Fostering improved, clean transportation has the potential to benefit the country enormously, and advances key goals of the Biden Administration. The transportation sector is the largest source of greenhouse gas emissions in the United States, accounting for one-third of all emissions, and must be addressed for there to be any hope of meeting climate goals. Transportation also affects every American's day-to-day life, from how they participate in their communities to how they pursue economic opportunity and empowerment, representing a significant opportunity to promote equitable growth.
The Blueprint is the Administration's most fleshed out vision for pursuing these goals. The Blueprint outlines a comprehensive approach, addressing changes to every mode of transportation, and proposing to do so through virtually every policy lever available—a true "whole of government" approach. It is consistent with, and further advances, key themes in the President's climate policy enunciated from day one, and further reflected in his signature legislative accomplishments, the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA).
The Blueprint was a highlight of government speakers at the recent Government/Industry Conference for the auto industry, sponsored by the Society of Automotive Engineers: In a keynote, Gabe Klein, Executive Director of the newly formed DOE-DOT Joint Office of Energy & Transportation, called it the "most important policy document in a decade."
Below are some of the key features:
- Multiple technological solutions will be needed, reflecting an evolving decarbonization path for several sectors. To many, the electric passenger car is the symbol of transportation decarbonization. But power demands and weight considerations, among other issues, may make it more difficult to use this technology in other sectors, including on-highway freight, maritime, and aviation. The Blueprint recognizes that additional technology must be deployed, including those not yet fully commercialized. It focuses on three: battery electric, hydrogen fuel cell, and sustainable biofuel.
The continued prominence of liquid fuels in a transportation decarbonization plan is especially notable. There remains active debate, even within the agencies which authored the Blueprint as to whether the types of "sustainable" fuels being promoted have the full range of climate benefits they claim.
- But new technology is not the only tool. In addition to developing and deploying clean technology, the Blueprint will promote measures to decrease transportation demand and increase transportation efficiency. The Blueprint seeks to redesign the communities in which we live, so that people are physically closer to where they work, learn, and recreate. Consistent with the Biden Administration's "whole of government" approach, this will involve policymakers outside of the four agencies who authored the report, including non-federal entities like towns, cities, and counties with jurisdiction over zoning laws that shape land use. The Blueprint also stresses policies to encourage the most climate-friendly mode of transportation when movement is necessary: For movement of people, this will likely result in renewed focus on mass transit and emission-free micromobility options.
- A three stage timeline with interim targets. Broadly speaking, between now and 2030, the Blueprint focuses most on research and investments to support deployment.In the 2030s, the focus is on scaling up clean transportation solutions, and the 2040s will be about completing the transition to a net zero transportation sector. But there are plenty of interim benchmarks in between, such as a commitment that all new light-duty acquisitions for the federal fleet be zero emission by 2027, and 30% of private sales of medium and heavy duty vehicles be zero emission by 2030.
- Continued focus on equity. Ensuring a just transition of the transportation sector is a cornerstone of the Blueprint. Among other concerns, this will mean a focus on ensuring that zero emissions technology successfully penetrates all communities. This could mean creating enhanced subsidies for acquiring electric vehicles, ensuring charging stations are meaningfully available in historically overburdened neighborhoods, and ensuring that transit service is fully accessible for the differently abled.
- Interaction with advanced driver assistance technology (ADAS). The Blueprint acknowledges that transportation will "dramatically change" in "ways that are hard to forecast," focusing in particular on another transformational shift occurring in the transportation sector: the emergence of automation and connectivity, up to full vehicle automation. Although such technology is often discussed for its appealing safety benefits, it may also reduce congestion and result in significant environmental gains as well.
- The continued role of agency-promulgated regulatory standards. The Blueprint is clear that agency-promulgated, technology-forcing regulation has an important role to play in decarbonizing transport, even if the BIL and IRA focused mainly on incentive-based mechanisms. The Blueprint specifically mentions renewable fuel standards, and emissions standards for heavy duty on-highway, off road, and fuel pipeline transportation. More are likely in store, although the Biden Administration will have to tread carefully in light of recent Supreme Court precedent narrowly interpreting the agency enabling statutes that will serve as the authority for these rules.
Whether the Blueprint's lofty ambitions will be met remains to be seen, but the document is an important outline of the federal agenda to come, at least for the remainder of Biden's presidency. The transportation sector is in the process of fundamental change, set to dramatically reduce where feasible uses of the internal combustion engine—the technology that served as its bedrock for over 100 years. This process will create exciting opportunities and difficult choices, and the Blueprint provides important insight into federal priorities that should be thoroughly understood when engaging policymakers going forward and when making investment decisions.
On August 16, 2022, President Biden signed the Inflation Reduction Act (IRA) into law, directing a record $370 billion toward clean energy investments.
Yesterday, the White House released a 182-page guidebook to the IRA entitled Building a Clean Economy. John Podesta, Senior Advisor to the President for Clean Energy Innovation and Implementation, explains in his introduction that the guidebook "provides a program-by-program overview of the Inflation Reduction Act, including who is eligible to apply for funding and for what purposes." In the coming weeks and months, the Administration will provide further updates on www.CleanEnergy.gov.
See here for our post providing an overview of the major energy provisions in the IRA.
(a) The make, model, model year, and any other appropriate identifiers of the motor vehicle;
(b) Certification that the motor vehicle is made by a qualified manufacturer, within the meaning of Section 30D(d)(3);
(c) Certification that the motor vehicle is treated as a motor vehicle for purposes of title II of the Clean Air Act;
(d) The gross vehicle weight rating of the motor vehicle;
(e) The battery capacity of the motor vehicle;
(f) The motor vehicle's vehicle identification number!and
(g) Such other information as the Secretary may provide on irs.gov.
With respect to the Section 30D credit, the following additional information needs to be provided:
(a) Certification that the motor vehicle is propelled to a significant extent by an electric motor that draws electricity from a battery that has a capacity of not less than 7 kilowatt hours and the battery is capable of being recharged from an external source of electricity, or the motor vehicle is a new qualified fuel cell motor vehicle;
(b) Certification that the motor vehicle is manufactured primarily for use on public streets, roads and highways (not including a vehicle operated exclusively on a rail or rails) and has at least four wheels;
(c) Certification that the final assembly of the motor vehicle occurred within North America;
(d) Certification of the percentage of the value of the applicable critical minerals contained in the electric vehicle's battery that were (i) extracted or processed in the United States or a FTA partner country, or (ii) recycled in North America;
(e) Certification of the percentage of the value of the EV battery components that were manufactured or assembled in North America;
(f) Whether the motor vehicle is a van, sport utility vehicle, pickup truck, or other vehicle!and
(g) The motor vehicle's manufacturer's suggested retail price.
