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�鶹��� comments in support of the Internal Revenue Service’s (“IRS”) and the U.S. Treasury Department’s (“Treasury”) Proposed Rules, “Section 6418 Transfer of Certain Credits,” 88 Fed. Reg. 40496 (June 21, 2023) (hereafter “Transferability Proposed Rule”) and “Section 6417 Elective Payment of Applicable Credits,” 88 Fed. Reg. 40528 (June 21, 2023) (hereafter “Direct Pay Proposed Rule”). 

�鶹��� fully supports the IRA, including but not limited to the Direct Pay (Section 6417) and Transferability (Section 6418) provisions.  Before these amendments, it was not possible to monetize federal tax credits generated by renewable energy projects outside of tax equity financing structures. The Direct Pay and Transferability Provisions allow new investors to enter the market, creating a broader and more diverse market to finance projects more quickly and affordably.