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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

Monday, May 04, 2020

SEIA Responsive Comments to FERC on PURPA Implementation Issues

On Monday, May 4th, SEIA filed responsive comments to the Federal Energy Regulatory Commission regarding implementation issues under the Public Utilities Regulatory Policies Act of 1978 (PURPA). In our comments, we advanced our argument that competition is a critical component of any FERC policy, and further asserted that FERC should not adopt its proposed “ten-mile rule,” as it will cause undue hardship on existing and new “Qualifying Facilities” and create uncertainty for their financial backers.

Wednesday, Dec 04, 2019

SEIA Comments to FERC on the Public Utility Regulatory Policies Act (PURPA)

SEIA submitted these formal comments to the Federal Energy Regulatory Commission (FERC) on Tuesday, December 3rd to address implementation issues under the Public Utility Regulatory Policies Act of 1978 (PURPA).

Monday, Feb 25, 2019

Comments on Whitepaper Regarding Future Value Stack Compensation, Including Avoided Distribution Costs

On December 12, 2018 the New York Department of Public Service released its Whitepaper Regarding Future Value Stack Compensation, Including Avoided Distribution Costs - which addresses the Demand Reduction Value (DRV) and Locational System Relief Value (LSRV) compensation mechanisms, as well as the Market Transition Credit (MTC)/community solar credit. SEIA joined with the Coalition for Community Solar Access, Natural Resources Defense Council, New York Solar Energy Industries Association, Pace Energy and Climate Center, and Vote Solar to submit comments on this Whitepaper.

Monday, Apr 16, 2018

SEIA Comments to USTR on Solar Safeguard Exclusion Requests

On April 16, 2018, SEIA submitted formal comments to the U.S. Trade Representative (USTR) regarding the Trump administration's consideration of product exclusions under the recent Section 201 solar safeguard tariffs.

Tuesday, Nov 07, 2017

Joint Industry Reply Comments Opposing DOE Proposal

A large collection of energy industry leaders, associations and stakeholders filed joint reply comments to the Department of Energy regarding the Federal Energy Regulatory Commission (FERC) October 2, 2017 Notice Inviting Comments. You can find the full comments in the PDF below.

Monday, Oct 23, 2017

Energy Trade Associations' Comments to FERC

A coalition of energy trade associations submitted formal comments to the Federal Energy Regulatory Commission (FERC) on October 23, 2017 regarding the Department of Energy's request of a rule for final action under section 403 of the Department of Energy Organization Act.

Friday, May 26, 2017

SEIA Comments to Lawrence Berkeley National Lab on Net Energy Metering

The Department of Energy's Lawrence Berkeley National Laboratory is assisting with the preparation of a study "to determine the costs and benefits of net-metering and distributed solar generation to the electrical grid, utilities and rate-payers". LBNL requested that SEIA respond to a series of questions to help inform the study. SEIA's responses to these questions can be found below. 

Wednesday, Nov 02, 2016

DOER Incentive Proposal

SEIA MA DOER Incentive Straw Proposal Comments FINAL 161028.pdf

Thursday, Sep 01, 2016

Public Comments - NARUC Distributed Energy Resources Compensation and Rate Design

The National Association of Regulatory Utility Commissioners (NARUC) established the Staff Subcommittee on Rate Design in November 2015 in response to the growing complexities and interest in rate design, along with the breadth of available rate design alternatives facing State Commissions. NARUC's draft DER Compensation Manual was released on July 21.

Tuesday, Feb 16, 2016

SEIA Comments to Internal Revenue Service on Section 48 Solar Tax Credit

On February 16, 2016, SEIA submitted comments to the Internal Revenue Service in response to Notice 2015-70 regarding the definition of qualified property for purposes of the energy credit under IRC Section 48. Click here to read the full comments.

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