Similarly, with respect to Section 25E and 45W credits, the manufacturer must provide additional information to show that vehicles satisfy the statutory qualifications for credit eligibility.
A vehicle seller, such as a dealer, must furnish a report to a purchaser not later than the purchase date and an annual report to the IRS, including the following information:
(a) The name and taxpayer identification number of the seller;
(b) The name and taxpayer identification number of the purchaser;
(c) The vehicle identification number, if assigned, of the vehicle;
(d) The battery capacity of the vehicle;
(e) For new clean vehicles, verification that original use of the vehicle commences with the purchaser;
(f) The date of sale, sale price of the vehicle, and maximum credit allowable to the purchaser!and
(g) If a purchaser makes an election to transfer the credit to the selling dealer that satisfies certain requirements for sales after December 31, 2023, any amount paid or allowable as a partial payment or down payment.
This revenue procedure notably does not require qualified manufacturers to certify as to a vehicle's satisfaction of the requirements in Section 30D(d)(7)—that the critical minerals in the battery have not been extracted, processed, or recycled by a "foreign entity of concern" and that the components contained in the battery have not been manufactured or assembled by a foreign entity of concern. This would seem to impose less of a diligence burden on manufacturers.同理,税收程序没有解决车辆购买者如何确定车辆满足这些需求的问题。我们注意到,IRS可添加这项附加认证要求,作为2024或2025前“秘书可能提供的其他信息”的一部分,而2024或2025前外国受关注实体规则生效。
IT似乎报告需要解决车辆信用分数问题万博体育app手机登录As such, two vehicles of the identical make, model, and year may not always have the same credit eligibility, which will vary depending on the composition of critical minerals and components and the location of final assembly.
Manufacturers and sellers must submit a declaration under penalties of perjury that the facts presented in support of this certification are true, correct, and complete. A purchaser of a vehicle can rely on the manufacturer's certification for the Section 30D, 45W, and 25E credits.
This revenue procedure does not provide any guidance on how to determine the value of critical minerals and components. The revenue procedure expressly notes that it does not constitute the guidance the IRS is required to propose regarding Section 30D(e)(1) (Critical Minerals Requirement) and Section 30D(e)(2) (Battery Components). Such guidance is due to be published separately, by no later than December 31, 2022.
最后,我们注意到税收程序没有表示政府会放松信用计划的法定时限-例如提供过渡期-正如许多制造商所请求的那样。
我们将继续监测和报告这些动态。
2022年10月5日,国库局和国税局发布通知,请求对《降低通货膨胀法》('IRA')中能源税益的不同方面发表评论11月4日星期五前应提交所有评论,或电子发布www.reducts.gov或寄送国税局万博体育app手机登录日期过后提交的书面评语将予考虑,只要不延迟发布指南。
通知征求一般性意见,但也侧重于具体定义问题和业务问题除其他外,请求出自爱尔兰共和军新的国内生产和采购需求,包括采购关键矿产品以制造电动车辆和用美国生产的材料搭建某些合格设施需求新的双级信用结构中也产生请求,对于其中许多信用,纳税人如果满足某些工资和学徒需求,有资格获得更高信用(通常是基数的五倍)。万博体育app手机登录一份通知侧重于某些信用项新的直接支付或可转移性特征,这基本上导致向纳税人支付现金,而不管他们在申请信用的年份是否负税。
IRA为国库向纳税人提供指导设定极短的最后期限结果是,如通知中所述,利害相关方有有限时间权衡今日发布通知请求在11月截止时间前提交评语,既包括年末到期的受管制入计量(如EV税抵免),也包括后年到期受管制入计量(如ITCPTC技术中和PTC)。除征求一般性意见外,每份通知都提出一些具体问题,下文摘要中强调其中一小部分问题。
/lqliququq3MD4NDLCJ1cwiOiJOdhuczovL3d5cnMvcre万博体育app手机登录Notice 2022-46 asks stakeholders to answer a number of specific questions related to:- What factors and definitions should be considered to determine the place of extraction or processing of critical minerals and the value of those minerals;
- How the guidance should define the components of a battery and determine the place of manufacture or assembly of battery components and the value of those components;
- Whether guidance is needed to clarify the definition of "foreign entity of concern" and to the extent available, whether there is any existing regulatory or guidance frameworks for tracking whether manufactures are in compliance with the foreign entity of concern rules!万博体育app手机登录and
- Whether guidance is needed on the definition of "acquired," "use," and "lease."
- Notice 2022-47 requests comments on energy security tax credits for manufacturing under § 48C and 45X.通知2022-47请利害相关方评论:
Where需要进一步澄清第45X(c)节中“合格组件”定义; 应如何确定“整合、集成或集成”短语,当合格组件整合、集成或集成为另一个组件时; 财政部和IRS在判定合格先进能源项目信用评分选择标准时应考虑什么i/li+li+li+i+i+i+i+i+i+i+i+i+i+i+2+2+2+2+2+#li+++++++++++++++++++++++++++++++++++++++++2+2+2+2+2+2++2+2+2+2++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++2+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++万博体育app手机登录通知2022-48提出了多项定义问题,包括:政府在制定指南时应考虑哪些标准和技术用于确定节能商业大楼的“用能强度”。万博体育app手机登录i>li+li+i+i+i+i+i+i+i+i+万博体育app手机登录政府在通知2022-49中寻求的部分评论包括: 政府在制定指南和确定纳税人的信用资格时应考虑哪些行业标准;投资信用设施要求投资税抵免必须满足生产税抵免的所有要求,例如要求将发电出售给无关者;政府需要定义指南和政府确定术语时应考虑哪些条件(例如技术类型),如“无关人员”、“结构”和“毛收入!万博体育app手机登录i>/li+li+li+i+i+i+i+i+i+i+i+i+i万博体育app手机登录Notice 2022-50 requests comments from taxpayers on a number of questions, including: - Whether any guidance is needed on the terms used in these monetization sections, such as "applicable credit," "excessive payments," and "applicable entity";
- What potential issues and factors that the government should consider when a partnership or an S corporation makes such an election;
- What types of structures may be entered into by applicable entities and taxpayers that have elected to be treated as applicable entities;
- Whether any documentation or registration should be required and what factors the government should consider to prevent improper payments or excessive payments and whether clarification is needed on the penalty provisions for excess payments!CHIPS/LILQLIJJJJJJJJlGLU2JJJJJUJUNJUNQ3MD4EILCJIOIJOJJOJJOJJOJJOJOJOJL3D5cnMU3B2L3BJI9PNJJCLSSLVLVLVLVLIJJJJJJJJJJJUJJJBLGLULXLXLIJJJJJJJJJUJLUGLXUNQNQQQMDUNQ3MCDEILCILCJJJICUIOIJOJOJOJL3DL3DL2L2LLLLLICI通知2022-51具体请求评论,包括:
文献或证明应用来证明遵守奖金信用要求的情况以及信息方目前维护并可能创建的信息量;国库司和IRS应一致使用48C.F.R下提供的定义万博体育app手机登录§661对内容需求以及现有规范或指导,如FederalCrap Regional和BuildingAmerica BuyCA指导,可能有益于开发指导; 定义,如“合格设施组件”、“制造产品”、“终端产品”和“总成本”需要澄清国内内容需求万博体育app手机登录和/lili>处理制造产品子组件需要澄清。 squal='wp-blest-separator has-alpha-chane-o2023年2月12日清洁氢生产税抵免 第45V节 2023年8月16日技术中立PTC和ITC(第45Y和48E段)2025年1月1日前完成
As we have written about previously, increasing the domestic supply of EVs and semiconductors, and expanding the country's clean energy capacity are among the core policy objectives of the Biden Administration.
Each of these supply chains could utilize these new MMOs, which are not currently listed on the Toxic Substances Control Act ("TSCA") Inventory. Because they are not listed, MMOs are subject to Section 5 of TSCA — a point that EPA confirmed in a separate compliance advisory.
Given this backdrop, manufacturers and importers of new MMOs must submit a Premanufacture Notice ("PMN") to EPA before manufacturing or importing these substances. Upon receipt of a PMN, EPA considers the potential hazards and exposures associated with the substance, and determines whether steps must be taken to reduce the risk to human health or the environment before the substance can enter the U.S.市场 关键是制造商和进口商按要求提交通知,包括因为TSCA禁止为商业目的使用个人知道或理应知道不符合TSCA方面要求的任何化学品,包括提交PMN或有资格免上这一要求的要求§ 2614. Manufacturers and importers do not need to submit PMN for MMOs already on the inventory (or that become added to the inventory).
EPA's announced plan to streamline this review process is good news for the EV, clean energy, and semiconductor industries. Under recent similar streamlining initiatives for biofuels, EPA has been able to complete its review for nearly all of the dozens of PMNs it has received since January 2022. This streamlining appears to be, in part, a response to concerns that EPA has acknowledged with respect to the speed of its new chemical reviews.
More details are forthcoming, and the EPA has announced that it will provide outreach and training sessions for interested stakeholders to describe the new streamlined review process.
In a series of prior blog posts, we previously highlighted the historic implications of the Inflation Reduction Act (IRA) for the U.S.'s international climate commitments, as well as for private companies navigating the energy transition. Shortly after our series published, the Senate passed the IRA on Sunday August 7th with only minor modifications to the bill's $369 billion in climate and clean energy spending. Today, the House passed the IRA without any further changes, and soon hereafter President Biden is expected to sign it into law.
However, this is only the beginning of the road!IRA四角将产生广度效果。 未来数月和数年中,我们期望看到对机构规则的强力操纵将决定IRA实施,并判定它作为能源策略的最终成功
As an initial matter, it seems Congress has not finished its work revamping the nation's climate and energy laws. As part of his agreement to support the IRA, Senator Joe Manchin (D-WV) announced that "President Biden, Leader Schumer and Speaker Pelosi have committed to advancing a suite of commonsense permitting reforms this fall that will ensure all energy infrastructure, from transmission to pipelines and export facilities, can be efficiently and responsibly built to deliver energy safely around the country and to our allies." While the exact contours of this legislation are not currently known, Senator Manchin's office recently released a legislative framework, which includes proposals to, among other things:
- tighten environmental reviews under the National Environmental Policy Act (NEPA);
- clarify the permitting and regulatory authorities of the Department of Energy and the Federal Energy Regulatory Commission;
- reform Clean Water Act provisions that allow state and local governments to impose additional requirements on federal permits!and
- create a list of strategically important energy projects, that the President can designate and periodically update, for streamlined permitting reviews.
According to Senator Manchin's office, permitting reform will receive a vote before the end of the fiscal year on September 30, 2022. Unlike the Inflation Reduction Act, which passed through arcane rules of reconciliation—and thus required only a simple majority—permitting reform will be subject to the Senate filibuster and require the support of at least 60 senators (and bipartisan agreement) to become law. At the moment, it is unclear whether broad bipartisan support exists for this measure!some Republicans have publicly signaled skepticism, and environmental activists have long opposed expedited fossil fuel permitting.However, in the past Republican Senators have expressed an interest in speeding the nation's permitting system. During this Congress, a bipartisan group of Senators introduced a law to accelerate infrastructure permitting, and all Republicans and Senator Manchin supported a resolution to disapprove of recent revisions to NEPA. Together, these actions suggest there may be some interest within the Republican caucus in implementing meaningful changes to current law, partisan divisions notwithstanding.
II.万博体育app手机登录减通货膨胀法关键赋值指南 外加,IRA本身有几部分未来数月将通过行政引导和规则制定过程予以澄清和实施守法标准支付工资、学徒和家用内容要求并计算温室气体排放法新税抵免 。
ahrfss/www.insideEnergyandense.com/2022/07/enger-support-for-电机-车-车-车-门-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电链/>这些规定并不适用于商业电车信用分量 。 具体地说,法律要求电电池组件的一定比例为“制造或组装北美 ”, 并适用百分比逐年变化 。 法律还要求电池中关键矿产品中一定比例为“提取或处理 ”, 在美国或与美国相邻的任何国家中实现“提取或处理 ” 。IRA § 13401(e).鉴于电车供应链的现状,预计许多汽车制造商难以满足这些外包需求万博体育app手机登录
However, key features of these clean vehicle credits have yet to take shape. By the end of this year, the IRA requires the Treasury Department to issue regulatory guidance to help shape and administer the battery and mineral sourcing requirements. Id. Among the questions open for interpretation are acceptable methods for calculating the "percentage of the value" for critical mineral and battery components, as well as better defining the terms "manufacture or assembly" and "extraction or processing." How Treasury addresses these points will have significant ramifications for the short- and medium- term value of the clean vehicle credits.
