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Comments to Treasury and IRS on IRA Implementation

Following the passage of the Inflation Reduction Act, the Department of Treasury and the Internal Revenue Service issued a series of Requests for Information seeking comments and suggestions on implementing the tax benefits contained in the historic climate law. Building on Policy Integrity's deep expertise in incorporating equity into the rulemaking process, we submitted general comments advising Treasury and IRS to: 

  1. coordinate with other federal agencies with experience incorporating environmental justice and equity into their rulemaking process; and
  2. conduct robust stakeholder outreach throughout the guidance and rulemaking process, especially in disadvantaged communities.

In addition, Policy Integrity included specific recommendations with respect to the calculation of carbon intensity for hydrogen production based on recent comments to the Department of Energy. Regarding the issue of hydrogen, Policy Integrity also filed supplemental comments with WattTime that offered additional information on why our recommended approach would be administrable.