BOSTON — Today, Attorney General Maura Healey led a coalition of 12 attorneys general, the California Air Resources Board, and the Ramsey County, Minnesota Attorney’s Office in calling on the Department of Treasury and the Internal Revenue Service (IRS) to efficiently, effectively, and equitably implement the Inflation Reduction Act (IRA) to reduce greenhouse gas emissions, create good-paying green jobs, and help states transition to a clean energy economy.

The IRA, which President Biden signed into law in August, makes the nation’s largest-ever investments in tackling climate change, directing hundreds of billions of dollars toward climate solutions. Among other things, the IRA provides for incentives to foster clean energy generation, encourage energy efficiency, and support U.S.-based companies that pay a living wage and offer long-term career opportunities.

In comments filed in response to Treasury and the IRS’s requests for public input, the coalition urges Treasury and the IRS to draw on the states’ expertise with implementing programs to promote the transition to clean energy and energy efficiency and offer guidance on centering equity and environmental justice in implementing the law

“The IRA has enormous potential to make a real difference in our states by creating good, green jobs, reducing greenhouse gas emissions, saving our families money, and promoting the critical transition to a clean energy economy,” said AG Healey. “We must ensure it is implemented in a way that ensures all our communities are at the table and benefiting from this historic legislation. We are committed to working with the federal government to fulfill the IRA’s promise.”

The comments point out the significant harm climate change has inflicted—and continues to inflict—on the health of communities in the coalition states, including from droughts, extreme weather events, and sea-level rise. These harms will only worsen over time, the comments note, as will their disproportionate impacts on disadvantaged communities already overburdened with environmental injustices including Black and Latinx populations and those with low incomes.

Massachusetts and other coalition states have pioneered clean energy and climate policies. For example, Massachusetts has promoted energy efficiency through the Mass Save program and facilitated the transition to clean energy by offering incentives for residential, commercial, and industrial consumers to transition to electric heat pumps and electric vehicles. The state spent more than $2.8 billion on energy efficiency programs from 2019 to 2021 and awarded $13 million to electric vehicle charging stations at 150 locations across Massachusetts this year.

The comments suggest various ways that Treasury and the IRS should promote equity and environmental justice through implementation of the IRA’s climate and labor provisions, including proactive public outreach and community engagement to ensure that members of disadvantaged communities have opportunities to provide stakeholder feedback on implementation. The comments also urge Treasury and the IRS to increase eligibility for disadvantaged and low-wealth taxpayers and to take steps to monitor the IRA’s implementation and ensure that disadvantaged and low wealth communities are seeing the benefits of IRA’s incentives.

Other recommendations include

• Working with the U.S. Environmental Protection Agency and Department of Energy to ensure that hydrogen incentives are directed to fuels with the lowest carbon intensity and to establish and regularly update greenhouse gas emissions rates for clean energy technologies;
• Creating precise definitions for credit-eligible commercial electric vehicles;
• Implementing accountability and enforcement mechanisms for ensuring compliance with prevailing-wage and apprenticeship provisions;
• Urging Treasury and the IRS to ensure consistency with state home energy efficiency audit programs—including auditor certification programs—and to ensure only low-emission technologies are eligible for energy efficiency credits;
• Developing clear procedures for identifying emissions-reduction technologies and clear policies to prevent tax benefits from accruing to entities with a history of environmental noncompliance; and
• Issuing transitional guidance to make clean vehicle credits widely available as soon as possible.

Today’s comments were led by AG Healey and joined by the attorneys general of Colorado, Delaware, Illinois, Maine, Maryland, Michigan, New Jersey, New York, Oregon, Rhode Island, and the District of Columbia, as well as the California Air Resources Board and the Ramsey County Attorney’s Office in Minnesota.

In Massachusetts, this matter was handled by Deputy Chief Turner Smith, Assistant Attorneys General I. Andrew Goldberg and Julia Jonas-Day, all of the AG’s Environmental Protection Division; Assistant Attorney General JoAnn Bodemer and Special Assistant Attorney General Kelly Caiazzo, both of AG Healey’s Energy and Telecommunications Division; and Assistant Attorney General Barbara Dillon DeSouza, of the AG’s Fair Labor Division.

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