A much broader set of IRA tax credits seek to promote investment in, and use of, clean electricity, but their value depends on the interpretation of key labor and domestic content requirements. As currently structured, the IRA extends and modifies the Investment Tax Credit and Production Tax Credits that apply to certain renewable sources of power through the end of 2024. Id. §§ 13101, 13102. Beginning in 2025, similar projects will also be eligible for a new technology-neutral Clean Electricity Production Credit and a Clean Electricity Investment Credit, which apply to any domestically produced electricity source with a greenhouse gas emissions rate of zero. Id. §§ 13701, 13702. These credits, and others throughout the IRA, are keyed to the satisfaction of prevailing wage and apprenticeship requirements.
Specifically, if these wage and apprenticeship requirements are not satisfied the credits are worth five times less than they otherwise would be. Additionally, the IRA creates a 10% "domestic content bonus" when facilities certify that certain percentages of steel, iron, and other manufactured products used in the facility are made in America, and further increases the value of the credit for projects located in "energy communities," i.e.棕田网站或经济困境前化石燃料生产网站解释应用将极大影响政府可用支持值。 未来清洁能源项目必须注意确保适当文档并遵守这些条款Finally, many IRA tax credits are pegged to a demonstration of the life-cycle emissions of the underlying facility or fuel. For instance, the value of the clean hydrogen credit varies based on the project's "lifecycle greenhouse gas emissions rate." On the high end, a 100% credit value is awarded to projects with a lifecycle emissions rate of less than .45 kilograms (kgs) of carbon dioxide equivalent (CO2e), but on the low end, projects only receive 20% of the credit value if their emissions rate is between 4 and 2.5 kgs of CO2e. Id. § 13204. Additionally, the availability of the new credit for sustainable aviation fuels depends on a certification that the applicable fuels achieve at least a 50% life cycle greenhouse gas reduction percentage compared to petroleum-based jet fuel!燃料项目再为生命周期温室气体排放量增量百分比增量增益Id.
The full implications of the IRA are yet to be understood. The law is likely to have significant implications for our energy future, leading to sharp growth in the nation's clean energy production and a decline in national greenhouse gas emissions. Though we have laid out some initial consequences, there are undoubtedly many more interpretive questions that will arise in the coming weeks, months, and years. Additionally, by subsidizing and lowering the costs of clean electricity and other low-emissions technology, the IRA could improve the benefit-cost analysis for a variety of environmental regulations, leading to more stringent and durable rules. Further, by bolstering the domestic energy industry, the IRA could alter the political economy of climate policy, creating a broader base of support for future government investments in clean energy production or greenhouse gas curtailment. Regardless of how this future unfolds, it will surely be a dynamic time for energy and environmental law and policy.
In addition to the extension of the solar investment tax credit, the IRA renews the previously expired production tax credit for solar energy and extends the credit to include qualifying facilities that begin construction before January 1, 2025. IRA § 13101. Taxpayers would also be eligible for a bonus 10% production tax credit if certain "domestic content requirements" are met or if the project is located in an "energy community." [1] The production tax credit is calculated by multiplying the amount of kilowatt-hours product by 0.3 cents or, if certain wage and apprenticeship requirements are met, 1.5 cents. Id.
Another key provision is an extension of the energy investment tax credit to include qualifying facilities that begin construction before January 1, 2025, with tax credits for geothermal energy being extended to 2035.13102. 类似于生产税抵免,纳税人有资格额外获得10%投资税抵免,如果满足某些“家庭内容”要求或项目位于“能源社区”。投资税抵免计算法是将设施投入服务成本乘以6%或如果满足某些工资和学徒需求则乘以30%。 Id. IRA包括扩展和修改45Q固碳ARA 1344. 碳捕获45Q信用额定为每公吨合格氧化碳17美元,或如果满足某些工资和学徒需求,则定值85美元。 Id. 45Q信用额也扩展至包括直接航空捕获量,并定值每公吨合格氧化碳36美元,或如果满足某些工资和学徒需求,定值180美元。 Id. IRA还包含高级能源项目信用额扩展至100亿美元,其中40亿美元预留用于 " 能源社区 " 。除其他外,该信用扩展包括水电设施、能源存储系统、重力电机和燃料电池及其相关收费基础设施、关键矿处理、精炼或回收以及用碳捕获存储设备对能源设施进行改换。 Id. em>Id. 它还将包括一个新的净化氢生产税抵免,可达60美分/千克合格净化氢,或,如果满足某些工资和学徒需求,可达3.00美分/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒/秒
For three of these tax credits, the IRA makes a "direct pay" option available to any taxpayer claiming the clean hydrogen credit, the carbon capture credit, or the advance manufacturing production tax credit. IRA § 13801. Direct pay allows taxpayers to receive a refundable tax credit even if they don't otherwise have any tax liability to absorb the credit (e.g., the taxpayer is operating at a loss). In this way, the credit is particularly beneficial for early-stage companies. With respect to clean hydrogen and carbon capture facilities, the "direct pay" option is only available in the taxable year in which the facility is placed into service, and the four years following that. Apart from these three tax credits, the "direct pay" option is also available for a longer list of other energy-related credits, but only if the organization claiming them is a tax-exempt organization, state or local government, tribal government, or the Tennessee Valley Authority. Id.
