Letters, Comments and Filings | ACP

ACP Letter for the Record, ENR Hearing May 21

Knox O'Reilly — Mon, 20 May 2024 15:37:21 +0000

In anticipation of the hearing in the US Senate Energy & Natural Resources Committee to ��ACP CEO Jason Grumet has sent the attached letter to Chairman Manchin (D-WV) and Ranking Member Barrasso (R-WY) which will be for the record.

The letter urges the Committee to redouble their efforts to develop a comprehensive permitting reform package that will address reliability challenges and help to meet our future energy needs. Further, the letter notes that while FERC Order No. 1920 is an important step to addressing regional transmission planning needs it does not address the impediments to interregional transmission permitting and planning which will be vital if we are going to meet the growing demand for power.

May 17, 2024 – Shipping Safety Fairways Along the Atlantic Coast Comments

Knox O'Reilly — Fri, 17 May 2024 15:43:55 +0000

On Friday, May 17, 2023, ACP, the Oceantic Network, New Jersey Offshore Wind Alliance, Southeastern Wind Coalition, New York Offshore Wind Alliance, and the Mid-Atlantic Renewable Energy Coalition submitted comments to the U.S. Coast Guard’s Notice of Proposed Rulemaking on Shipping Safety Fairways Along the Atlantic Coast.

In the comments, we specifically ask USCG to:

Scale back the average width of the Fairways and tailor their sizes to demonstrated needs;
Not adopt prescriptive buffers;
Adopt Fairways that do not obstruct the ability to meet the nation’s offshore wind development objectives, in specific consideration of the cumulative state offshore wind energy development goals and mandates;
Consider an illustrative alternative presented by ACP which would allow for more sea space to be considered for future potential offshore wind power development (map below)
Better assess costs incurred by the NPRM; and
Complete a statement of energy effects under EO 13211

ACP Comments on 45V

Knox O'Reilly — Tue, 27 Feb 2024 20:20:08 +0000

Section 45V: Credit for Production of Clean Hydrogen is a Proposed Rule introduced by the Internal Revenue Service and the Department of the Treasury which proposes regulations relating to the credit for production of clean hydrogen and the energy credit, respectively.

On February 26, 2024 ACP filed comments expressing concern over the proposed near-term time-matching requirement that will prevent green hydrogen production from scaling up.

A new analysis from Wood Mackenzie—submitted alongside these comments—along with many other studies, support ACP’s position that Treasury’s current time-matching proposal would severely limit the role green hydrogen will play in the economy of tomorrow.

While ACP supports much of the Proposed Rule, we encourage Treasury to consider implementing the recommendations presented herein in the final rule to ensure the green hydrogen industry can scale up to meet its potential.

ACP Basel III Comments

Will Sturgeon — Tue, 05 Dec 2023 14:02:50 +0000

Basel III, a set of international banking , was introduced to address the shortcomings and vulnerabilities in the global banking system that became apparent during the 2008 financial crisis – and it appears renewable tax equity (the main financing tool for clean energy projects) unintentionally got swept up in them.

On November 21 2023, ACP filed comments expressing concern about negative impacts the proposed rules are already having on clean energy tax equity.

These rules would quadruple the capital requirements for renewable tax equity investments after 2025. But since many current PTC and ITC deals would extend beyond that date, it has already essentially frozen the renewable tax equity market.

ACP is urging the administration to provide interim relief by providing that legacy clean energy tax equity investments entered into before the effective date of the rule (2025) be captured under the status quo (100% risk weight if the investments are less than 10% of a bank’s books) and to ultimately issue a final rule clarifying renewable energy tax equity investments are assigned a simple 100% risk weight (with the 10% threshold lifted). ACP is currently working on an advocacy plan with federal agencies and the Hill.

November 20, 2023 – Gulf of Maine Draft WEA Comments

Knox O'Reilly — Mon, 20 Nov 2023 17:42:46 +0000

ACP submitted comments Re: Draft Wind Energy Areas, request for comments.

MISO Queue Reform Protest

ACP — Sat, 04 Nov 2023 16:25:28 +0000

Pursuant to Rule 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (Commission), the ��vlog�� Association (ACP), the American Council on Renewable Energy (ACORE), the Solar Energy Industries Association (SEIA), and Clean Grid Alliance (CGA, collectively “Clean Energy Associations”) submit this limited protest of the November 3, 2023 filing by the Midcontinent Independent System Operator, Inc. (MISO) to amend its Generator Interconnection Procedures (GIP).

MISO Cap Protest

ACP — Fri, 03 Nov 2023 16:10:24 +0000

Pursuant to Rule 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (Commission), the ��vlog�� Association (ACP), the American Council on Renewable Energy (ACORE), the Solar Energy Industries Association (SEIA), and Clean Grid Alliance (CGA, collectively “Clean Energy Associations”) submit this protest of the November 3, 2023 filing (Cap Proposal) of the Midcontinent Independent System Operator, Inc. (MISO). In this docket, MISO proposes to implement a cap on the total megawatt (MW) value of Interconnection Requests that may be included in a cluster or “cycle” in MISO’s generator interconnection queue.

October 26, 2023 – ACP HAPC Comments

Knox O'Reilly — Thu, 26 Oct 2023 16:33:39 +0000

ACP submitted comments s on the National Marine Fisheries Service’s (NMFS) proposed rule to implement the New England Fishery Management Council’s (NEFMC) Framework Adjustment that would identify a Habitat Area of Particular Concern (HAPC) offshore of Southern New England.

October 25, 2023 – Letter to Chairman Manchin and Ranking Member Barrasso

Knox O'Reilly — Wed, 25 Oct 2023 17:23:53 +0000

The ��vlog�� Association (ACP) wrote a letter expressing concerns related to permitting delays, which are adversely impacting the offshore wind projects vital to our nation’s domestic energy goals. Download the letter using the form below: