Climate Mayors Elective Pay Feedback Letter

We thank the Department of the Treasury and the Internal Revenue Service (together, Treasury) for providing this opportunity to comment on Treasury’s Notice of Proposed Rulemaking (NOPR or proposed rule)¹ providing additional guidance on the Elective Payment of Applicable Credits established under Section 6417 of the Internal Revenue Code, as added by the Inflation Reduction Act (IRA) in 2022. The undersigned Climate Mayors, a bipartisan network of over 350 Mayors, believe the intentions of elective pay will be truly transformative for cities and appreciate Treasury considering integrating these recommendations into the final guidance.

Read the full letter and recommendations therein here.

Signed,

Mayor Satya Rhodes-Conway City of Madison, WI Climate Mayors Chair
Mayor Kate Gallego City of Phoenix, AZ Climate Mayors Vice Chair
Mayor Justin M. Bibb City of Cleveland, OH Climate Mayors Vice Chair 
Steering Committee Members Mayor
Michael P Cahill City of Beverly, MA Mayor LaToya Cantrell City of New Orleans, LA Mayor Jane Castor City of Tampa, FL Mayor Andre Dickens City of Atlanta, GA Mayor Jacob Frey City of Minneapolis, MN Mayor Craig Greenberg City of Louisville, KY Mayor James Hovland City of Edina, MN Mayor Lioneld Jordan City of Fayetteville, AR Mayor Indya Kincannon City of Knoxville, TN Mayor Lauren McLean City of Boise, ID Mayor Jeffrey J. Mims, Jr. City of Dayton, OH Mayor Ron Nirenberg City of San Antonio, TX Mayor Daniel J. Rickenmann City of Columbia, SC Mayor Regina Romero City of Tucson, AZ Mayor Lucy Vinis City of Eugene, OR Mayor Michelle Wu City of Boston, MA Climate Mayors Membership Mayor Marilyn Ezzy Ashcraft City of Alameda, CA Mayor Leirion Gaylor Baird City of Lincoln, NE Mayor Lisa Batey Milwaukie, OR Mayor Angela Birney City of Redmond, WA Mayor Daniel Biss City of Evanston, IL Mayor Rick Blangiardi City and County of Honolulu, HI Mayor Noam Bramson City of New Rochelle, NY Mayor Paul Brodeur City of Melrose, MA Mayor Barbara Buffaloe City of Columbia, MO Mayor Daniella Levine Cava Miami-Dade County, FL Mayor Paige G. Cognetti Scranton, PA Mayor Chance Cutrano Town of Fairfax, CA Mayor Gleam Davis City of Santa Monica, CA Mayor John Giles City of Mesa, AZ Mayor Bruce Harrell City of Seattle, WA Mayor Jordan Hess City of Missoula, MT Mayor Brandon Johnson Chicago, IL Mayor Cavalier Johnson City of Milwaukee, WI Mayor Emily Larson City of Duluth, MN Mayor Heidi Leub City of Tigard, OR Mayor Matt Mahan City of San Jose, CA Mayor Steve Noble City of Kingston, NY Mayor John Ortega Village of Questa, NM Mayor Shawyn Patterson-Howard City of Mount Vernon, NY Mayor Mary Lou Pauly City of Issaquah, WA President Senta Plunkett Village of Wilmette, IL Mayor Thomas M. Roach City of White Plains, NY Mayor Talisha Searcy City of Takoma Park, MD Mayor Damon Seils Town of Carrboro, NC Mayor Gamal Sherif Borough of Rutledge, PA Mayor Christopher Taylor City of Ann Arbor, MI Mayor Alan Webber City of Santa Fe, NM Mayor Miro Weinberger City of Burlington, VT

 ¹88 Fed. Reg.  40528 - Section 6417 (June 14, 2023), https://www.govinfo.gov/content/pkg/FR-2023-06-21/pdf/2023-12798.pdf