Allentown RTKL Response to Illegal Firearm Regulation Proposals

As many of our viewers are aware, I frequently submit Right to Know Law (RTKL) requests to municipalities in relation to firearms law matters. After the City of Allentown noticed its intent to propose and adopt new firearm ordinances, in violation of 18 Pa.C.S. § 6120, I filed a RTKL Request seeking information relative to the proposals, including communications related thereto.

Specifically, I requested:

Any letter, email, fax or written communication from any person in the Lehigh County District Attorney’s Office or any person from the Office for Solicitor for the City of Allentown relating to any existing or proposed ordinance or regulation relating to firearms or ammunition from January 1, 2008 through the present.  Reporter Emily Opilo recently published an article stating that letters received from District Attorney Martin and Solicitor Wild relating to a proposed ordinance regulating firearms and ammunition were discussed at a meeting on August 17, 2016 – http://www.mcall.com/news/breaking/mc-allentown-lost-gun-law-committee-20160817-story.html

Today, I received a response from the City approving in part and denying in part my request. In addition to the cover letter, they produced 52 pages of records. While many of the pages are copies of cases, pages 1-2, 45-50 and 51-52 are letters from Lehigh County District Attorney James Martin informing the City, the City Council members and Mayor Ed Pawlowski that any such regulation is unlawful and unconstitutional. While it is extremely refreshing to see a District Attorney actively involved in a firearm and ammunition preemption issue, its unfortunate that no mention was made of the criminality of violating Section 6120, as such would be a misdemeanor of the first degree, pursuant to 18 Pa.C.S. § 6119, as well as constituting official oppression. Maybe, District Attorney Martin was saving the best for last, in case they elected to move forward with an illegal and unconstitutional regulation.

I, personally, would like to thank and commend District Attorney Martin for immediately and preemptively addressing this issue. Come election time, please always remember that District Attorney Martin is a staunch defender of Article 1, Section 21 of the Pennsylvania Constitution.

Leave a comment

Filed under Firearms Law, Pennsylvania Firearms Law

BREAKING: BATFE Has Not Changed Anything Relating to Fingerprints for NFA Firearms

screen-shot-2016-09-27-at-9-53-33-am

This morning TheFirearmBlog.com posted a story which stated that ATF had revised its ruling in relation to fingerprints for NFA firearms. The article claims that ATF now requires law enforcement agencies to take fingerprints rather than anyone qualified to. To support this position the article links to ATF’s Explosives website.

As always, the information is provided by an anonymous source. Had the source or TheFirearmBlog.com looked at where the information came from, they would have clearly been able to see that this is simply not true. I’m a bit disappointed in TheFirearmBlog.com because usually they are an excellent source for correct information.

The problem is that the link goes to the Explosives portion of the website, NOT the firearms part. This is the same link that SilencerCo had previously used to support its position that Silencer Shop’s Secure Identity Documentation (SID) system would not be acceptable for the purposes of NFA firearms when it had sent an email to a major distributor earlier this year.

The link the article points to states:

How do I get my fingerprints taken?

Fingerprints must be submitted on Fingerprint Identification Cards, FD–258 that have been issued by ATF. The fingerprint cards must contain the following ORI information: WVATF0900; ATF–NATL EXPL LIC, MARTINSBURG WV. These fingerprint cards may be obtained by contacting the Federal Explosives Licensing Center at 877-283-3352 or the ATF Distribution Center at 703-870-7526 or 703-870-7528. The fingerprint cards must be completed by your local law enforcement authority.

Last Reviewed September 23, 2016

Emphasis added. Further if we look at the website the link goes to, we can clearly denote it is in the explosives area by looking at the information found on the left and above the question.

screen-shot-2016-09-27-at-9-43-04-am

ATF’s own Q&A relating to ATF 41F states that a licensee may take fingerprints provided they are properly equipped.

Q. May a Federal firearms licensee fingerprint a customer? As an FFL dealer, can we fingerprint our customers?

A. Fingerprints may be taken by anyone who is properly equipped to take them (see instructions on ATF Form 1, Form 4, Form 5, and Form 5320.23). Therefore, applicants may utilize the service of any business or government agency that is properly equipped to take fingerprints.”

As if there were any doubt, let us head to the regulations to review them.

In relation to the transfer of an NFA firearm, 27 C.F.R. § 479.85 Identification of Transferee states:

(a) If the transferee is an individual, such person shall:

….