The IRA includes a provision that allows taxpayers to transfer certain enumerated clean-energy credits to unrelated taxpayers.[2] IRA § 6418(a). Consideration paid for a transferrable credit must be paid in cash, and is not includable in the income of the transferor, nor deductible by the transferee. Id. § (b). Excessive transferability payments could result in an addition to tax of the transferee equal to the sum of the excessive payment amount plus a penalty of 20% of the excessive payment amount. Id. § (g)(2). This provision is particularly beneficial for taxpayers with low tax liability that cannot otherwise take advantage of the direct pay option for credits other than the three enumerated above, and instead have to turn to the tax equity markets to facilitate use of the credits.IRA创建或扩展多项附加税收抵免,包括:(1)清洁电生产抵免,§13701清洁电投资信用第13702条3)与低收入社区连通的太阳能和风能信用第13103节+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++有大量就业领域提取、处理、运输或存储化石燃料自2000年起关闭煤矿自2009年起煤厂停产或停产的普查段
This package presents the opportunity for Congress to finish legislating President Biden's Build Back Better agenda, completing the story detailed in our series The ABCs of the AJP. As we left the saga last summer, we noted that the effort to enact that agenda was Not Broken, Simply Unfinished. Today we are updating that series to detail the following energy related elements of the IRA:
- Accelerating efforts to decarbonize the economy and address climate change
- Ten year stability for expanded clean energy tax credits
- New funding for a National Green Bank through a Greenhouse Gas Reduction Fund
- The Creation of a Methane Emissions Reduction Program
- Strong support for the electric vehicle sector and domestic supply chain
- Empowerment of environmental justice
As President Biden noted yesterday, "Sometimes seem like nothing gets done in Washington ...但政府工作可能缓慢和沮丧,有时甚至令人厌烦。 之后拒绝放弃支付的人辛勤工作时日月数计算。历史成真。生活变换 。 至此,这些情感可能还为时过早!Arizona-Has/news/2022/07/28/dmocrats-climate-xacco-Service-Bill-reces-00048459能源和气候政策,随着法案跨过立法过程最后阶段,我们将继续更新和补充覆盖量。
As the United Nations Climate Change Conference of the Parties ("COP") in Glasgow has drawn to a close, with seemingly mixed messages and a somewhat ambiguous conclusion, it is worth reflecting on the overall trajectory of the climate issue, societal expectations, and the accomplishments that — with time — Glasgow is likely to represent. COP26 highlighted the fragility of the planet, as well as the fragility of the global consensus-based United Nations approach to protecting it. It highlighted the sweep of global climate-induced challenges and the scale of transformation needed to address them. With rising temperatures has come a rising global focus on climate and a far greater set of emerging societal expectations for meaningful responses by government and the private sector. Despite the risk that the global agreement forged in Glasgow is seen by climate activists as all talk and no action — what they referred to as "blah, blah, blah" — I believe that a number of features will endure as important accomplishments.
Representatives from 197 nations, businesses, hundreds of civil society organizations, scientists, educators, media, and climate activists — you name it — all converged on Glasgow to shine a global spotlight on the climate crisis. The Conference had some 40,000 registered participants. With just a few thousand of those involved in the negotiations themselves, the rest converged around elevating climate understanding, climate solutions, and climate action. And still tens of thousands of others converged to protest and lend their voices to the climate debate.期望因Covid-19延迟一年以及美国返回巴黎气候进程而提高但这些期望都集中在依赖实现每一项结果一致性的联合国谈判进程上 。
尽管Covid云下集合和大批与会者所构成挑战,但缔约方会议在某些方面组织得比以往更好。它不再完全是一个国际谈判,而更多地是一个通信机制,以凝聚世界对雄心气候行动需求的看法United Nations进程启动全球领导人峰会,有120位国家元首参加It featured inspiring statements from governmental and societal leaders, such as Sir David Attenborough. The Summit then flowed into the overall COP, which had a thematic organization for each day of the conference, by which it highlighted actions or the sweep and scale of climate impacts in a more coherent fashion than ever before — spanning from energy, finance, transport, cities and the built environment, science and innovation, nature, gender, youth, and adaptation to and loss and damage from climate change. And the overall gathering encapsulated a heightened global focus on climate as a defining generational issue in a way that has never happened before.
The World Rallied Around the Urgency Shown By the Evolving Climate Science
The defining element of the Glasgow considerations was the acceptance of a far sharper sense of climate science findings around the scale and urgency of emissions reductions needed to stabilize the earth's climate and prevent catastrophic consequences. Every aspect of the discussions was judged by the context the new climate science shows.
Leading up to the COP, the UN's authoritative science body, the Intergovernmental Panel on Climate Change ("IPCC"), had issued two reports — one in 2018 focused on the imperative of holding global average temperature rise to 1.5 degrees Centigrade, and one in the Summer of 2021 highlighting the "overwhelming" evidence of climate change. The reports showed that a rise in global temperature to 2 degrees would lead to catastrophic results in both the frequency and severity of climate-induced events and global changes. The reports found the science of human-induced impacts "unequivocal" and noted that global temperatures had already risen by 1.1 degrees over pre-industrial levels — demonstrating how limited the remaining carbon budget is — and that climate adverse effects were widespread, rapid, and intensifying.The report further found that urgent action is needed to cut emissions by 45% by 2030 and achieve net zero emissions by 2050 in order to maintain a sustainable trajectory.
The IPCC findings were characterized by UN Secretary General António Guterres as a "code red for humanity." They became the touchstone for judging the adequacy of country pledges and private sector net zero commitments. In addition to the scale of the emissions reductions, the need for an accelerated pace of change also became far clearer and a widely accepted expectation. The notion that we are now in a "decisive decade" to get on the right emissions trajectory was embraced by the COP process. Going into the COP, various assessments, such as from the International Energy Agency, showed that existing country emissions reduction commitments would lead to a global temperature rise of 2.8 degrees by the end of the century. Those pledges covered less than 20 per cent of the gap in emissions reductions needed to be closed by 2030 to keep a 1.5 degree path within reach. According to a number of projections, the plethora of new commitments announced at the COP would, if delivered in full, lower the rise to somewhere between 1.8 and 1.9 degrees. The UN noted that the actual nationally determined contributions ("NDCs") submitted by participating nations would result in an unsustainable global temperature rise of 2.4 degrees.
At the end of the day, the overall agreement reached by 197 countries — including new emissions reductions announcements, the move to more regular revision of national commitments, transparency requirements around that process, and the development of rules for the global carbon markets — at bottom kept alive the possibility of limiting global temperature rise to 1.5 degrees by the end of the century and essentially transformed that temperature target into the new object of the UN process.虽然1.8度和1.5度之间的差值似乎不大,但实际上它代表着减轻气候变化最大破坏性影响的实质性差值。 广泛报道的争议涉及是否逐步停用煤炭和化石燃料补贴,发展中国家是否有足够的气候资金,以及是否向受影响国家提供补偿“损耗和损害”抑制了对协议的热度。 尽管如此,正如缔约方会议主席Alok Sharma得出的结论, “我们现在可以可信地说我们已经保住1.5度。But, its pulse is weak and it will only survive if we keep our promises and translate commitments into rapid action."
