WASHINGTON — America’s largest domestic steel producers, the United Steelworkers, and organizations representing the industry and its workers today released a letter outlining serious concerns with the recent Domestic Content Bonus Credit Guidance (“Guidance”). The Guidance, published by the Department of the Treasury and the Internal Revenue Service (IRS), describes rules for implementing the domestic content bonus credit requirements for solar and other renewable energy electricity generation projects under the Inflation Reduction Act (IRA). As first reported by The Wall Street Journal, Treasury’s Guidance “would let firms use steel from abroad and still qualify for the 10% credit.”
The letter was signed by Zekelman Industries, Nucor Corporation, U.S. Steel, Steel Dynamics Inc., North Star BlueScope Steel, United Steelworkers, the Committee on Pipe and Tube Imports (CPTI), and the Coalition for a Prosperous America. Read the letter here.
“If the current Guidance were to be made final, it would significantly damage U.S. domestic steel producers, putting at risk 1.5 million tons of production and jeopardizing the livelihoods of millions of Americans who depend on our industry,” the letter states. “It also puts at risk the hundreds of millions of dollars that companies are investing to support domestic solar production. Additionally, if left unaddressed, it would severely undermine a key goal of the IRA: to require the structural steel components of new solar projects eligible for the domestic content bonus credit requirements to be manufactured with steel and iron that are produced entirely in the United States.”
Specifically, the letter is “requesting the immediate correction of an error in the Guidance that places the structural steel components of photovoltaic trackers, which are mounting structures, in the Manufactured Product category instead of the Steel and Iron category.” The Guidance incorrectly categorizes photovoltaic trackers as in “Manufactured Product” instead of in the “Steel/Iron Category.” According to the Department of Energy’s supply chain report on solar photovoltaics, a “significant portion of mounting structures is made of galvanized or stainless steel.”
“Failing to recognize the structural nature of tracking systems has grave implications: to include tracking systems in the manufactured products category has the effect of removing much of the steel and iron used in the mounting structure from the “steel and iron” category, where it would be required to be of U.S. origin,” the letter continues. “Categorization of tracking systems as manufactured products would permit many of the structural steel components of new solar projects in the U.S. to be imported from China and other countries desiring to target the U.S. market and U.S. jobs by dumping their excess steel capacity in the U.S., so long as the overall project met the 40 percent domestic content requirement.”
“Fixing this error in the Guidance is consistent with the clear intent of Congress that the steel and iron in solar electricity generation projects be produced entirely in the United States,” the letter affirms. “Additionally, it ensures that the Guidance does not unwittingly benefit China and other countries that have a history of using predatory, illegal trade tactics to target the U.S. steel industry.”
Read the full letter here.
About the Organizations:
The United Steelworkers is North America’s largest industrial union, with 1.2 million members and retirees strong in the United States, Canada and the Caribbean, and proudly representing workers in nearly every industry there is.
The Committee on Pipe and Tube Imports (CPTI) is the leading trade association for the U.S. steel pipe, tube and fittings industry. CPTI has an expansive footprint across the country with 39 member companies located in 32 states with 35,000 workers.
The Coalition for a Prosperous America (CPA) is the only national organization representing exclusively domestic producers across many sectors. We are a bipartisan coalition of manufacturers, farmers, ranchers, and labor organizations that make and grow things in the United States. American jobs, strength, and well being are built and sustained by growing America’s productive capacity. We value quality employment, national security, and domestic self- sufficiency over cheap consumption.
