Comment Letter on Section 45Y Clean Electricity Production Credit and Section 48E Clean Electricity Investment Credit

Thank you for the opportunity to comment on the proposed rules implementing Section 45Y (Clean Electricity Production Credit) and Section 48E (Clean Electricity Investment Credit) of the Internal Revenue Code (IRC). I am a senior fellow with the Manhattan Institute for Policy Research, a non-profit, non-partisan think tank that develops and disseminates ideas that foster economic choice and individual responsibility. Since 2003, I have served as the Institute’s director of legal policy. I am writing to express my concern that the rules as proposed lack a clear statutory basis and threaten to expand energy subsidies well beyond the 10-year scope enumerated by the Inflation Reduction Act (IRA).

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

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