(2) Attach to the application two properly completed FBI Forms FD-258 (Fingerprint Card). The fingerprints must be clear for accurate classification and should be taken by someone properly equipped to take them.

In relation to the making of an NFA firearm, 27 C.F.R. § 479.63 Identification of Applicant states:

(a) If the applicant is an individual, the applicant shall:

….

(2) Attach to the application two properly completed FBI Forms FD-258 (Fingerprint Card). The fingerprints must be clear for accurate classification and should be taken by someone properly equipped to take them.

(b) If the transferee is not a licensed manufacturer, importer, or dealer qualified under this part and is a partnership, company, association, trust, or corporation, such person shall:

(2) Except as provided in paragraph (c) of this section, attach to the application –

(iv) Two properly completed FBI Forms FD-258 (Fingerprint Card) for each responsible person. The fingerprints must be clear for accurate classification and should be taken by someone properly equipped to take them.

(b) If the applicant is not a licensed manufacturer, importer, or dealer qualified under this part and is a partnership, company (including a Limited Liability Company (LLC)), association, trust, or corporation, the applicant shall:

(2) Except as provided in paragraph (c) of this section, attach to the application –

(iv) Two properly completed FBI Forms FD-258 (Fingerprint Card) for each responsible person. The fingerprints must be clear for accurate classification and should be taken by someone properly equipped to take them.

Once again, we see there is no support for the proposition ATF changed anything. If you are applying to make or transfer an NFA firearm you can roll your own fingerprints, utilize Silencer Shop’s SID kiosk, have your FFL roll your fingerprints or head over to your local law enforcement to have them taken.

Did you find this blog article helpful? Be sure to share it with your friends by using the buttons below. Don’t forget to like Firearms Industry Consulting Group and Prince Law Offices, P.C. on Facebook by clicking the “like” button to the right.

Leave a comment

Filed under ATF, Firearms Law, Gun Trusts, Uncategorized

Maine Allows for Marijuana Use in Workers’ Compensation

by Karl Voigt

If marijuana law is a particularly dynamic field of practice, then marijuana law as it pertains to Worker’s Compensation law is even moreso mutable. We have all seen news coverage of individual states trying to get a handle on changing legal standards with respect to marijuana growing, sales, and use. Only now are we beginning to see coverage of new stories that involve using marijuana to treat work injuries.

Two very new cases come to us from Maine, where medical marijuana is legal. Both come from the state’s Workers’ Compensation Board Appellate Division and both serve to advance the use of marijuana to treat injured workers’ chronic pain. In Bourgoin v. Twin Rivers Paper Company, WCB App. Div. No. 16-26 (August 23, 2016) and Noll v. Lepage Bakeries, Inc., WCB App. Div. No. 16-25 (August 23, 2016), the appellate reviewers essentially determined that federal law does not prohibit requiring the workers’ compensation employer and insurer to pay for medical marijuana.

While Maine does prohibit private health insurers from paying for medical marijuana, there is no such prohibition against workers’ compensation insurers paying for that treatment. Therefore, in Maine, so long as it is found “reasonable and proper”, a workers’ compensation insurer can be compelled to pay for medical marijuana.

Pennsylvania’s law is not quite this liberal; the Pennsylvania Worker’s Compensation Act requires that workers’ compensation insurance carriers pay for work-related medical treatment. Because the US Food and Drug Administration (FDA) has never categorized medical marijuana as medical treatment, insurers in Pennsylvania likely cannot be compelled to pay for medical marijuana

Regardless, the Maine employers challenged the judges’ rulings, arguing that federal law prohibits use of marijuana as a controlled substance. Paying for medical marijuana, they insisted, would put them at risk for federal prosecution, as the federal government’s authority to prosecute drug crimes supersedes Maine’s. The appellate Board, referring to the federal Justice Department’s own public statements that interfering with state medical marijuana laws is not one of its enforcement priorities, ruled that there was virtually no such risk of such prosecution.

Both cases ultimately allowed not just for the injured worker to use medical marijuana for treatment of chronic pain, but also compelled the workers’ compensation carrier to pay for that treatment. This is just the most recent ruling in this fledgling area of law. Stay tuned here for updates.

 

Leave a comment

Filed under Marijuana Law, Workers' Compensation

New Regulations for Explosives/Pyrotechnics Industries (Part 2)

 

09/19/2016

OSHA is currently accepting comments for proposed rulemaking. The proposal is for new Process Safety Management rules for the Explosives and Pyrotechnics Industries and comments will be accepted until September 23rd!

