• 5 MIN READ

I3 Responds to DOE Requests for Information

The Inflation Reduction Act of 2022 (IRA) makes an unprecedented investment in the solutions necessary to reduce emissions from the vital yet challenging industrial sector. Clear guidance for implementing these investments and getting cross-cutting decarbonization solutions to scale will be critically important to achieving midcentury climate goals. To do this, the General Services Administration (GSA), the Treasury Department and the Internal Revenue Service (IRS) have released formal requests for information and comment.

The Industrial Innovation Initiative (I3) submitted responses to four such requests, providing the industrial perspective on what additional guidance, clarity, or support is necessary for the effective implementation of the relevant provisions within the IRA.

Quick links to our responses:

Clean Construction Materials

Responding to the General Services Administration Federal Buy Clean Request for Information on Construction Materials with Substantially Lower Embodied Carbon, the Initiative provided feedback on decarbonization strategies, especially as they relate to the Tier 1 priority materials (concrete, steel, asphalt, and flat glass) identified by the Federal Buy Clean Task Force. The response emphasized the importance of clear and comparable emissions data, including health-harming pollutants, and the critical role environmental product declarations will play in decision-making among products.

Read the full response

48C – Advanced Manufacturing Credit

Responding to the Treasury Department and IRS Request for Comments on Energy Security Tax Credits for Manufacturing Under Sections 48C and 45X, the Initiative calls for greater guidance related to how advanced energy equipment is defined, suggesting the inclusion of a suite of clean hydrogen production and carbon management technologies. Other recommendations include energy and materials efficiency considerations, waste reduction pathways, and the need for guidance related to feedstock efficiency.

Read the full response

45Q – Carbon Oxide Sequestration Credit

Responding to the IRS and Treasury Department Request for Comments on the Credit for Carbon Oxide Sequestration, the Initiative made suggestions to help clarify how “qualified facilities” should be determined under the tax credit, as well as the need to distinguish discrete functional production and emissions pathways from one another, regardless of their presence within a common fence-line. This response also calls for the explicit inclusion of in situ mineralization as an eligible carbon sequestration method.

Read the full response

45V – Clean Hydrogen & 45Z – Clean Fuels Production Credits

Responding to Treasury Department and IRS Request for Comments on Credits for Clean Hydrogen and Clean Fuel Production, the Initiative provided input on the emissions sources that should be included in lifecycle greenhouse gas emissions analysis and the allocation of emissions related to hydrogen produced as an industrial by-product. Among other recommendations, the Initiative calls for additional clarity around the definition of a facility, suggesting, similar to the response for 45Q, that a facility is defined by independent production streams, allowing for credits to be applied specifically to the relevant process. While third party verified emissions data is paramount for accurate calculations, the response outlines several opportunities to improve upon the commonly used GREET model, calling for greater specificity so that low-carbon fuel producers may get full credit for their emissions reductions.

Read the full response

Stay Up to Date

The information contained within these responses represents a small fraction of the collective knowledge and expertise of our participants. I3 will continue to seek out opportunities for formal input and comment in partnership with the GSA, IRS, Treasury, and other offices associated with the implementation of federal industrial decarbonization policies. Keep up to date with I3 news by signing up for our monthly newsletter. For more information on I3 or to get involved, contact David Soll at dsoll@gpisd.net.

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Senior Program Coordinator - Carbon Management, GPI

Carrie Danner joined the Great Plains Institute in 2023 and serves as the operations coordinator for the Carbon Management team. In her work, she supports all projects within the program to elevate operations, specifically in the grant making and event planning spaces. Carrie earned a bachelor’s degree from Knox College in environmental studies. Prior to joining GPI, she supported programs at the Conservation Corps of Minnesota & Iowa as their member experience administrator.

Carbon Management Program Associate, GPI

Alana joined GPI in 2024 as a program associate on the Carbon Management team, specifically supporting the Industrial Innovation Initiative, where she helps to advance industrial decarbonization through GPI’s consensus-building approach. Alana previously worked as an account executive at Jamf, where she helped current K-12 education customers improve and scale the management and security of their Apple device deployments. Alana has spent most of her professional years working with Minnesota nonprofits, including two years as an AmeriCorps member with Twin Cities Habitat for Humanity.  She holds a bachelor’s degree in community environmental studies from the University of Wisconsin-Eau Claire.

Ankita Gangotra, Associate, WRI

Dr. Ankita Gangotra is an Associate in WRI’s US Climate Program, researching avenues to decarbonize the industrial sector, focusing on cement and steel decarbonization, environmental trade policies and international cooperation. Prior to joining WRI, Ankita was a postdoctoral research fellow in the School of Foreign Service and the Department of Physics at Georgetown University. Her research looked at the readily available technology and policy options for upgrading low-carbon cement production in the United States. Ankita has an integrated Master's in Electronics Engineering with Nanotechnology from the University of York, UK (2015) and a Ph.D. in Physics from the University of Auckland, New Zealand (2020). During her time in New Zealand, Ankita interned at the Office of the Prime Minister's Chief Science Advisor looking into equity, diversity and inclusion policy options for New Zealand’s science, research and innovation workforce.

Carrie Dellesky, Program and Outreach Manager, Carbon Removal and Industrial Innovation, WRI

Carrie Dellesky is the Program and Outreach Manager for Carbon Removal and Industrial Innovation. She develops strategies to advance policies and practices for scaling up a suite of carbon removal approaches and decarbonizing the industrial sector. She engages allies and builds and expands partnerships to mobilize champions and enhance visibility, action and impact. She also leads communications to amplify research and thought leadership, including messaging, media relations, event planning, social media and digital strategy.

