ACEEE, the League of Conservation Voters, and the Alliance to Save Energy filed this response to the Department of the Treasury (Treasury) and the Internal Revenue Service’s (IRS’s) Request for Comment on Energy Security Tax Credits for Manufacturing Under Section 48C of the Internal Revenue Code. The organizations recommended that Treasury and IRS prioritize maximizing long-term greenhouse gas reductions along with climate and economic justice considerations when allocating the 48C credit to eligible projects. Our filing also provided guidance to the agencies on how to define several terms in the context of additions and changes to the advanced energy project credit passed into law as part of the Inflation Reduction Act. These terms included energy efficiency, the 20 percent reduction of greenhouse gas emissions threshold, and industry guidelines on emissions accounting.