You might ask, “What is ‘Process Safety Management’?”  That is a great question answered in Part 1 of this post click HERE to check it out!

The proposed regulations are expansive and, along with those items mentioned in Part 1, require that employers develop PHAs, SOPs, and Mechanical Integrity Plans.  So welcome to Part 2 let’s get started.

Process Hazard Analyses (PHAs)

Among the proposed regulations is the requirement that all employers perform PHAs.  OSHA defines PHAs as – “A systematic effort designed to identify and analyze hazards associated with the processing or handling of highly hazardous materials; and a method to provide information which will help workers and employers in making decisions that will improve safety.”

At its heart PHAs ares nothing more than identifying processes and identifying what hazards are present. OSHA states that PHAs “attempt[] to determine: the failure points, methods of operations, and other factors that potentially lead to accidents.”

Beyond that, OSHA’s best guidance on the subject was developed by The New Jersey Work Environment Council (WEC) under grant of OSHA. That document is 31 pages long and can be downloaded HERE.  Most businesses have (at a minimum) dozens of processes.  If you fail to identify a hazard within a process, that is a violation.  If you fail to identify a process and the hazards it contains – violation. If you fail to document everything in accordance with those 31 pages of ‘guidance’ – violation.

Seven Steps to PHA Success

Here is a hypothetical – Fictional Enterprises makes Pyrotechnics. The manufacturing is complicated involving over 75 operations.  – Each of these involves one process for purposes of a PHA. Operation 34 states – Technician will mix 3mL of Chemical X with 25cc of Explosive. Technician must then place the mixture in Centrifuge, spinning mixture for exactly 5 minutes at exactly 120 rpm. Fictional Enterprises wants to perform a PHA on Operation 34.

Step 1 – assembling the right team. OSHA stipulates that to perform a PHA your team, “should include engineers, operators, supervisors and other workers who have knowledge of the standards, codes, specifications…which apply to the process….” You assemble Mr. Engineer, Mrs. Supervisor, Ms. Technician, and Homer the technician who performs Operation 34. Your team proceeds to…

Step 2 – develop checklists of applicable regulations and safety standards. Your team examines Operation 34, finding 3 fire safety codes, 5 electrical ordinances, 9 chemical safety standards, and 122 other regulations which may be applicable to Operation 34. Developing the checklist was performed efficiently and only required 42 man hours to complete. The team moves to…

Step 3 – examine those regulations and determine the steps needed to ensure compliance with (or alternatively the non-applicability of) the standards.  All of this must be documented and included in your PHA. Your team continues their efficiency requiring 115 man hours to finish. The team now begins…

Step 4 – performing “What If” evaluations. OSHA defines this as having, “a relatively loose structure” and “only [being] as effective as the quality of questions asked and the answers given.” Even with that precision guidance your team spends 100 man hours in brainstorming the possible “what ifs.” The team now moves to…

Step 5 – Hazard and Operability Study (HazOp). OSHA defines this as “a structured, systematic review that identifies equipment that is being used in a way that it was not designed to be, and which might create hazards or operational problems.”  OSHA notes that this may require an additional “multi-skilled team.” This team must be familiar with, “piping and instrument diagrams” and have a competent understanding of “certain limitations and deviations in flow, temperatures, and pressures…” for your equipment.

Your team enlists the help of Supplier Engineer, Equipment Designer, and Senior Chemist. The team is efficient and prepared documentation for your PHA in only one week.  The Team moves to…

Step 6 – Failure Mode and Effect Analysis (FMEA). OSHA defines this process as a “systematic study of the consequences of failure (breakdown) of certain operational hardware….” This is the only guidance provided and results in your team spending an additional week attempting to figure out the FMEA.  The team moves to…

Step 7 – Fault-Tree Analysis. OSHA describes this as, “draw[ing] a picture (model) that shows what undesirable outcomes might result from a specific initiating event….” Or you make a flow chart of Operation 34, INCLUDING flow routes for if things go wrong.  So instead of just having “Homer runs centrifuge for 5 minutes” you should also include what happens if Homer gets distracted by a certain round raspberry confection and lets the centrifuge spin for 19 minutes.

The team is fortunate to have Homer with them and subsequently maps out all the possible faults in only 97 man hours.  Bringing your total time in completing the PHA for Operation 34 to over 800 man hours.

What’s wrong with this picture?

