ACORE Comments to Treasury on Prevailing Wage and Apprenticeship Requirements

Office of Associate Chief Counsel
(Passthroughs & Special Industries)
Internal Revenue Service
1111 Constitution Ave, NW Washington, DC 20224

Dear Office of Associate Chief Counsel,

The American Council on Renewable Energy (“ACORE”) respectfully submits these comments in response to the U.S. Department of the Treasury (“Treasury” or “Department”) and Internal Revenue Service (“IRS”) request for public comment in response to the proposed regulations pursuant to REG-100908-23 (“proposed regulations”) concerning the increased credit or deduction amounts for satisfying certain prevailing wage and registered apprenticeship (“PWA”) requirements. With its enactment of historic labor standards tied to the full value of certain tax credits, the Inflation Reduction Act of 2022 (“IRA”) is poised to expand well-paying renewable energy employment opportunities in tandem with accelerated project deployment.

The proposed regulations are an important step toward that end, but we appreciate your attention to several critical areas of clarification identified by the comments to follow, which we offer in support of your ongoing work to facilitate compliance through timely, fair, and practicable guidance for all parties involved.