The BlueGreen Alliance (BGA) unites the nation’s labor unions and environmental organizations to solve today’s environmental challenges in ways that create and maintain quality jobs and build a stronger, fairer economy. Our partnership is firm in its belief that we don’t have to choose between good jobs and a clean environment—we can and must have both. The 45X Advanced Manufacturing Production Tax Credit provides the largest ever investment in U.S. manufacturing of clean energy technologies. These investments are core to our mission to link climate action with good union jobs and to counter the racial and income inequality fed by manufacturing job losses. 45X is critical to the Inflation Reduction Act’s larger strategy to reduce industrial emissions and pollution, re-shore clean technology supply chains, support good manufacturing jobs, and spur U.S. global competitiveness. We appreciate the opportunity to respond to the U.S. Department of the Treasury’s (Treasury) recently published NPRM for the 45X Advanced Manufacturing Production Credit.

Implementation of 45X is essential to supporting the domestic manufacturing revitalization needed to address climate change; supporting and creating good union jobs; and advancing racial, economic, and environmental justice. BGA commends the proposed rule as critical for growing domestic manufacturing for solar, wind, batteries, and aluminum. The rule would make domestically manufactured goods in the sectors included competitive with imports. Since passage of the Inflation Reduction Act, the 45X credit has been responsible for billions of dollars of announcements for new clean energy manufacturing facilities. Finalizing the proposed rule is the next step to ensuring these announcements lead to sustained investments in the solar, wind, battery, and aluminum processing sectors.

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