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.

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.

Clean energy, including generation, storage, demand response, distributed energy resources, and efficiency represent critical resources. While renewable generation is a small portion of the current PJM resource mix, it represents the overwhelming majority of the capacity of the PJM interconnection queue.

This joint statement calls for a reconsideration of representation in the forum, including a representative from the clean energy industry on the panel so that the clean energy industry may participate in the Commission’s forum. In particular, the statement recommends accepting the prior nominations of Rahul Kalaskar of AES Clean Energy Development, LLC, Zander Bischof of MN8 Energy LLC and/or Molly Jerrard of Enel North America and inviting them to participate in the forum.

View the joint letter here.

The testimony includes a Discussion Framework designed to make the process of planning, siting, permitting, and cost allocation for high-impact power lines more efficient, fair, and conducive to increased deployment of clean energy.

This framework proposes creating National Interest Transmission Electric Corridors (NIETC) for high-impact transmission lines, speeding up the permitting process for these lines, and revising the planning and cost allocation process for interregional facilities.

Key Components of the Framework include:

• Designation of High-Impact Facilities in the National Interest: The framework proposes an applicant-driven process where transmission developers can apply to the Department of Energy (DOE) to have their high-impact transmission lines designated as NIETC. The criteria for this designation take into account economic, energy security, national defense, and environmental factors. High-impact lines must have a transmission capacity of not less than 750 megawatts, be capable of transmitting electricity at a voltage of not less than 345 kilovolts, and cross at least two states or one state and the outer continental shelf.
• Expediting Existing Siting & Permitting Authority for High-Impact Facilities in the National Interest: The framework proposes speeding up the permitting process for these high-impact lines. This involves a simultaneous review process by states and the Federal Energy Regulatory Commission (FERC) and an improved environmental review process. There’s also a focus on community engagement and potential funding mechanisms to offset the impact on affected communities.
• Fixing the Existing Interregional Planning and Cost Allocation Process: The framework calls for FERC to issue a rulemaking on interregional planning and cost allocation within 180 days and finalize the rule no later than one year. It proposes a formal procedure for the identification and joint evaluation of interregional facilities and sets out planning requirements to ensure consistency, coordination, and accounting for full electricity system benefits. It also proposes a cost allocation methodology that ensures costs are roughly commensurate with overall benefits and no costs are allocated to those who receive no benefits.

In essence, the testimony and the framework argue for a pragmatic, bipartisan approach to improving the regulatory environment to help the U.S. transition to a clean energy future.

In the letter, the organizations stated their support for the critical work being done by the U.S. Department of Energy’s (DOE) Grid Deployment Office, Loan Programs Office (LPO), and Office of Electricity (OE), writing that new funding for these offices will “drive substantial clean energy deployment, unleash billions in private investment, create thousands of new jobs, deliver low-cost energy to benefit customers, and substantially reduce emissions.”