Paired with these science targets was a far more prominent voice given to the moral underpinnings to the proceedings that focused on the inequity created because the most vulnerable nations to climate impacts are those who have contributed least to the emissions causing such impacts, and a palpable sense of obligation to future generations. The IPCC report drove home the concept that the COP process is not some future exercise with distant impacts, but that the delegates were poised to address an urgent crisis of the here and now.
The Paris Climate Framework Survived the Absence, and Accommodated the Return, of the United States as an Active Participant
The nations of the world remained committed to the UN Climate Framework Convention's goal of "the stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system" even in the absence of U.S.巴黎气候协议自下而上承诺框架由每个国家根据自身环境确定,体现了应对这一全球挑战的共同全球承诺,没有美国则保持稳定和适切性participation, and the reaffirmation of that framework may be one of Glasgow's greatest accomplishments.
The Paris balance had achieved a "bottom-up" system of emissions reduction commitments that flexibly accommodates the circumstances of individual countries, yet one that does not allow so much flexibility that there is no realistic hope of actually bettering the climate situation by addressing emissions mitigation, adaptation to the already locked-in effects of climate change, and assistance for climate-impacted developing nations. Paris provided a solution and a directional sense of its goals, even as it admitted that its trajectory may need to grow more stringent over time, informed by meaningful science. Glasgow refined that process with a commitment by the parties to revisit their NDCs in one year rather than five and with enhanced transparency around individual country goals and their implementation. This process preserves the possibility that the collective emissions reduction actions are calibrated to avoid the worst climatic impacts.
The durability of the Paris structure was aided, to be sure, by the promise of new technology, which could allow for countries to enhance their emission reduction commitments through cost effective wind, solar, energy efficiency, and electric vehicle technologies — technologies that were still only on the verge in Paris — making a clean energy transformation that is consistent with the Paris climate goals today seem like an attainable objective.
When the United States did return to the negotiating table, it brought with it an ambitious NDC — pledging to achieve a 50-52 percent reduction from 2005 levels in economy-wide net greenhouse gas pollution by 2030, to achieve 100 percent carbon pollution-free electricity by 2035, and net zero emissions no later than 2050. It also brought a bevy of other actions to instill more confidence in its commitment.This included leadership in assembling a global methane reduction coalition by which more than 100 countries agreed to cut emissions to tackle this highly potent short-acting greenhouse gas by 2030, a "first movers" technology coalition, as well as a series of whole-of-government financial and regulatory initiatives.
While the Biden Administration would have liked to have had its actions backed up by climate legislation, particularly power plant incentives and a range of clean energy tax credits in the reconciliation bill, it made a strong case nonetheless about the comprehensive approach it is taking to prioritizing climate outcomes across the government, whether that be in the financial sector, energy, or transportation. And the United States demonstrated ambition in its diplomacy, reaching a surprise commitment with China to work collaboratively across a range of areas to keep alive the prospects for achieving 1.5 degrees. President Biden's address to the COP was complemented by a widely praised speech by former President Obama speaking directly to youth climate activists who had taken to the streets during the COP, as well as by Congressional leadership.
The Global Focus on the Climate Crisis Puts a New Spotlight on the Importance of Business Solutions and the Business Opportunities Around Climate — Subject to Ever Greater and More Intensive Scrutiny
The first week of the COP brought a breathtaking series of collaborative public and private sector announcements to achieve carbon emissions reductions. In many ways, these commitments seem almost as significant in accomplishing a clean energy transformation as the text of the UN agreement itself.
In addition to the methane pledge, leaders from over 120 countries, representing about 90 percent of the world's forests, pledged to halt and reverse deforestation by 2030. Hundreds of financial firms, operating through the Glasgow Financial Alliance for Net Zero (GFANZ), committed over $130 trillion of private capital — representing 40 percent of global financial assets — to transforming the economy for net zero.Various combinations of development organizations and private sector capabilities identified a range of opportunities they will pursue for investments in particular developing nation economies, such as in efforts to stem coal use in South Africa. Nearly 30 national governments, joined by cities, states, major automotive manufacturers, fleet owners, and investors, signed the Glasgow Declaration on Zero-Emission Cars and Vans to end the sale of internal combustion engines by 2035 in leading markets, and by 2040 worldwide. Other transportation commitments touched on heavy duty vehicle electrification, green shipping, and enhancing the deployment of sustainable aviation fuels.
Glasgow in many ways represents a shift in focus from a governmental initiative to a recognition that the scale and pace of the energy and societal transformation and response demanded by climate change necessarily will require swift and credible action by the private sector as well. As one Chief Executive Officer put it, the concept of a "climate-advantaged" company has taken hold, where sustainability has been transformed from a "nice to have" effort being done on the side, to a vital consideration at the center of business strategy, and where such companies can benefit from a substantial value premium. As one of the UN's High Level Climate Champions put it: "Net zero has gone from extreme to mainstream."
Of course, with the proliferation of net zero pledges comes an increasing level of skepticism about the credibility of those commitments and the ability to deliver on them in the long run. In the ramp up to the COP, the IPCC focus on the more stringent and nearer term emissions reductions meant that the Science Based Targets Initiative formally revised its goals for net zero corporate commitments to align with the new 1.5 degree IPCC target and issued a new standard for evaluating company emission reduction offerings. Along these same lines, the so-called "Under 2 Coalition," representing commitments by some 60 percent of world's economy, is recasting itself as the "Net Zero Coalition."
Likewise, the UN Secretary General, at the Opening to the World Leaders Summit portion of the COP and prompted by developing nation and activist concerns over the credibility of emissions reduction commitments, characterized "a deficit of credibility and a surplus of confusion over emissions reductions and net zero targets, with different meanings and different metrics." The Secretary General therefore announced that he will "establish a Group of Experts to propose clear standards to measure and analyze net zero commitments from non-state actors." The Secretary General reiterated his intent to establish a high level group for this purpose at the conclusion of the COP as well. These will likely complement a range of emerging national financial sector and ESG transparency requirements, including the announcement of the formation of a new International Sustainability Standards Board, along with other Paris Climate Agreement provisions, particularly the new carbon market rules.
Indeed, youth activists expressed particular concern over the pace and credibility of emissions reduction commitments, stating quite simply that "we don't believe you" and urging the business community to "prove them wrong." This skepticism was heightened by the overall context of the final COP debate around the failure to honor in a timely way climate finance commitments of $100 billion per year to affected developing countries, the absence of a clear loss and damage compensation commitment, and the somewhat relaxed treatment of fossil fuels, particularly the insistence by some nations to preserve an ongoing role for coal.
