BlueGreen Alliance | BlueGreen Alliance Responds to the Department of the Treasury & Internal Revenue Service’s Request for Comments on Energy Security Tax Credits for Manufacturing under 48C and 45X

BlueGreen Alliance Responds to the Department of the Treasury & Internal Revenue Service’s Request for Comments on Energy Security Tax Credits for Manufacturing under 48C and 45X

These tax credits present a once-in-a-generation opportunity to dramatically reduce greenhouse emissions, as well as toxic air, water, and land pollution, while providing good union jobs in the clean economy and driving growth in U.S. manufacturing.

November 4, 2022

With strong implementation, these provisions will help build a reliable and equitable U.S. supply chain for the clean economy instead of depending on production overseas that is often marred by labor abuses, higher levels of pollution, and shipping bottlenecks. These investments are essential not only to achieve our climate goals, but also to counter the racial and economic inequality fed by manufacturing job losses. They could be a game-changer for cutting industrial emissions—a leading source of climate and air pollution—while onshoring clean technology manufacturing. The Inflation Reduction Act provides the largest investment in clean manufacturing in decades, offering a historic opportunity to support good union jobs, climate action, and a more just economy.

The 45X and 48C tax credits offer a supply-side push for clean technology manufacturing and reduced industrial emissions, which pairs well with the newly established demand-side pull of the clean vehicle tax credit and the domestic content bonus for the clean energy tax credits. The criteria and definitions for each of these provisions must be carefully designed to ensure meaningful community and labor engagement; the creation of high-quality jobs, deep reductions in emissions; and greater economic, racial, and environmental equity.

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