Advocacy lies at the core of the Advanced Energy Buyers Group's work. Through effective engagement with policymakers, elected officials, and regulators, we seek to achieve our mission of an energy system that supports and enables customer pursuit of advanced energy.

The Advanced Energy Buyers Group is focused on several priority issues at the federal and state level, including legislative, regulatory, and utility engagement. The following is a summary of key comment filings, letters, and other written engagements since our launch in September 2017. For more detail and information about in-person engagements, please contact AEBuyersGroup@aee.net.

Federal and Wholesale markets

Filings at the Federal Energy Regulatory Commission (FERC), Department of Energy (DOE), Environmental Protection Agency (EPA), Office of the U.S. Trade Representative (USTR), and the U.S. International Trade Commission (U.S. ITC).

  • FERC Transmission Incentives:
    • July 1, 2020 comments in FERC Docket No. RM20-10 outlining principles for transmission planning and policy, and offering suggestions to improve outcomes under the Commission's Notice of Proposed Rulemaking.
    • June 26, 2019 comments in FERC Docket No. PL19-3-000 recommending transmission policies that prioritize customer cost savings and projects that will bring benefits to customers, including investments needed to unlock access to cost-effective renewable energy resources and projects and efforts that will improve interregional coordination and encourage expansion of regional markets.
  • PJM’s Capacity Market Proposals:
    • May 15, 2020 comments to FERC in Docket No. EL16-49-000, EL18-178-000, et al. in response to PJM's March 18th compliance filing responding to FERC's December 2019 Order, supporting PJM's proposal to allow voluntary projects to pursue the competitive exemption, and asking for similar treatment for the voluntary portion of projects also selling into compliance markets.
    • January 21, 2020 comments to FERC in Docket No. EL16-49-000, EL18-178-000, et al. in response to the Commission's December 19, 2019 Order expanding PJM's Minimum Offer Price Rule, requesting clarification, or, in the alternative, rehearing, to ensure that voluntary renewable energy purchases will not be inappropriately treated as state subsidies subject to mitigation.
    • October 2, 2018 comments and November 7, 2018 reply comments to FERC in Dockets No. EL16-49-000, EL18-178-000, et al. regarding the Commission's proposed changes to PJM's capacity market, urging against treatment of renewable energy purchases by voluntary buyers as "out-of-market" revenue, and expressing concern at the unknown and potentially harmful impacts of the proposal.
    • May 7, 2018 comments to FERC in Docket No. ER18-1314-000 regarding PJM Interconnection’s Capacity Market Proposals, arguing that PJM’s proposed tariff revisions would increase costs to consumers without providing any demonstrated benefits with regard to resource adequacy or market efficiency, and urging further exploration and analysis.
  • House Select Committee on the Climate Crisis RFI: November 22, 2019 comments in response to a Request for Information from the House Select Committee on the Climate Crisis, outlining support for efforts to accelerate the transition to a clean energy economy and providing guidance on policy pathways. Particular emphasis on ensuring that any future policies complement and support large customer actions to reduce emissions.
  • Priorities for the 116th Congress: Letter submitted to Congressional leadership January 23, 2019, asking that Congress consider the perspective of large corporate buyers when pursuing energy policy, and outlining key priorities to ensure that customers are able to pursue a range of advanced energy options, to avoid policies that raise costs for consumers and disadvantage clean energy technologies, and to support cost-effective and technology-neutral emission reduction policies.
  • EPA's Affordable Clean Energy Proposal: October 31, 2018 comments in Docket No. EPA-HQ-OAR-2017-0355 regarding the Agency's Affordable Clean Energy proposal, arguing against a command-and-control regulatory approach and encouraging use of technology-neutral, market-based, and competitive solutions to achieve regulatory goals affordably and with minimal disruptions to electricity markets.
  • FERC Distributed Energy Resources Docket: June 26, 2018 comments to FERC in Dockets No. RM18-9-000 and AD18-10-000 regarding DER participation in wholesale markets, urging the Commission to issue a final order establishing clear and equitable opportunities for aggregated DERs to participate in wholesale markets and providing specific recommendations for such an order.
  • FERC Grid Resilience Proceeding: May 9, 2018 comments to FERC in Docket No. AD18-7-000 regarding grid resilience in Regional Transmission Organizations and Independent System Operators, arguing that there is no immediate threat to grid resilience requiring emergency action and urging the Commission to ensure that any steps taken to enhance system reliance be based on clear metrics and rely on market-based and technology-neutral solutions that reward innovation and foster voluntary customer actions to boost system resilience.
  • First Energy Solutions 202(c) Emergency Relief Request: April 26, 2018 comments to DOE regarding a 202(c) request by FirstEnergy Solutions, strongly urging DOE against use of its § 202(c) authority in this case because doing so would be inconsistent with the statute, would be an unlawful departure from its prior use, and would undermine competitive wholesale markets while raising electricity prices at the cost of electricity consumers such as members of the Advanced Energy Buyers Group.
  • Renewable Energy Tax Credits: December 8, 2017 letter to U.S. Senators and Representatives urging fixes to H.R. 1 to avoid harmful changes to renewable energy tax credits.
  • DOE’s Grid Resilience NOPR: FERC Docket No. RM18-1-000 regarding the Department of Energy’s Notice of Proposed Rulemaking (NOPR) on “Grid Reliability and Resiliency Pricing”
  • USTR Solar Tariff Consideration: November 20, 2017 comments to USTR in Docket No. USTR-2017-0020 regarding potential tariffs on CSPV cells and modules (the Section 201 Solar Trade Case), urging against undue tariffs and explaining that, as downstream solar customers, members of the AEBG would be directly harmed by increased operating costs and by negative impacts on the solar industry if undue tariffs were imposed, and explaining how how even relatively modest tariffs would harm the competitiveness of future projects.
  • U.S. ITC Solar Tariff Proceeding: US ITC Case No. 201-075, regarding potential tariffs on crystalline silicon photovoltaic cells and modules
    • September 27, 2017 pre-hearing brief, recommending a balanced approach that would avoid unduly increasing the cost of solar energy for downstream customers.
    • October 10, 2017 post-hearing brief, reiterating call for a balanced approach and emphasizing that voluntary purchasers of solar energy are price sensitive, and that undue cost increases will impact the solar market accordingly.


