or institutions. More importantly, form letters from environmental non-profits were 75% of all comments. And perhaps most importantly, only 917 comments out of 30,000 are unique, and only 408 are from companies or institutions. And of those 408 organizations, 36 are involved in the $7 billion US Clean Hydrogen Hubs program

Notably, despite most comments in support of hydrogen investment, the majority demanded changes to these proposed rules. These proposed changes were quite diverse and wide-ranging. More than half of comments want the US government to “avoid greenwashing,” and another 20%+ want to strengthen the rule in various ways to maximize the environmental benefits of green hydrogen produced without using fossil fuels. 

Jeff Copy of Halcyon - 45V Comments Analysis_v2_05.14.24-4

We’re just getting started. There are six important proposed amendments to the 45V rule, which Halcyon analyzed in terms of support for/against and proposed modifications: 

  • Temporal Matching - Support or against requirement, and for what frequency
  • Spatial Matching - Support, support with caveats, or against
  • Additionality of Renewable Supply - Support, support with caveats, or against
  • Modifications - Fixed allowance %, evidence-based, or carve-out?
  • Qualified Facility - Support, later due to grid constraints, later for other reasons
  • Renewable Natural Gas - Support, support with caveats, opposes book and claim market structure

Here is one of Halcyon’s matrices. It shows how different entities think about the proposed rules’ ‘temporal matching’ requirement, meant to ensure that any green hydrogen produced uses clean electrons that are produced at the same time that hydrogen is produced. Corporations are more opposed to the idea than supportive (16.8% of company comments opposed the rules, while only 7.2% supported). 

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Halcyon also determined the key concerns for those opposing temporal matching: it will impose additional costs, infrastructure is insufficient to build appropriate energy supply systems by 2028, and, well, it may be simply unfeasible. We ran similar analyses for the five other proposed modifications listed above. 

While this type of analysis is fairly novel, it’s not hard to imagine the types of businesses and organizations that would benefit from knowing who is commenting and how they feel about 45V. Obviously environmental and energy sector companies would use this in their project planning, competitive analysis, and lobbying efforts. But it’s equally relevant to anyone financing green hydrogen, underwriting it, trading it, and designing its next supportive policies - quite a large group of stakeholders. 

Technology analyst Ben Thompson says that there are only two scarce resources on the internet: time and attention. Halcyon agrees, and that is why our first platform efforts solve for time - accelerating information processing at much greater scale, so that you can make better decisions faster. We share this here as a demonstration of what technology can do, when pointed at a climate- and business-critical unstructured data challenge.  

Comments or questions? We’d love to hear from you -, or find us on LinkedIn and Twitter.