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 Reply Comments in Texas PUC Project No. 39797
On February 6, 2012, SEIA filed reply comments in Texas PUC Project No. 39797, a rulemaking to implement SB 365 and SB 981, which are intended to clarify who may own renewable and natural gas distributed generation and eliminate regulatory hurdles to such ownership.
Comments to CFTC and SEC on Proposed Rule on Definition of "Swap"
SEIA comments to the Commodity Futures Trading Commission and Securities and Exchange Commission joint proposed rules regarding the further definition of "swap."
SEIA Comments in Texas PUC Project No. 39797
On January 23, 2012, SEIA filed comments in Texas PUC Project No. 39797, a rulemaking to implement SB 365 and SB 981, which are intended to clarify who may own renewable and natural gas distributed generation and eliminate regulatory hurdles to such ownership.
SEIA Comments on USFWS ANPR Regarding Incentives for Voluntary Conservation Actions
To: Mr. Jim Serfis, Chief, Office of Communications and Candidate ConservationU.S. Fish and Wildlife Service RE: Advanced Notice of Proposed Rulemaking ‐ Endangered and Threatened Wildlife and Plants; Expanding Incentives for Voluntary Conservation Actions Under the Endangered Species Act
Summary of SCE’s Proposed RAM 3 PPA Changes/RAM Program Changes
Adds sections to the RAM 3 PPA granting SCE the right to terminate a contract with a project whose bid has been selected in the RAM if the project’s reimbursable network upgrade costs exceed a specific cap. As proposed, if the reimbursable network upgrade costs in an interconnection study or agreement for a project exceed the lesser of (1) $100,000 plus estimated network upgrade costs, or (2) 125% of the estimated network upgrade costs the contract would be terminated. SCE argues this provision is necessary to shield its customers from excessive network upgrade costs and cites this as common practice in other PPAs in which projects have achieved commercial operation.
DRAFT SEIA Comments: FERC Variable Energy Resources Integration Rule
Attached for your consideration and comment are draft SEIA comments on the FERC Variable Energy Resources integration rule issued June 22, 2012.
Arizona Solar Working Group Comments On the Draft EIS for the Restoration Design Energy Project
Joint Comments from the Arizona Solar Working Group to the Arizona BLM submitted May 16, 2012.
SEIA Comments to BLM regarding Arizona's Draft EIS for the Restoration Design Energy Project
Comments submitted to BLM on May 16, 2012 regarding the Draft Environmental Impact Statement for the Restoration Design Energy Project.
Reply Comments of the California Utilities 5.4.12
Filing in the SEIA rulemaking proceeding at FERC regarding small generator interconnection reforms, on May 4, 2012.
SEIA Responds to Comments on FERC Interconnection Filing
SEIA filed an answer to comments and protests from utilities on its interconnection filing on April 11, 2012.