Joint Comments of the Clean Energy Organizations on the Requests for Comments on Guidance on Certain Clean Energy Tax Credits Under the Inflation Reduction Act

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Internal Revenue Service
CC:PA:LPD:PR (Notices 2022-49, -50, -51)
Room 5203 P.O. Box 7604
Ben Franklin Station
Washington, DC 20044

RE: Joint Comments of the Clean Energy Organizations on the Requests for Comments on Guidance on Certain Clean Energy Tax Credits Under the Inflation Reduction Act

The American Clean Power Association (“ACP”), American Council on Renewable Energy (“ACORE”), Advanced Energy Economy (“AEE”), and Solar Energy Industries Association (“SEIA”) are the national non-profits and trade associations (collectively, “Clean Energy Organizations”)1 representing various segments of the U.S. clean energy industry. Our members promote environmentally responsible development of distributed and utility-scale clean energy, storage, and related technologies.

We are committed to working with federal agencies, environmental and conservation organizations, Tribal governments, state agencies, and other stakeholders to achieve this goal. On behalf of our member companies, we appreciate the opportunity to provide these comments on the Treasury Department (“Treasury”) and Internal Revenue Service’s (“IRS”) request for comments on energy guidance under the Inflation Reduction Act (“IRA”).

On November 4, 2022, ACP, ACORE, AEE, and SEIA each submitted separate responsive comments to the Notices 2022-46 through 2022-51. Those comments offer robust recommendations on how proper implementation of the clean energy tax credits under the IRA will accelerate clean energy deployment and carbon emission reduction, consistent with the IRA, while invigorating the U.S. clean energy workforce and supply chain.

On behalf of our member companies, we appreciate the opportunity to provide these joint comments highlighting areas of alignment with respect to key areas for prompt and workable guidance.