I 
119TH CONGRESS 
1ST SESSION H. R. 2545 
To amend the Internal Revenue Code of 1986 to extend the publicly traded 
partnership ownership structure to energy power generation projects and 
transportation fuels, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
APRIL 1, 2025 
Mr. ESTES (for himself and Mr. THOMPSON of California) introduced the 
following bill; which was referred to the Committee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to extend 
the publicly traded partnership ownership structure to 
energy power generation projects and transportation 
fuels, and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Financing Our Energy 
Future Act’’. 
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SEC. 2. GREEN ENERGY PUBLICLY TRADED PARTNER-
SHIPS. 
(a) IN GENERAL.—Section 7704(d)(1)(E) of the In-
ternal Revenue Code of 1986 is amended— 
(1) by striking ‘‘income and gains derived from 
the exploration’’ and inserting ‘‘income and gains 
derived from— 
‘‘(i) the exploration’’, 
(2) 
by 
inserting 
‘‘or’’ 
before 
‘‘industrial 
source’’, and 
(3) by striking ‘‘, or the transportation or stor-
age’’ and all that follows and inserting the following: 
‘‘(ii) the generation of electric power 
or thermal energy exclusively using any 
qualified energy resource (as defined in 
section 45(c)(1)), 
‘‘(iii) the operation of energy property 
(as defined in section 48(a)(3), determined 
without regard to any date by which the 
construction of the facility is required to 
begin), 
‘‘(iv) in the case of a facility described 
in paragraph (3) or (7) of section 45(d) 
(determined without regard to any placed 
in service date or date by which construc-
tion of the facility is required to begin), 
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the accepting or processing of open-loop 
biomass or municipal solid waste, 
‘‘(v) the storage of electric power or 
thermal energy exclusively using energy 
storage technology (as defined in section 
48(c)(6)), 
‘‘(vi) the generation, storage, or dis-
tribution of electric power or thermal en-
ergy exclusively using energy property that 
is combined heat and power system prop-
erty (as defined in section 48(c)(3), deter-
mined without regard to subparagraph 
(B)(iii) thereof and without regard to any 
date by which the construction of the facil-
ity is required to begin), 
‘‘(vii) the transportation or storage 
of— 
‘‘(I) any fuel described in sub-
section (b), (c), (d), (e), or (k) of sec-
tion 6426, or 
‘‘(II) liquified hydrogen or com-
pressed hydrogen, 
‘‘(viii) the conversion of renewable bio-
mass (as defined in subparagraph (I) of 
section 211(o)(1) of the Clean Air Act (as 
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in effect on the date of the enactment of 
this clause)) into renewable fuel (as de-
fined in subparagraph (J) of such section 
as so in effect), or the storage or transpor-
tation of such fuel, 
‘‘(ix) the production, storage, or 
transportation of any fuel which— 
‘‘(I) uses as its primary feedstock 
carbon oxides captured from an an-
thropogenic source or the atmosphere, 
‘‘(II) does not use as its primary 
feedstock carbon oxide which is delib-
erately released from naturally occur-
ring subsurface springs, and 
‘‘(III) is determined by the Sec-
retary, after consultation with the 
Secretary of Energy and the Adminis-
trator of the Environmental Protec-
tion Agency, to achieve a reduction of 
not less than a 60 percent in lifecycle 
greenhouse gas emissions (as defined 
in section 211(o)(1)(H) of the Clean 
Air Act, as in effect on the date of the 
enactment of this clause) compared to 
baseline lifecycle greenhouse gas emis-
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sions 
(as 
defined 
in 
section 
211(o)(1)(C) of such Act, as so in ef-
fect), 
‘‘(x) the generation of electric power 
from a qualifying gasification project (as 
defined in section 48B(c)(1) without re-
gard to subparagraph (C)) that is de-
scribed in section 48B(d)(1)(B), 
‘‘(xi) in the case of a qualified facility 
(as defined in section 45Q(d), without re-
gard to any date by which construction of 
the facility is required to begin) not less 
than 50 percent of the total carbon oxide 
production of which is qualified carbon 
oxide (as defined in section 45Q(c))— 
‘‘(I) the generation, availability 
for such generation, or storage of elec-
tric power at such facility, or 
‘‘(II) the capture of carbon diox-
ide by such facility, 
‘‘(xii) the generation of electric power 
or energy from any advanced nuclear facil-
ity (as defined in section 45J(d)(2)), or 
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‘‘(xiii) the production, storage, or 
transportation of any renewable chemical 
which— 
‘‘(I) is produced in the United 
States (or in a territory or possession 
of the United States) from renewable 
biomass, 
‘‘(II) is not less than 95 percent 
biobased content, 
‘‘(III) is not sold or used for the 
production of any food, feed, fuel, or 
pharmaceuticals, 
‘‘(IV) is approved to use the 
USDA Certified Biobased Product 
label under section 9002(b) of the 
Farm Security and Rural Investment 
Act of 2002 (7 U.S.C. 8102(b)), and 
‘‘(V) is a chemical intermediate 
(as such term is defined in section 
3201.109 of title 7, Code of Federal 
Regulations 
(or 
successor 
regula-
tions)),’’. 
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