On August 2, 2024, the New Jersey Environmental Justice Alliance, along with co-signed allies, submitted comments to U.S. Department of the Treasury and the Internal Revenue Service regarding the proposed regulations for the 45Y/48E Clean Energy Tax Credits.
This federal funding will be an integral component in the Just Transition and funding clean energy in the United States. However, as these credits are designed to be technology-neutral (i.e. no one particular type of energy production is to be favored), there is a risk that these credits may be granted to facilities which do not truly produce clean energy and pose a risk to the surrounding communities.
We submit these comments to: (1) urge the Dept. of the Treasury and the IRS to center environmental justice, (2) incorporate GHG co-pollutants into the emissions calculations, (3) expand the emissions calculations, (4) include a geographical analysis in the alternative fates analysis, (5) exclude polluting combustion and gasification facilities from the list of qualified facilities as they cannot demonstrate a zero emissions mode of production, and (6) address EJ concerns with carbon captures. All of these changes can bring significant protections to environmental justice communities and greatly reduce the risk of harm.
For questions regarding NJEJA’s position and related policy concern, please contact Brooke Helmick, Director of Policy at brooke@njeja.org.
Read our full comments below:
