Comments on Section 45X Advanced Manufacturing Production Credit

On December 15, 2023, the U.S. Treasury issued a Notice of Proposed Rulemaking on the Section 45X Advanced Manufacturing Production Credit for the domestic production of certain renewable energy equipment, including thermal batteries. The RTC submitted comments strongly supporting the inclusion of thermal batteries in the credit and advocating for the use of the widely recognized ASME PTC 53 standard for measuring the storage capacity of battery modules. ASME PTC 53’s rigorous methodology aligns with the technology-neutral intent of the proposed rules and would ensure accurate, consistent capacity measurements for enforcement by the IRS.

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