AGC will provide the agency comments by the November 4 deadline on the reporting and documentation requirements of the new labor requirements.
On October 5th the U.S. Department of the Treasury announced they were seeking public comments on labor provisions tied to clean energy tax incentives in the so-called Inflation Reduction Act. The announcement marks the first step in outlining how contractors must comply with prevailing wage and registered apprenticeship requirements for projects to be eligible for the full value of the tax incentives. For the full credit, contractors will have to begin meeting the requirements 60 days after Treasury issues final guidance. It is important to note that yesterday’s announcement does not trigger the countdown to an effective date and Treasury stated that they “will explicitly identify when it has published guidance” on the labor requirements and when contractors will have to comply.
The IRA requires contractors to pay prevailing wages to laborers working on eligible projects. Contractors would also have to have at least 15 percent of total craft labor hours on an eligible project performed by “qualified apprentices” by 2024. The tying of construction labor mandates to private development tax incentives at the federal level is unprecedented.
AGC will provide the agency comments by the November 4 deadline on the reporting and documentation requirements of the new labor requirements.