Key filings at public utility commissions and state legislatures in priority states.

  • Arizona:
    • Salt River Project Pricing Proceeding: March 8, 2019 comments to the Salt River Project (SRP) Board applauding the utility's development of the Sustainable Energy Offering program, and encouraging additional renewable energy purchasing options for commercial and industrial customers.
    • Retail Choice & Competition: December 14, 2018 comments to the Arizona Corporation Commission (ACC) supporting the Commission's efforts to explore expansion of retail choice in Arizona, and explaining how buyers use retail choice as one tool to meet their renewable energy goals.
    • Energy Modernization: April 23, 2018 letter to the ACC on behalf of the Arizona Advanced Energy Collaborative, asking that customer clean energy options be considered as part of the goal of “supporting customer choice whenever possible,” and urging the Commission to prioritize deployment of cost-competitive advanced energy options.
    • Integrated Resource Planning: January 30, 2018 letter to the ACC on behalf of the Arizona Advanced Energy Customer Collaborative making the Commission aware of customer renewable energy demand in Arizona as it considers utility resource plans.
  • California:
    • Direct access:
      • October 16, 2020 comments and October 26, 2020 reply comments, submitted jointly with AEE, offering feedback and recommendations in response to the California Public Utilities Commission (CPUC) draft report to the Legislature regarding direct access reopening.
      • January 21, 2020 comments, submitted jointly with AEE, in response to initial workshop on Phase II of SB 237 implementation; joint proposal for direct access reopening schedule.
      • September 30, 2019 comments, submitted jointly with AEE, in response to a request for comment on the scope for Phase II of SB 237 implementation, R1903009.
      • April 5, 2019 comments and April 10, 2019 reply comments, submitted jointly with AEE, in response to Order Instituting Rulemaking to implement SB 237 (direct access expansion), R1903009.
      • February 4, 2019 guidance to the California Public Utilities Commission (CPUC) regarding implementation of SB 237.
      • July 19, 2018 joint letter with Advanced Energy Economy to the Legislature in support of SB 237, which would expand direct access to all commercial and industrial customers in the state, and September 7, 2018 letter to Gov. Brown in support of his signature on the bill.
    • Customer choice:
      • November 13, 2018 comments to the California Public Utilities Commission (CPUC) in response to the "Draft Gap Analysis / Action Plan," encouraging the Commission to take specific steps to ensure that expansion of customer choice is not inhibited by concerns regarding customer protection, resource adequacy, or duty to serve.
      • June 11, 2018 comments to the CPUC on the "Draft Customer Choice Green Book," encouraging a thoughtful, inclusive, and transparent planning process moving forward and explaining how increased customer choice would help deliver on California’s goals of decarbonization, affordability, and reliability.
  • Florida
    • November 2, 2020 comments in Docket No. 20200176-EI suggesting improvements to Duke Energy Florida's Clean Energy Connection program, and recommending Commission approval of the program.
    • January 13, 2020 comments in Docket 20190061-El suggesting improvements to Florida Power & Light's proposed SolarTogether program, and recommending Commission approval of the program.
    • March 12, 2019 comments in Docket 20180204EI encouraging Tampa Electric Co. to build off its Shared Solar Rider by developing a program or programs that would meet the needs of large C&I customers.
  • Colorado:
    • November 15, 2019 comments in Docket 19M-0495E outlining support for participation by Colorado electric service providers in broader organized wholesale market in the West, particularly a full RTO/ISO. 
  • Michigan:
    • Consumers Energy Voluntary Green Pricing Program (U-18351, U-20649)
      • May 28, 2020 direct testimony in response to Consumers Energy's revised Large Customer - Renewable Energy Pilot (LC-REP) program, supporting the program's expansion and recommending further improvements.
      • April 25, 2018 direct testimony arguing for key improvements to the LC-REP program included in Consumers Energy's application, in particular requesting expansion of the program to allow future customers to participate.
      • June 29, 2018 initial brief and July 20, 2018 final reply brief summarizing and reiterating concerns with the initial filing.
    • DTE Energy Voluntary Green Pricing Program (U-18352)
      • April 23, 2018 direct testimony arguing for key improvements to DTE’s existing MIGreenPower program and asking the Commission to require introduction of another program tailored specifically to the needs of C&I customers.
      • June 29, 2018 initial brief and July 20 final reply brief summarizing and reiterating concerns with DTE’s initial filing, and asking the Commission to require an additional C&I program within six months.
  • Virginia:
    • Dominion Rider Total Renewable Generation (Docket No. PUR-2019-00094)
      • May 11, 2020 comments in response to the Hearing Examiner's report, summarizing arguments against approval of Rider TRG and supporting a proposed sunset provision if the Commission ultimately approves the program.
      • October 17, 2019 direct testimony explaining why the program falls short of meeting the clearly articulated needs and preferences of large C&I customers, and why it is neither just and reasonable nor in the public interest.
      • December 20, 2019 post-hearing brief reiterating why the Commission should not find the program to be just and reasonable and in the public interest.
    • Dominion New Market Based Rate Schedule Proposal: March 26, 2019 comments, jointly submitted with Virginia AEE, supporting Dominion's proposal to expand eligibility for its Existing MBR Rate Schedule and revise the program to better meet customer needs, and encouraging additional revisions to make the program available to additional customers.
    • Dominion Grid Transformation Proposal: November 6, 2018 comments delineating specific goals that the Buyers Group would like to achieve through grid modernization, and advocating a thorough analysis of costs and benefits, including clear performance metrics to ensure desired outcomes.
    • 2018 Virginia Energy Plan: August 24, 2018 comments advocating for an energy system in Virginia that includes flexible and cost-effective options for customers to purchase advanced energy, and that ensures that all utility investments are focused on delivering reliable, clean, and affordable electricity while delivering positive quantifiable benefits to customers.
    • Dominion Schedule Renewable Generation (Docket No. PUR-2017-00163): April 10, 2018 comments pointing out positive aspects of the program, and recommending several improvements.
    • Dominion Schedule Continuous Renewable Generation (Docket No. PUR-2017-00060)
      • August 23, 2017 direct testimony expressing concern at the anticipated high cost of the offering, and at the fact that approval would preclude alternative options otherwise available to customers.
      • January 16, 2018 post-hearing brief reiterating concerns with the program.
      • March 23, 2018 reply to Hearing Examiner’s brief, agreeing with the finding that Dominion’s proposal would be costly, and that the impact on alternative options available to customers warrants additional scrutiny.