by Barry Devine


This article will provide what manufacturers need to know about The Qualifying Advanced Energy Project Credit (48C) program. The aim is to explain the technical evaluation process, information related to the application process, utilization of the credit, and how to submit a winning concept.

The 48C Program

The Qualifying Advanced Energy Project Credit (48C) program was initially established by the American Recovery and Reinvestment Act of 2009. The Inflation Reduction Act of 2022 expanded the program with a $10 billion investment.

The Advanced Energy Project Credit provides a tax credit for investments in advanced energy projects, as defined in 26 USC § 48C(c)(1). The Tax Credit is a percentage of investment cost and is a 6% base credit or up to 30% when prevailing wage and apprenticeship requirements are met. A mandatory aspect of the program is that 40% of the recipients must be in a Designated Energy Community. (See link below.)

48C is a competitive program requiring manufacturers to apply for credit allocation. The program is administered through the DOE, Department of Energy (DOE), Office of Manufacturing and Energy Supply Chain (MESC) and the Internal Revenue Service (IRS).

Most renewable energy tax credits are based on the production or the capital cost of a renewable energy asset, but the 48C program is as a facility credit. The definition of the term “facility” is provided for purposes of §48C (and §45X.)

The 48C Program cannot be taken with other specific programs and credits. No credit is allowed under Section 48C for any investment for which a credit is claimed under Sections 48 (energy credit), 48A (advanced coal), 48B (gasification), 48E (clean electricity), 45Q (carbon oxide sequestration) or 45V (clean hydrogen production). Taxpayers will also not be allowed to claim a credit under Section 45X for components manufactured at a facility for which the Section 48C credit was claimed.

Program Timing

In May of 2023, the DOE announced the intent to release approximately $4 billion in a first round of tax credits for projects with $1.6 billion for allocation within designated energy communities.

Unfortunately, round one concept submission is closed and the window to submit was very small. The DOE opened the 48C eXCHANGE portal for interested applicants and concept papers submissions on June 30, 2023. Concept papers were due no later than July 31, 2023. Here is your insider tip: Be Prepared for Round 2.

As of the date of this article, round one application portal is not available, and the estimated time for round two is also not yet available. It is estimated that round two will be available after March or April of 2024. Will you be ready?


Who can benefit from the 48C program? Everyone. The rules for utilization are defined in §6417 and §6418.

Basically, under §6417, a tax-exempt organization, State, Indian tribal government, etc. (applicable entity) may elect to be treated as making a federal income tax payment equal to the amount of the energy credit.

Under §6418, a taxpayer (that is not an applicable entity) may elect to transfer all or a portion of the credit to an unrelated party.

To restate this another way, tax-exempt entities have a refundable tax credit option for cash payment and for-profit entities can either use the credit to offset tax liability, or and sell the credit to an unrelated party for cash.

How to Qualify

So, interested in the program yet? There are three distinct categories for qualification as outlined by the program. If you are a manufacturer, you must be planning to expand or re-equip an industrial or a manufacturing facility in one of these three categories.

1. Clean Energy Manufacturing and Recycling: For a company that re-equips, expands, or establishes an industrial or a manufacturing facility to produce or recycle specified advanced energy properties including:

  • Property designed for use in the production of energy from the sun, water, wind, geothermal deposits, or other renewable resources;
  • Fuel cells, microturbines, or energy storage systems and components;
  • Electric grid modernization equipment or components;
  • Property designed to capture, remove, use, or sequester carbon oxide emissions;
  • Equipment designed to refine, electrolyze, or blend any fuel, chemical, or product that is renewable, or low-carbon and low-emission;
  • Property designed to produce energy conservation technologies;
  • Electric or fuel cell vehicles, as well as technologies, components, or materials for such vehicles and associated charging or refueling infrastructure;
  • hybrid vehicles with a GVW rating of not less than 14,000 pounds as well as technologies, components, or materials for such vehicles; or
  • Other advanced energy properties designed to reduce greenhouse gas emissions as may be determined by the Secretary.

