Comment Letter on Section 30C of the Internal Revenue Code

My name is James R. Copland, and I am a senior fellow with and director of legal policy for the Manhattan Institute. 1 In those roles, I develop and communicate novel, sound ideas on how to improve America’s civil- and criminal-justice systems. My latest book, The Unelected: How an Unaccountable Elite is Governing America (Encounter Books), was published in September 2020. I have testified before Congress as well as state and municipal legislatures and international rulemaking bodies. I have authored many policy briefs and book chapters; articles in journals including the Harvard Business Law Review and Yale Journal on Regulation; and opinion pieces in popular publications including the Wall Street Journal, National Law Journal, Washington Post, and USA Today.

I strongly oppose the proposed regulations for their inconsistency with the statutory language and intent of Section 30C of the Code, which was designed to provide a narrow and targeted tax-incentive credit for alternative fuel vehicle refueling property (including electric vehicle (EV) charging stations). The proposed regulations are contrary to the public interest and will raise the true cost of the IRA far beyond Congressional Budget Office estimates sold to the public and assumed by elected legislators at the time the IRA was passed.

James R. Copland is a senior fellow at the Manhattan Institute and director of Legal Policy. 

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