The U.S. has experienced more than $200 billion in new clean energy project investments since passage of the Inflation Reduction Act (IRA) in 2022. Because of its natural resources for clean hydrogen feedstock (both gas and renewables), Texas has been one of the major beneficiaries. However, throughout 2023 and into 2024, would-be clean fuels project developers and sponsors struggle with uncertainty in developing their projects. Legal and regulatory risk, in particular, has caused some would-be developers to wait on the sidelines for the time being. First-movers in the clean fuels space must learn to adapt to a long list of challenges.