- Proving Zero Emissions: These technologies must demonstrate a greenhouse gas emissions rate of zero or negative to qualify for the credits. This requires a lifecycle analysis (LCA) to prove compliance, which can be more complicated and costly compared to technologies already on the list, such as solar and wind.
- Regulatory Uncertainty: The process for establishing and certifying compliance with emissions standards is not fully defined, which may lead to delays. There is also uncertainty about which agency will be responsible for certifying compliance and whether it will have adequate funding.
- Definition of Zero Emissions: There are questions about how “zero emissions” will be defined, particularly for technologies that emit greenhouse gases but capture them through carbon capture technology. Clarification is needed on what constitutes meeting the zero-emissions standard, especially for technologies like renewable natural gas and biomass.
- Lifecycle Analysis Requirements: Technologies not on the automatic list need to perform an LCA to assess their emissions over their entire lifecycle. This can be complex and may require accepted methodologies like the GREET model.
- Potential Delays in Financing: The complexity in demonstrating compliance and the uncertainty around regulatory guidance may limit a project’s ability to secure financing, as investors might be hesitant due to unclear regulatory conditions.
Original article by NenPower, If reposted, please credit the source: https://nenpower.com/blog/what-are-the-potential-challenges-for-technologies-not-automatically-qualifying-for-the-tech-neutral-itc-and-ptc/
