Joint SMART/SMACNA Comments on Proposed Rulemaking

SMART/SMACNA COMMENTS
OCT 30 2023

Joint Comments of SMART and SMACNA

Joint Comments of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and the Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) on the Prevailing Wage and Apprenticeship Requirements in the Inflation Reduction Act of 2022

The International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and the Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) submit these comments in response to the Department of the Treasury and the Internal Revenue Service’s (collectively referred to as “Treasury” in these comments) NPRM, Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements.

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SMART/SMACNA COMMENTS
AUG 14 2023

Transferability (Section 6418 Transfer of Certain Credits) Proposed Rule

SMART and SMACNA address transferability from two perspectives: first, as supporters of compliance with prevailing wage requirements for the protection of workers and to protect signatory contractors who comply with labor standards from underbidding by violators of these prevailing wage standards; and second, as supporters of small businesses who will benefit from tax credits and create “good”[1] union jobs in communities. 

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SMART/SMACNA JOINT LETTER TO THE WHITE HOUSE
MAR 15 2023

Upgrading Standards for Registered Apprenticeship Programs

On behalf of our thousands of union members and signatory contractors, the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) would like to reiterate our appreciation for the opportunity to share our recommendations with the White House Task Force on Worker Organizing and Empowerment. The recommendations below address upgrading the standards for registered apprenticeship programs (RAPs) in 29 C.F.R. part 29 and supplement the recommendations in our December 6, 2022 letter to the Task Force, which focused primarily on requiring proof by an applicant for sponsorship of a RAP that the proposed program has “future sustainability,” i.e., it has the present and future financial and training capacity to provide broad-based, quality training to apprentices.

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SMART/SMACNA JOINT LETTER TO THE WHITE HOUSE TASK FORCE
DEC 06 2022

Upgrading Standards for Registered Apprenticeship Programs

On behalf of our thousands of union members and signatory contractors, the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART) and Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) would like to reiterate our appreciation for the opportunity to share our recommendations with the White House Task Force on Worker Organizing and Empowerment. These new recommendations address upgrading the standards for registered apprenticeship programs (RAPs) in 29 C.F.R. part 29 and supplement the recommendations concerning apprenticeship standards in SMART’s June 25, 2021 letter (attached) to the Task Force.

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SMART/SMACNA JOINT COMMENTS
NOV 04 2022

On Requirements in the Inflation Reduction Act of 2022

We recommend that the Treasury Department require that home energy auditors hold the following certifications accredited by the ICB in order to receive credit: Total Building Energy Audit Technician, Indoor Air Quality (IAQ)/Ventilation Verification Technician, Indoor Air Quality/Ventilation Verification Contractor and Indoor Air Quality/Ventilation Verification Supervisor. These certifications hold third-party accreditation status, have strong standards, and play a critical role in auditing and assessing the energy performance of buildings. The ICB is a recognized leader in providing certifications for the heating, ventilation and air conditioning (HVAC) industry.

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SMART/SMACNA JOINT COMMENTS
NOV 04 2022

Requirements in the Inflation Reduction Act of 2022

The IRA’s massive investments to fight the climate crisis will incentivize expansion of workforce training and creation of career-sustaining, middle class jobs by providing expanded tax credits for taxpayers that satisfy prevailing wage and apprenticeship requirements.

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SMART/SMACNA JOINT COMMENTS
NOV 04 2022

In Support of the Use of Project Labor Agreements for Federal Construction Projects

Comments on specific steps that the Treasury Department, individually or in coordination with the Wage and Hour Division (WHD) and/or Office of Apprenticeship (OA), may take to promote accountability, appropriate oversight, and enforcement and to determine which functions can appropriately be delegated to the taxpayer.