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The Solar Energy Manufacturers for America (SEMA) Coalition commends the Department of the Treasury (Treasury) and Internal Revenue Service (IRS) for providing the opportunity to comment on the June 3, 2024, notice of proposed rulemaking (NPRM) relating to the clean electricity production credit (45Y) and clean electricity investment credit (48E) established by the Inflation Reduction Act’s (IRA). The NPRM aims to clarify for clean electricity project developers what specific technologies would categorically qualify for the new 45Y and 48E, replacing the existing production and investment tax credits that sunset on December 31, 2024. SEMA strongly supports Treasury’s proposed regulations clarifying that energy storage technology (EST) and energy generation technology (including solar) are separate qualified facilities under 48E. These comments build off SEMA’s previous recommendations to Treasury on July 15, 2024, requesting the clarification that hybrid systems should independently qualify by technology for the domestic content bonus credit.
The SEMA Coalition is a diverse group of solar manufacturers united to rebuild the domestic solar supply chain. SEMA represents the interests of the major non-Chinese solar manufacturers who are building or looking to build strategic solar components across the value chain in the U.S. Our coalition works to implement a suite of policies to rebuild a secure, competitive, and sustainable U.S. solar supply chain to meet current and future solar deployment needs while creating good-paying manufacturing jobs.
We respectfully submit the enclosed comments in response to Docket No. IRS-2024-0026 and would welcome the opportunity to continue engaging with Treasury, IRS, and Department of Energy (DOE)officials on these important matters.
