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IRSNonrulemakingIRS-2022-0023

Request for Comments on Certain Energy Generation Incentives (Notice 2022-49)

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Dec 31, 2024
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closed 1362d ago
Southern Environmental Law Center (SELC) filings
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Southern Environmental Law Center (SELC) filed 4 comments on this docket between Nov 8, 2022 and May 23, 2024. 121 other organizations filed here. The comment window closed 1362d ago.

What Southern Environmental Law Center (SELC) filed (4)

May 23, 2024· Comment from Southern Environmental Law Center· IRS-2022-0023-2202

The undersigned respectfully submit the following supplemental comments to the Department of the Treasury and the Internal Revenue Service ("Treasury") in response to the Request for Comments on Certain Energy Generation Incentives (Notice 2022-49) under the Inflation Reduction Act of 2022 ("IRA"). The Southern Environmental Law Center, Natural Resources Defense Council, and National Wildlife Federation, together with other non-governmental organizations, initially submitted comments by the deadline of November 4, 2022 (the "Initial Comments"). These supplemental comments address two topics raised in submissions by other commenters: (1) the Greenhouse gases, Regulated Emissions, and Energy use in Transportation ("GREET") model, and (2) international carbon accounting conventions. Like our Initial Comments, these supplemental comments focus exclusively on the use of forest-derived biomass, by which we mean a woody fuel removed directly from a forest. Please see attached file.

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Jan 4, 2024· Comment from Southern Environmental Law Center· IRS-2022-0023-2188

Southern Environmental Law Center letter re: Tax Credit Eligibility for Solar Thermal Projects Under Section 48

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Nov 30, 2022· Comment from Southern Environmental Law Center· IRS-2022-0023-2120

The undersigned respectfully submit the attached comments to the Department of the Treasury and the Internal Revenue Service in response to the Request for Comments on Certain Energy Generation Incentives (Notice 2022-49) under the Inflation Reduction Act of 2022 ("IRA" or the "Act"). The undersigned non-governmental organizations have worked extensively on issues related to the use of forest biomass for electricity production. These comments therefore focus exclusively on the role of forest-derived biomass and demonstrate that the emissions rate for power plants utilizing such material is well above zero. Accordingly, Treasury must classify forest-biomass-burning power plants as non-zero emissions sources ineligible for Clean Electricity Production Tax Credits ("CEPTC") under Section 45Y. This submission is an amended version of comments submitted on November 4, which have been assigned Comment ID IRS-2022-0023-1963. The second sentence of the first paragraph has been amended to enhance grammatical clarity. No substantive changes have been made. Athens County's Future Action Network Center for Biological Diversity Common Defense Dogwood Alliance Earthjustice Friends of the Earth League of Conservation Voters Mighty Earth National Wildlife Federation Natural Resources Defense Council Partnership for Policy Integrity Pivot Point Sierra Club Southern Environmental Law Center

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Nov 8, 2022· Comment from Southern Environmental Law Center· IRS-2022-0023-1963

The undersigned respectfully submit the attached comments to the Department of the Treasury and the Internal Revenue Service in response to the Request for Comments on Certain Energy Generation Incentives (Notice 2022-49) under the Inflation Reduction Act of 2022 ("IRA" or the "Act"). The undersigned are a group of non-governmental organizations that have worked extensively on issues related to the use of forest biomass for electricity production. These comments therefore focus exclusively on the role of forest-derived biomass and demonstrate that the emissions rate for power plants utilizing such material is well above zero. Accordingly, Treasury must classify forest-biomass-burning power plants as non-zero emissions sources ineligible for Clean Electricity Production Tax Credits ("CEPTC") under Section 45Y. Athens County's Future Action Network Center for Biological Diversity Common Defense Dogwood Alliance Earthjustice Friends of the Earth League of Conservation Voters Mighty Earth National Wildlife Federation Natural Resources Defense Council Partnership for Policy Integrity Pivot Point Sierra Club Southern Environmental Law Center

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Abstract

The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) plan to issue guidance regarding the provisions of §§ 45, 45U, 45Y, 48, and 48E of the Internal Revenue Code (Code), as amended or added by §§ 13101, 13105, 13701, 13102, and 13702, respectively, of Public Law 117-169, 136 Stat. 1818 (August 16, 2022), commonly known as the Inflation Reduction Act of 2022 (IRA).

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Co-filers (121)

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