Zachary Byrum, Research Analyst, WRI

Zachary Byrum is a Research Analyst in WRI's U.S. Climate Program, where he provides technology and policy analysis for carbon removal and deep decarbonization. His work focuses on pathways to reduce industrial emissions as well as bolstering technological carbon removal. Prior to WRI, Zach was a research assistant in the Carbon Management Research Initiative at the Center on Global Energy Policy. In the preceding years, he served as White House Intern in the National Economic Council under the Obama Administration and then an assistant analyst at the Congressional Budget Office. Zach holds a Master of Public Administration in Environmental Science and Policy from the School of International and Public Affairs at Columbia University and a B.A. in Economics and Political Science from Goucher College.

Katie Lebling, Associate, WRI

Katie Lebling is an Associate in WRI's Climate Program where she works on research and analysis of technological carbon removal approaches and industrial decarbonization. Before joining WRI, she worked at The Asia Group, and interned at the Woodrow Wilson Center’s China Environment Forum and the Treasury Department’s Office of Environment and Energy. She holds a Master's degree from Johns Hopkins School of Advanced International Studies in Energy, Resources, and the Environment, where she spent one year of the program studying in Nanjing, China, and has a B.A. from Colby College in Biology and Chinese language.

Debbie Weyl, Deputy Director, WRI United States

Debbie Karpay Weyl is the Deputy Director for WRI U.S. She previously served as Manager for the Buildings Initiative at WRI Ross Center for Sustainable Cities. She led an expanding global partnership to accelerate building energy efficiency in cities around the world. She also contributed to program management and development, research, and knowledge exchange for urban energy efficiency and sustainability. Debbie joined WRI from CLASP, a global non-profit organization that improves the environmental and energy performance of appliances, lighting and equipment. From 2011-2016 Debbie managed and developed global programs, led research projects, and facilitated collaboration among international experts and other representatives in the public, private, and non-profit sectors. Prior to joining CLASP, Debbie worked at the U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, where she was a contractor supporting building efficiency and other energy efficiency programs in the United States. Debbie holds a Master of Science in Environment and Development from the London School of Economics and Political Science, and a B.A. in Politics (Political Economy and International Relations) from Princeton University.

Angela Anderson, Director of Industrial Innovation and Carbon Removal, WRI United States

Angela Anderson is the Director of Industrial Innovation and Carbon Removal in the Climate Program. She leads WRI's growing portfolio of work in industrial decarbonization and carbon removal and aims to change narratives around “hard-to-abate” sectors and promote the natural and technological interventions required to achieve net-zero targets. Prior to joining WRI, Angela worked as a program director, coalition builder, international advocate, and campaign strategist. She led the Climate and Energy Program at the Union of Concerned Scientists for ten years; facilitated US-NGO engagement in the international climate negotiations while at US Climate Action Network and at the Pew Environmental Trust; and founded Clear the Air, a national coalition to reduce pollution from power plants. Angela holds a B.A. in political science from Colorado State University.

Patrice Lahlum, Vice President of Carbon Management, GPI

Patrice Lahlum is the vice president of the Carbon Management program at the Great Plains Institute. The Institute, headquartered in Minneapolis, MN, works with diverse stakeholders and communities across the country to transform the energy system to benefit people, the economy, and the environment. We strive to combine our unique consensus-building approach, expert knowledge and analysis, and local action to promote solutions that strengthen communities, shore up the nation’s industrial base, and enhance domestic energy independence, all while eliminating carbon emissions. Patrice oversees several initiatives including the Carbon Capture Coalition, Industrial Innovation Initiative, Carbon Action Alliance, and the Regional Carbon Capture Deployment Initiative.

Kate Sullivan, Senior Program Coordinator, Carbon Management, GPI

Kate Sullivan joined the Great Plains Institute in 2019. As Senior rogram Coordinator, Kate uses her analytical and design skills to provide research, writing, and logistical support across the Carbon Management team. Prior to joining GPI, Kate worked as an Energy Counselor in the Center for Energy and Environment’s residential department, assisting homeowners with their energy needs and providing resources for efficiency upgrades. Kate earned her BA in Biology from St. Olaf College with an emphasis in Environmental Studies.

David Soll, Industrial Decarbonization Manager, GPI

David Soll joined the Great Plains Institute in 2023 and serves as Industrial Decarbonization Manager. He oversees the Industrial Innovation Initiative, a coalition advancing decarbonization solutions for the Midcontinent region’s most important industrial sectors. Prior to joining GPI, he taught history and environmental studies at the University of Wisconsin-Eau Claire, where he focused on urban infrastructure and energy conservation. David earned a Master’s in government from the University of Texas at Austin and a PhD in history from Brandeis University.

Jill Syvrud, Senior Program Manager, Carbon Management, GPI

Jill Syvrud joined the Great Plains Institute in 2017 and serves as the program manager for the Carbon Management Program. In addition to overseeing the overall program, Jill directly supports the Industrial Innovation Initiative, a coalition advancing decarbonization solutions for the Midcontinent region’s most important industrial sectors. Jill earned a bachelor of science in biology from the University of Wisconsin–Eau Claire and a master of science degree in science technology and environmental policy from the University of Minnesota’s Humphrey School of Public Affairs. Jill’s past experience includes multiple graduate research assistantships concentrating on technology innovation and sustainable megacities along and a previous position as an administrative and outreach coordination intern with the Midwest Renewable Energy Association.