The clean energy tax credits extended and strengthened in the Inflation Reduction Act, and the accessibility of those credits for tax-exempt institutions through elective pay, will accelerate and broaden the deployment of clean energy, especially by non-profit and public entities. We commend the Department of Treasury for effectively advancing guidance to clarify these entities’ ability to access the clean energy tax credits. This opportunity will help drive down emissions, create high-quality, union jobs, and more equitably distribute clean energy investment to serve the public interest.

Our comments on the proposed rule center on the following four topics: 1) technical support for low-income and energy communities; 2) domestic content; 3) ITC eligibility for U.S. territories; and 4) pre-filing registration processes. Our recommendations on these topics are intended to ensure that the historic opportunity of direct pay is fully optimized and accessible to those who need it the most.

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