WASHINGTON — Citizens for Responsible Energy Solutions (CRES) Forum submitted comments urging the U.S. Department of the Treasury to revisit the proposed guidance on Section 45X of the Internal Revenue Code (IRC). Section 45X is the advanced manufacturing production tax credit, which is intended to onshore clean energy manufacturing supply chains and bolster existing domestic manufacturing.
“Increasing U.S. manufacturing independence is critical to bolstering the strength of the domestic clean energy industry, as reliance on imports from foreign producers has meant vulnerabilities in the U.S. supply chain,” wrote CRES President Heather Reams. “Dependence on potential adversaries for materials for advanced components that drive our economy will imperil our national security, and Section 45X is intended to strengthen domestic capacity and resilience in clean energy and industrial manufacturing, enabling the United States to maintain its global competitiveness. CRES Forum encourages Treasury to restore the focus of the guidelines for the Section 45X tax credit to address the original intent of the statute.”
CRES Forum’s comments requested clarification on several items from Treasury’s proposed guidance, including information on the origin of components, timelines, tax credit calculation and eligibility of critical minerals.
The comments also expose several shortcomings that should be improved to leverage the U.S. carbon advantage and increase American competitiveness. CRES Forum calls on Treasury to use 45X to strengthen the domestic mining industry by promoting the use of raw materials produced in the United States. Doing so would increase American energy security and lower global emissions by subverting use of minerals developed in countries like China, where the economy is three times more carbon-intensive than the United States.