Just as there will be these formal processes to help refine net zero expectations, there no doubt also will be enhanced activist group scrutiny of company pledges and climate impacts. Companies will be called to task to demonstrate what they are doing to implement their net zero commitments.This scrutiny is likely to be even more acute given the inability of the formal negotiating process to achieve a level of ambition through country NDCs that will reach the 1.5 degree target or deliver in the short term the climate finance commitments for the developing world and the credibility gap that this outcome may perpetuate. As France's former Climate Ambassador and the key architect of the Paris Climate Agreement, Laurence Tubiana, put it, "Greenwashing is the new climate denial." Climate accountability in many ways will be the new currency.
We Can Expect More Focus on Climate Commitments Going Forward
Building on the Paris accord, the agreement follows the pattern of existing domestic environmental laws in recognizing that it may not be a perfect solution, in and of itself, and that the science will continue to evolve.But those frameworks recognize that it is critical to get started on the emissions reduction process even if the target may be revised in the future. Similar to the Clean Air Act's five year review provision for fundamental health-based pollutants, Glasgow acknowledges the need to calibrate future emissions reductions based on new science more frequently and with greater transparency to assess the success of country measures in meeting the emissions targets, and that there is a fierce urgency of the now being expressed by climate advocates that should inform those evaluations. While the global community has demonstrated that it can, in essence, walk and chew gum at the same time, the question this time is whether it can do so while running.That will be tested starting next year with submissions to the next COP.
Implementation of the various COP26 pledges will be a critical piece of the equation. The test will continue to be how to turn commitments into action for this decade. As the UN Secretary General indicated, "COP27 begins today." In some ways, Glasgow represents a sharper focus on science-aligned plans — by governments and business and in the face of a new global climate consciousness — to maintain climate stability, and the focus will now shift to the implementation and refinement of those commitments. For companies, growing global climate consciousness and risks and opportunities posed by the energy transformation present a new post-Glasgow dynamic necessitating climate engagement, but requiring a credible approach in doing so.
The focus is on domestically-generated renewable electricity to create a power system based on a mix of renewables, new nuclear power stations, flexible storage, gas with CCS and hydrogen.
Specifically, the NZS undertakes to:
- Secure FID on a large-scale nuclear plant by the end of this Parliament;
- Launch a new £120 million Future Nuclear Enabling Fund.
- Create 40 GW of offshore wind by 2030.
- Create up to one of floating offshore wind by 2030.
- Deploy new measures to help smooth out future price spikes.
2) Fuel Supply & Hydrogen
The NZS re-states the ambition that the UK will deliver 5 GW of hydrogen production capacity by 2030. The UK will at the same time halve emissions from oil and gas and increase the production of biofuels.
Specifically, the NZS undertakes to:
- Provide up to £140 million to establish the Industrial Decarbonisation and Hydrogen Revenue Support (IDHRS) scheme, with a target of creating up to 250MW of green hydrogen production capacity in 2023.
- Introduce a climate compatibility checkpoint for future licensing on the UK Continental Shelf.
- Regulate the oil and gas sector in a way that minimises greenhouse gases through the revised Oil and Gas Authority Strategy.
3) Industry
The NZS commits the UK to creating four carbon capture usage and storage (CCUS) clusters by 2030. The UK will support a ‘deep decarbonisation of industry' through carbon pricing and the creation of low carbon industry clusters, which would have access to Government support under the CCS Infrastructure Fund and revenue support mechanisms.
Specifically, the NZS undertakes to:
- Accelerate the development of the Hynet and East Coast Clusters to capture 20-30 MtCO2 per year by 2030.
- Create a ‘reserve cluster' of Teesside and the Humber, Merseyside, North Wales and the North East of Scotland.
- Use the Industrial Energy Transformation Fund to future-proof industrial sectors.
- Consult on a net-zero-consistent UK Emissions Trading Scheme (ETS) cap to incentivise cost-effective abatement in industry.
4) Heat and Buildings
The NZS creates a pathway to ensuring that from 2035 all new heating appliances in homes and workplaces are low carbon and sets 2026 as the date for a decision on the role of hydrogen in heating.The Government will seek to reduce electricity costs and to rebalance energy levies (such as RO and FiTs) and obligations (such as ECO) away from electricity to gas.
Specifically, the NZS undertakes to:
- Prevent the sale of new gas boilers beyond 2035.
- A Boiler Upgrade Scheme will incentivize the swap-out of domestic gas boilers.
- Create a new Heat Pump Ready programme to provide funding for heat pump technologies with a target of 600,000 installations a year by 2028.
- Rebalance policy costs from electricity bills to gas bills.
- Fund the Social Housing Decarbonisation Scheme and Home Upgrade Grants and decarbonise public sector buildings by 75% by 2037.
- Launch a Hydrogen Village trial to inform a decision on the role of hydrogen in the heating system by 2026.
- Consider mandatory disclosure requirements for mortgage lenders on the energy performance of homes in their portfolios (UK housing stock generates 20% of carbon dioxide emissions).
5) Transport
The NZS aims to remove all road emissions and begin work to deliver zero emission international travel including through new vehicle grants and investment in electric vehicle infrastructure!and to increase use of public transport, cycling and walking.
Specifically, the NZS undertakes to:
- Introduce a zero emission vehicle mandate to give a clear signal to investors.
- End the sale of new petrol and diesel cars by 2035.
- Increase funding for zero emission vehicle grants and EV Infrastructure.
- Allocate funding to support the electrification of UK vehicles and their supply chains.
- Trial three zero-emission HGV technologies on UK roads to determine their operational benefits and infrastructure needs.
- Introduce funding to promote cycling and walking in UK towns and cities.
- Fund an increase in bus use.
- Make local transport systems net zero, including through zero-emission buses and trains and supporting infrastructure and remove all diesel-only trains by 2040.
- Extend the Clean Maritime Demonstration Competition.
- Research zero emission flights and commercialise sustainable aviation fuel.
6) Natural Resources, waste and fluorinated gases
The NZS sets out the Government's ambition to increase woodland creation in England to meet the UK's overall target of planting rates to 30,000 hectares per year by the next election.NZS旨在鼓励农民实施低碳耕作法,包括通过农林业The NZS sets out the UK's ambition to encourage a circular economy and continue to phase out the use of F-gases.
