division of energy resources




Subject: RFI – Impact of H.R. 1 on Clean Energy Projects





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To assist in meeting Minnesota’s Clean Electricity Standard for electric utilities to provide 100% carbon-free electricity by 2040, the Minnesota Climate Innovation Finance Authority (MnCIFA) [ [link removed] ] and the Minnesota Department of Commerce, Division of Energy Resources [ [link removed] ] have issued a Request for Information (RFI) from developers, contractors, project owners, equipment suppliers, manufacturers and other interested parties to understand the impact of the new requirements in federal law (H.R. 1) for certain clean energy projects and facilities to secure federal investment tax credits. Comments will be used to help MnCIFA and Commerce to review policies and procedures in light of changing federal requirements.

MnCIFA and Commerce specifically seek information related to:


* The perceived challenges to project owners and developers of wind and solar projects to meet new Foreign Entity of Concern (FEOC) material assistance requirements which will apply to projects that begin construction on January 1, 2026, or later.
* The potential value to project owners to begin construction by December 31, 2025, to secure a statutory federal waiver with respect to FEOC Material Assistance requirements,
* Actions that state and local actors may take to assist project developers in beginning construction by December 31, 2025, to secure the FEOC Material Assistance waiver, and
* Actions that state and local actors may take to assist project developers in meeting FEOC Material Assistance requirements for projects that begin construction January 1, 2026, or after.

*All RFI responses must be submitted no later than* *1 p.m. Central Time, September 12, 2025*. Responses can be provided via an online form [ [link removed] ]. Questions can be emailed to [email protected] <[email protected]?subject=MnCIFA%20RFI%20Questions>. Full details are available in the full RFI, which is posted to Commerce’s Request for Proposals (RFP) webpage and accessible via this link [ [link removed] ].








*Minnesota Department of Commerce | Energy Division
*85 7th Place East, Suite 280 | St. Paul, MN 55101*
*Email: [email protected]
Local: 651-539-1886 | Greater MN: 1-800-657-3710

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