On June 24, the American Chemistry Council responded to a Request for Information from the U.S. Department of Energy (DOE), “Transforming Industry: Strategies for Decarbonization (DEFOA-0003363). Our comments are part of our ongoing engagement with policymakers on ways to drive the nation toward a lower emissions economy while promoting an innovative and competitive U.S. manufacturing sector.
Improving Performance
ACC members are taking action to reduce the industrial greenhouse gas (GHG) intensity of their supply chains, operations, and products. Through Responsible Care®, the chemical industry’s environmental, health, safety, and security performance initiative, we track member company performance on a range of EHS metrics, including GHG intensity. From 2017 to 2022, ACC’s reporting members reduced their GHG intensity by more than 8 percent, even as demand for chemistry products increased.
We’re incorporating new metrics into Responsible Care to address GHG emissions and energy. We’re asking our members to indicate the percentage of their energy portfolio comprising renewable energy and other lower-emissions energy. This will help us gauge progress in adapting our facilities and energy use to transition to lower-emissions options.
Chemistry’s Role in Industrial GHG Improvement
American chemistry is a key stakeholder and partner in the nation’s drive toward a lower emissions future, both as a regulated industry and as a provider and enabler of materials, products, and technologies that help society save energy and reduce emissions.
Chemical manufacturing is energy-intensive, and chemistry products and processes are diverse. The chemistry industry operates in global markets where it faces intense competition. There is no ‘one size fits all’ technology solution or approach for reducing emissions, and this needs to be reflected in development and implementation of strategies for the industrial sector.
Many of the base chemicals and chemical products manufactured by ACC members and used throughout the economy have carbon as a building block. As a result, our industry typically uses the terms “emissions reductions” and “emissions abatement” rather than “decarbonization,” which can have multiple meanings and applications.
A Focus on Innovation
Chemistry companies are working with the public and private sectors and other stakeholders to accelerate innovation into technologies that help reduce emissions. Examples include process efficiency technology and programs; lower-emissions hydrogen; carbon capture, utilization, and storage (CCUS) and direct air capture; the use of biomaterials and circular feedstocks; and advanced recycling of plastics. And we’re looking ahead to advanced nuclear, process electrification, and more.
Our work also includes product innovation: Chemistry and plastics are key “inputs” for a host of emissions-reducing applications, including solar and wind power; fuel efficient automobiles and electric vehicles (EVs); high-performance building materials, advanced battery systems, and more.
Priorities for R&D Funding
ACC’s response to DOE highlighted our support for an ‘all-of-the-above’ technology strategy. DOE should evaluate a variety of technologies that could help reduce emissions at different scales and with different chemistries, and in different regions with access to key resources and inputs.
One area of concern is the pending final guidance and eligibility requirements for the 45V Clean Hydrogen tax credit. Earlier this year, ACC submitted comments regarding the need to ensure the final 45V tax credit guidance incentivizes investment in all forms of lower-emissions hydrogen production technologies that can meet the GHG emissions standards, regardless of the energy source, feedstock or process. DOE should consider providing a pilot tech center for clean hydrogen technologies, similar to the National Carbon Capture Center.
Policies to Support Lower-Emissions Manufacturing
ACC works with members to identify the array of pathways and policies needed to help reduce emissions in the industrial sector. Fundamentally, proposals need to spur innovation while maintaining U.S. competitiveness. They should encourage the development and use of energy sources, infrastructure, and manufacturing technologies of all kinds. Effective coordination across agencies and programs is critical.
We view regulatory and permitting reform and substantial investment into pipelines and other infrastructure as priorities. Our nation needs to swiftly connect lower-emissions energy and manufacturing value chains and markets, but uncertainty around technology investment coupled with significant capital and operating budget constraints can make it difficult for companies to invest in new technology abatement pathways.
We encourage policymakers to streamline the permitting processes for lower-emissions technologies (e.g., hydrogen, CCUS, and zero-emissions electricity) and provide greater clarity on tax incentives for reduced emissions fuel sources and feedstocks. Regulatory policies must be predictable and reasonable with respect to both project and infrastructure permitting and renewals. We also advocate for policies that will continue to strengthen and maintain strong domestic supply chains.
Collaboration Is Vital
Increased interagency coordination and sector specific engagement are needed. We urge the administration to continue to look for and develop opportunities to consult with industry and consider streamlining or clarifying the process for interested stakeholders seeking guidance or technical support. For example, the standards and requirements outlined in Funding Opportunity Announcements (FOAs) and guidance are often complex and involve many factors beyond the climate benefits of a specific project. This can make it difficult for companies to assess whether a government program or grant will be suitable and competitive.
