Comments on: More details on IRA domestic content bonus revealed today by Treasury, IRS

By: Elliott Jessup

Elliott Jessup — Fri, 12 Jul 2024 19:31:47 +0000

Any non-residential project above 15KW does now unfortunately have a prevailing wage requirement.

By: Chris Klinga

Chris Klinga — Tue, 02 Jul 2024 16:13:19 +0000

Does anyone have a perspective on whether domestically sourced aluminum racking for carport structures could be used towards the domestic content threshold based on this new guidance? Should this be considered “rooftop”? Why did they specify “rooftop”? Why did they leave out aluminum racking on fixed-tilt ground mounts?

By: Nelson B

Nelson B — Sat, 25 May 2024 03:15:52 +0000

Does anyone have any insights into the “Fasteners” portion of rooftop racking?

And where do the roof attachments/Mounts stand, which are such a significant portion of the rooftop racking system?

By: Kelly Pickerel

Kelly Pickerel — Fri, 17 May 2024 11:33:20 +0000

In reply to Brian Boguess. Solar projects less than 1 MW do not have to have the prevailing wage requirements. Projects greater than 1 MW have to meet prevailing wage requirements.

By: Kelly Pickerel

Kelly Pickerel — Fri, 17 May 2024 11:31:11 +0000

In reply to Jeff Sharpe. I think in that example on Pg. 22, it's saying that the project uses American-made torque tubes only with the qualified American-made solar panels, and that the actual tracker has no other component made in the United States. Therefore, the tracker is not of domestic origin. Just a few purposely placed torque tubes are domestic.

By: Jeff Sharpe

Jeff Sharpe — Thu, 16 May 2024 21:48:27 +0000

In the example given on pg.22 of this latest Guidance, it states-
“The PV trackers are Non-U.S. Manufactured Products because some of their Manufactured Product Components are not produced in the United States.”

I haven’t been able to find in the legislation or updates where it states that any single component of a tracker not being of domestic origin automatically disqualifies the tracker for being a Manufactured Product? I expected it would be subject to the 40% content rule (plus 100% steel/iron).

Has anyone found insight on this? Thanks

By: Solarman2

Solarman2 — Thu, 16 May 2024 21:01:06 +0000

Since just yesterday, this Treasury Guidance for project components may change drastically. It has been announced that Biden has signed to raise imported items from China from Chinese built vehicles at a 100% tariff to ‘other’ Chinese supply chain items into the 301 tariff schedule to 25% to 50% more. It seems like rare earth materials will be 27%, cars 100% and some solar PV and battery units 50% more than last year. 2024 seems to be when a bulk of this is applied, but, this also seems to have “guidance” in some tariffs increasing to the 100% or 50% mark from now to about 2027. SO, this is a tell that the Treasury Department will have to revise their guidance from now to 2027 that will affect solar PV and energy storage moving forward. What does “stacked” guidance look like, first the IRA component and materials guidance is changing year over year on the amount of required materials from the U.S. or their trade partners, then these tariffs affecting the more robust supply chain from China. For instance many battery ‘modules’ for residential BESS units are running from $1,500 to $2,500. If these units were manufactured in China the new tariff of 50% will make these same modules $2,250 to $3,750 per module. This alone will ‘body slam’ solar PV plus ESS systems with a really big price increase and could destroy the momentum gained over the last 10 years. This portends a 20kWh battery in a solar PV system today costing around $10K will be $15K and the cost per kWh of storage will jump from around $1,000/kWh to around $3,750/kWh at the BESS level. This will be the time when one will see who a U.S. trading partner valued product is and who has been making products and using China for their supply chain of such components.

By: Brian Boguess

Brian Boguess — Thu, 16 May 2024 19:28:46 +0000

Kelly.

You wrote it Only applies to solar projects < 1MW (AC) or less? Really? Are you sure?