Specifically, the NZS undertakes to:
- Support low-carbon farming and agricultural innovation.
- Restore 280,000 hectares of peat in England by 2050 and treble woodland creation rates in England.
- Increase investment in net-zero-related R&D across Natural Resources, Waste & F-gases.
- Explore options for the elimination of biodegradable municipal waste to landfill from 2028.
7) Greenhouse Gas Removals
The NZS sets out the UK's ambition to deploy at least 5 MtCO2/year of engineered GGRs by 2030 through Government support to early commercial deployment of GGRs, with an ambition to move towards a market-based framework for GGRs.
Specifically, the NZS undertakes to:
- Invest in the increased deployment of GGRs.
- Explore regulatory oversight monitor, report and verify GGRs.
8) Support the transition with cross-cutting action
The NZS sets out the UK's intention to use its status as COP26 host nation to encourage other countries to get to net-zero by 2050, and set more ambitious interim emissions reduction targets.NZS鼓励私营部门提供绿色金融并设定政策意图使选择绿色选项对消费者更容易和便宜The NZS aims to support training and skills including through a focus on local solutions and undertakes to embed climate into all Governmental policy and spending decisions.
Specifically, the NZS undertakes to:
- Deliver funding to support net zero innovation projects.
- Use the UK Infrastructure Bank (UKIB) to crowd in private finance and pull through low carbon technologies and sectors to maturity and scale.
- Introduce a new Sustainability Disclosures Regime, including mandatory climate related financial disclosures and a UK green taxonomy.
- Reform the skills system to incentivize employers and learners in delivering net zero.
- Publish an annual progress update against a set of key indicators.
Reaction:
Overall, the Net Zero Strategy has been welcomed as providing a clear response to the scale of the climate change challenge and the transformation to the UK economy that decarbonisation will require over the next 30 years.
In particular, commentators welcomed the prominence given to: the ZEV mandate!资助离岸风供应链和基础设施近海传输网络协调承诺审查CfD拍卖频率重写氢雄心and the nuclear power commitments.
Commentators have welcomed the emphasis on carbon sequestration, both through natural means (peat bogs, trees) and new capture and storage technologies. For others, the requirement for the UK Government to reflect environmental issues in national policy- making, is one of the most important commitments in the document, since it places net-zero at the core of governmental decision-making processes.
On the Other Hand…
No Strategy ever satisfies everyone and some of the critical comments are worth examining briefly.
1) Weaknesses of the Policy Offering
- The NZS simply consolidates in one place the various UK Government strategies published in the last 12 months, rather than contributes significant new funding, or policy.
- There is no mention of the EU in the International Cooperation Section of the NZS and therefore no indication of how to solve the issues around carbon pricing cooperation (including any potential linkage between the UK and the EU ETS).
- The PM's 10 Point Plan of last December had already made the commitment to 5 GW of green hydrogen by 2030, so the absence of clarity on the UK's post-2030 hydrogen plans (including silence on the potential split between green and blue hydrogen) in the NZS was a missed opportunity.
2) Reliance on Unproven Technology
- The NZS's low carbon future society relies heavily on a techno-centric, market-driven vision, based on largely unproven technology.
- Greenhouse gas removal technologies (that are untested at scale) must, between now and 2050, be developed and deployed so as to remove and store more carbon than the UK currently emits from all its homes.
- Green hydrogen is allocated a major role, though the UK currently has very few operating production facilities.
- Nuclear has been given a (welcome) central role in addressing renewables' intermittency problems. But the solution chosen – small modular nuclear reactors – uses largely unproven technology.
3) Financing
- The Committee on Climate Change has previously calculated that £1.4tn of investment is required over 30 years (equivalent to 2.4% of the UK's GDP or £46 billion per year) to make the country carbon neutral.
- The scale of finance committed by the government in decarbonising the UK's housing stock is less than a quarter of the investment required by 2025.
- The NZS aims to mobilise £60bn of private finance by 2030 in addition to £26bn of public funds: equivalent to the sum the UK has invested in the renewable industry over the last decade.
- The NZS target for installing heat pumps is 600,000 per year by 2028.But the grant funding available for heat pumps will cover the installation of only 90,000 pumps.
4) Government Inconsistencies
The Treasury's Net Zero Review (NZR), released on the same day as the NZS, accepted that action to mitigate climate change was "essential to long-term UK prosperity". However, there were points where the NZR did not appear to share the NZS enthusiasm for the green revolution:
- The NZR raised concerns about the possibility of ‘industrial leakage' caused by stricter green policies in the UK as compared to other countries.
- The NZR raised concerns that the race to Net Zero was likely to result in the loss of up to £37bn a year in tax revenues from fossil fuel duty.
- The NZR noted the need for new taxes to pay for the NZS.
- The Treasury is concerned about possible job losses caused by the energy transition.
- Treasury officials are said to be considering some form of road pricing as another mechanism to raise funds.
There are other areas of apparent inconsistency:
- The apparent tension between Government commitments to grant new oil and gas licenses in the North Sea and open a new coal mine in Cumbria and the green agenda set out in the NZS.
- The NZS is silent on meat-eating, which contrasts with the approach taken in the UK's national food strategy.
Comment:
For all this criticism, the NZS is a welcome document. It is one of the first to comprehensively attempt to chart with some degree of precision how a country (the UK in this case) will reach its mid-century Net-Zero target.
If it was not clear before, the NZS reveals the almost unimaginable scale of the transformation that will be necessary to reach Net-Zero by 2050. By 2035, electricity will be fully clean!燃气锅炉和油气耗车将从英国房屋和公路上消失by 2025, the UK will be planting trees covering an area the size of Milton Keynes annually. And Net-Zero considerations will be placed at the centre of Government policy decision-making.
It is also clear that the UK is serious about addressing the climate crisis and that there is cross-Party support for accelerating the UK's Energy Transition. The government views its Presidency of COP26 as an opportunity to act as a global catalyst for progress in confronting the climate crisis and the NZS is a road-map to which the UK Government hopes other countries will look for inspiration.
There will be turbulence as the UK economy adjusts to the transformation. Turbulence which may create investment risks, but will also create major opportunities for investment- wind, nuclear, hydrogen, EV, energy efficiency, smart grids, smart storage etc.
Covington is well-placed to offer legal and public policy advice and support to companies seeking to navigate this new environment and discuss these opportunities with you to identify how we might work together.