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The Solar Energy Manufacturers for America (SEMA) Coalition appreciates the opportunity to comment on the Energy Information Administration’s (EIA) notice of proposed extension and revisions to the Electric Power Surveys (EPS). As detailed in the following comments, SEMA is concerned with EIA’s proposal to discontinue Form EIA-63B, Photovoltaic Module Shipments Report. This survey provides a needed official, government-collected dataset on U.S. solar module shipments by source and disposition and by state/territory. Importantly, the data collected regarding imports can be used by Customs and Border Protection (CBP) to enforce our trade and forced labor laws and by the Internal Revenue Service (IRS) to enforce the anti-China provisions in President Trump’s One Big Beautiful Bill Act (OBBBA). Its discontinuation would create a significant gap in visibility at precisely the moment when tax and trade enforcement agencies, manufacturers, grid operators, and investors need more transparency, not less, in the solar supply chain.
The U.S. solar manufacturing sector is expanding at an unprecedented pace, with tens of billions in new investments and thousands of new jobs being created. But Chinese-owned actors in the solar supply chain have a track record of violating our trade laws and harming American manufacturing workers. Transparent, reliable, government-collected data is indispensable to defending against China’s efforts to manipulate our energy markets by not paying tariffs, enforcing OBBBA restrictions, supporting domestic supply chains, and ensuring U.S. energy security. Discontinuing Form EIA-63B would undercut these national priorities. We stand ready to work with EIA to modernize the survey in a way that reduces burden while maintaining the critical transparency it provides.
