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�鶹��� COMMENTS

March 18, 2024

�鶹��� Statement Supporting DOL’s Effort to Reform Nation’s Registered Apprenticeship Program

The Sheet Metal and Air Conditioning Contractors’ National Association (�鶹���) is supported by more than 3,500 construction firms engaged in industrial, commercial, residential, architectural and specialty sheet metal and air conditioning construction throughout the United States and North America.

�鶹��� COMMENTS

AUG 14 2023

Transferability and Direct Pay Proposed Rule

�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.

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�鶹��� COMMENTS ON PROPOSED RULE

MAR 13 2023

“Guidance for Grants and Agreements,” 88 Fed. Reg. 8374

�鶹��� Comments in support of the Office of Management and Budget’s (OMB) Proposed Rule, Guidance for Grants and Agreements, which implements the Build America, Buy America Act (BABA Act), as part of the Infrastructure Investment and Jobs Act of 2021 (IIJA).

�鶹��� fully supports the IIJA – and, in particular, the “Buy America” portions of the BABA Act – because the law ensures that federal infrastructure investments are completed with American-made “iron, steel, manufactured products, and construction materials.  The “Buy America” requirements reinvest tax dollars in America, which creates jobs, ensures goods are produced under appropriate environmental and workplace safety standards, and protects America’s Economic and national security.

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�鶹��� COMMENTS

DEC 13 2022

Employee or Independent Contractor Classification Under the Fair Labor Standards Act

�鶹��� comments in support of the DOL’s Notice of Proposed Rulemaking — Employee or Independent Contractor Classification under the Fair Labor Standards Act published Oct. 13, 2022. �鶹��� believes that the construction industry needs stronger protections against the deliberate misclassification of workers as independent contractors — also called “worker status fraud.” �鶹��� believes the DOL should develop rules specific to the construction industry to prevent unscrupulous contractors from deliberately misclassifying workers to gain an unfair advantage for law-abiding contractors that pay workers middle-class wages and benefits.

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