Domestic Content Bonus Credit Amounts under the Inflation Reduction Act of 2022: Expansion of Applicable Projects for Safe Harbor in Notice 2023-38 and New Elective Safe Harbor to Determine Cost Percentages for Applicable Percentage Rule (Notice 2024-41)

The American Public Power Association (APPA) appreciates this opportunity to comment on Notice 2024-41, "Domestic Content Bonus Credit Amounts under the Inflation Reduction Act of 2022: Expansion of Applicable Projects for Safe Harbor in Notice 2023-38 and New Elective Safe Harbor to Determine Cost Percentages for Adjusted Percentage Rule" (Notice 2024-41), which modifies Notice 2023-38, "Domestic Content Bonus Credit Guidance under Sections 45, 45Y, 48, and 48E" (Notice 2023-38). APPA has previously filed comments on these notices, but takes this opportunity to comment on the request in Notice 2024-41 for information about the expansion of the various safe harbors to include new and additional technologies.

Please see the attached joint comment letter regarding Notice 2024-41, Domestic Content Bonus Credit Amounts under the Inflation Reduction Act of 2022: Expansion of Applicable Projects for Safe Harbor in Notice 2023-38 and New Elective Safe Harbor to Determine Cost Percentages for Adjusted Percentage Rule. The letter is signed by the American Public Power Association, Government Finance Officers Association, National Association of Counties, National League of Cities and National Rural Electric Cooperatives Assocation.