2. Greenhouse Gas Emission Reduction: For a company re-equips an industrial or manufacturing facility with equipment designed to reduce greenhouse gas emissions by at least 20% through the installation of:

  • Low or zero-carbon process heat systems;
  • Carbon capture, transport, utilization and storage systems;
  • Energy efficiency and reduction in waste from industrial process; or
  • Any other industrial technology designed to reduce greenhouse gas emissions, as determined by the Secretary
  • Critical Materials (Refining, Processing, and Recycling): For a company that re-equips, expands or establishes an industrial facility to process, refine or recycle critical materials.
  • “Critical Materials” defined by the Energy Act of 2020 section 7002(a)
  • The list of materials is extensive and limited to “non-fuel mineral, element, substance, or material”
  • Contains materials like Lithium, Cobalt, Nickel, Uranium, etc. (full list available)


The Application Process

The 48C Program is a competitive application process in which the DOE reviews concept papers and provides recommendations to the IRS for awarding. For each project that a Taxpayer pursues, they must complete a two-stage technical evaluation process:

  • Stage 1: Concept Paper for DOE Consideration
  • Stage 2: A §48C(e) application

All applicants must register an account in the 48C eXCHANGE portal at

All applicants must submit the first stage concept paper to be eligible to submit a formal application for the second stage. Thus, your concept is critical.

DOE will evaluate concept paper submissions using the category-specific technical review criteria, including whether the project addresses specific energy supply chain and manufacturing priority areas and overarching program policy factors.

DOE will evaluate eligible applications against technical review criteria reflecting four major priorities:

  • Criterion 1: Commercial Viability
  • Criterion 2: Greenhouse Gas Emissions Impacts
  • Criterion 3: Strengthening U.S. Supply Chains and Domestic Manufacturing for a Net-Zero Economy
  • Criterion 4: Workforce and Community Engagement

The DOE will only provide a recommendation and ranking for a project if it determines that the application meets all requirements and supports program policy factors. The DOE recommendation for the concept paper stage will include all projects encouraged to submit a § 48C(e) application. Projects not included in the DOE recommendation will receive a letter of discouragement.


A Winning Concept

As stated above, your concept is critical to the process; however, just utilizing the criteria above may not be adequate to receive consideration. There is more to the evaluation process. What’s missing?

Your Story! Show the ‘why’ behind your project. Show that you understand both the technology and energy components of your project including outputs, performance, portfolio diversity, etc. Moreover, show that you are making a positive impact in the community. Can you articulate the workforce continuity aspects of your project? Can you measure the workforce and community engagement and additional benefits?

This is critical to be awarded but remember; Less is MORE! These are the maximum submissions for concept and application.

Files required for concept paper submission:

  • Concept Paper (max 4 pages)
  • Concept Paper Workforce and Community Engagement Plan (max 1 page)

Files required for full application submission:

  • Section 48C(e) Application (max 30 pages)
  • Section 48C(e) Application Workforce and Community Engagement Plan (max 5 pages)


Your concept paper cannot be more than four pages, and the community engagement plan is limited to one. Given these parameters, partnering with a specialist who knows how to tell your story and what aspects of a workforce community plan to highlight is highly recommended. Especially for multi-national corporations or foreign-owned U.S. entities, the localized knowledge of these additional aspects could be the critical component for a winning concept.

Now that you know the 48C program, the qualification categories, and some additional program policy factors, such as energy communities and workforce relations, it is time to prepare your concept paper. But remember, round two is coming up quickly, so be ready, and good luck!


Additional Guidance Notice 2023-44. · Initial Guidance Notice 2023-18. · Energy Community, which lists the Section 48C(e) Energy Communities Census Tracts that taxpayers may rely on to substantiate a tax return position.


Learn more about Tri-Merit’s offerings regarding renewable energy tax credits.