SEIA Resources
Formal Comments
SEIA produces a variety of research and other supporting resources for the solar industry, ranging from full reports to short factsheets. Below is a list of our formal submitted comments, organized by date. For a full library of research and resources, click here.
SEIA Comments on PJM Capacity Resource Plan
SEIA comments on PJM's Capacity Resource Plan proposal in FERC Docket ER15-623-000.
Comments to the EPA on the Proposed Clean Power Plan Regulating Existing Power Plants Under Section 111(d) of the Clean Air Act
The EPA’s Clean Power Plan recognizes and bolsters the current opportunity to reduce carbon emissions by transitioning United States electric grid from a fossil fuel dominant fuel mix to a balanced energy portfolio that includes higher penetration of renewable energy resources. The Clean Power Plan will require affected electric generating units (affected EGUs) within each state to reduce their carbon emissions, thus presenting the opportunity for utilities and states to shift towards sources that generate energy with little or no carbon emissions such as solar energy.
Proposed REIT Regulation Language
SEIA filed regulatory language with the IRS and Treasury to update the definition of real property to include solar energy property.
SEIA Comments in Response to IRS REIT NOPR
On August 12, 2014, SEIA filed comments in response to the IRS Notice of Proposed Rulemaking regarding the definition of real property for the purposes of real estate investment trusts (REITs). SEIA praised the IRS for taking steps to make REITs accessible to the solar industry but also suggested ways to improve REIT regulations.FINAL SEIA REIT NOPR Comments - 8 11 14.pdf
SEIA Comments in PUCT Project 40000
On June 17, 2014, SEIA filed comments in PUCT Project 40000 highlighting solar’s tremendous growth, price declines and economic investment in Texas and nationwide. SEIA also provided suggestions for how ERCOT could better account for solar on its system and include solar in its resource planning.
Solar SDG&E Green Tariff Joint Recommendation
Comments submitted to the California PUC by SEIA, Vote Solar, San Diego Gas & Electric re: SDG&E's Green Tariff.
SEIA Comments on ERCOT 2014 LTSA
This winter, SEIA participated in a series of workshops held by ERCOT to discuss long-term transmission planning and ERCOT’s overall system assessment. On May 9, SEIA filed comments suggesting that ERCOT study a few solar-related scenarios when assessing its system and its direction over the next 10 to 20 years.
SEIA's Response to DOE on RFI on NEM Benefits and Costs
The Solar Energy Industries Association (SEIA) appreciates the opportunity to submit comments in response to the Department of Energy Solar Energy Technologies Office (DOE SETO) Request For Information on “Net Benefits and Costs of Distributed Solar Energy and Innovative Solar Deployment Models”. SEIA is a very active participant on these issues in legislative and regulatory arenas in states across the country as well as in a variety of national forums.
SEIA Comments Re Chairman Baucus' Energy and Cost Recovery Discussion Drafts
SEIA filed comments in response to Senate Finance Committee Chairman Baucus’ Energy and Cost Recovery Staff Discussion Drafts. The comments highlight SEIA’s concerns with the proposals’ replacement of MACRS, reduction of the ITC to 20%, expiration of Section 25D residential credit and the exclusion of Solar Heating and Cooling from the ITC. FINAL SEIA Comments Re Tax Reform Discussion Drafts - 1 17 14.pdf
SEIA reply comments on SGIP proposed rule
SEIA filed additional comments in the FERC rulemaking which proposes changes to the Small Generator Interconnection Procedures (SGIP), docket RM13-2-000.SEIA's comments again express support for the proposed rule, as written, and object to proposals made by other parties to increase the cost and amount of time it takes to process interconnection requests.