ACORE’s Comments to Treasury on Implementing the IRA’s Alternative Fuel Vehicle Refueling Property and Clean Hydrogen Production Incentives

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

Re: Comments pertaining to Notices 2022-56 and 2022-58:

Dear Office of Associate Chief Counsel:

The American Council on Renewable Energy (“ACORE”) respectfully submits the following comments in response to the U.S. Department of the Treasury (“Treasury” or “Department”) and Internal Revenue Service (“IRS”) request for comment on implementing key provisions of the Inflation Reduction Act of 2022 (“IRA”). ACORE is a 501(c)(3) national nonprofit organization working to unite finance, policy, and technology to lead the transition to a renewable energy economy.

ACORE appreciates this opportunity to provide Treasury with feedback on Notices 2022-56 and 2022-58 pertaining to its implementation of IRA under § 30C, Alternative Fuel Vehicle Refueling Property Credit and § 45, Clean Hydrogen and Clean Fuel Production tax credits, respectively.

The comments below reflect our appreciation of the pivotal role the Department has for incenting greater development of refueling stations, especially for communities without historical access to these properties, as well as the development of a durable and world-leading national clean hydrogen network.