 The first thing you probably noticed was just how many man hours it takes to complete the PHA for one operation. Good thing your company only has 74 more that need to be evaluated…

The next thing that creates a problem is the FMEA.  OSHA provides very little guidance on FMEAs. This could mean they want you to use RAGAGEP but this is never stated. Given that OSHA is explicit in the other sections where they want RAGAGEP it might mean they have some specific standard in mind.  However, if it exists, it is not provided.

Worse still would be if RAGAGEP is to be used –With Aerospace you must often perform FMEAs before you are certified to conduct business.  The American Society for Quality (ASQ) has an excellent write up on their preferred methods for performing FMEAs.  This method is one I am familiar with and find to be successful.  Their write up can be found HERE.  Interestingly, you will note that the ASQ methodology for FMEAs is very similar in description to what OSHA requires for the entire PHA.

This should be of significant concern to business owners because it muddies what OSHA wants.  If they want you to refer to RAGAGEP the ASQ standard is undoubtedly one of the most thorough in the business.  However, if you follow the ASQ methodology you will essentially have a PHA within a PHA. Alternatively, if OSHA wants you to use a specific standard – they do not provide it. In short the FMEA requirement’s lack of clarity puts employers in a catch 22.

Some readers may note that the PHA steps listed above are exactly what is already available in the above referenced guidance document.  This is true and the next problem – the proposed regulations merely create an additional standard which can be cited as requiring employers to be compliant.  So what was before a violation of one PHA requirement can now be a violation of two.

My final gripe before we continue is that OSHA expressly states their reason for promulgating these new regulations are several incidents which could have been prevented had PHAs or other measures been taken.  These new requirements do not assist employers in being better able to conduct PHAs. Neither do they require employers who were previously unregulated to conform.

To the contrary, these new regulations will only serve to confuse businesses by telling them to comply with multiple but un-specified RAGAGEP standards. Confusing and redundant standards do not promote worker safety. They create a culture where employers who are unable to understand what OSHA wants merely give up. OSHA’s response continues to be “just fine them again” rather than actually finding ways to create safety standards that are clear, concise, and focused on the functional application of safe work practices.

In addition to the PHAs employers are also going to be re-required to create Standard Operating Procedures (SOPs) and create Mechanical Integrity Plans.

SOPs, in brief (I promise).

Again, OSHA is only reiterating already promulgated rules on operating procedures. The only new provision is a couple of vague examples encouraging those in the explosive and pyrotechnics industries to look to RAGAGEP for particulars of their industry.  It is also worth noting that as required by several other standards this standard would once again require employees be trained in the procedures and that employers document this training. However, the general requirements for procedures remain the same:

  1. Procedures must be written.
  2. must be clear
  3. must be available to all operators.
  4. must specify steps for
    1. normal operation.
    2. upset conditions
    3. temporary operations
    4. start-up
    5. emergency shutdown
  5. must include Basic Safety Information
  6. must be certified annually for current-ness an adequacy.
    1. Recommended that they be reviewed before each use to verify the current version is in use.

Mechanical Integrity Plans (MIPs)

OSHA’s requirements for Mechanical Integrity Plans are essentially PHAs used to evaluate equipment rather than processes.  So instead of focusing on what an operator is doing you focus on how our example Centrifuge works, in great detail.

OSHA decided to also include an explicit RAGAGEP provision. So in addition to the extreme scrutiny that must be given within the PHA styled process, they also require “employers [to] identify the subset of RAGAGEP most appropriate for their process equipment, document in the MIP which protocols are to be followed, and ensure that inspection and testing is performed accordingly.”  So stated in English, OSHA’s new standard is requiring employers to (1) figure out which standards apply to them; (2) write up how they decided this and how they are complying; and (3) ensure they are complying in the appropriate manner to the standards which the employer had to find themselves.

OSHA states, “employers are completely unfamiliar with [] RAGAGEP references, consultation with a professional [] is advised.” This can be roughly translated as OSHA saying, “Good luck complying!”

Closing Remarks (and the people rejoice)

This whole section of proposed regulation is a farce.  It is an attempt by OSHA to satisfy an executive order by promulgating a new rule that says nothing more than “do our existing rules” and “find what rules apply and then follow them.”  I cannot reiterate enough that this does not promote worker safety.  No sane person wants their employees to be endangered.  However, no employer can commit to thousands of man hours just to guess at whether they are being compliant with an OSHA Standard.

If your business is in the explosives or pyrotechnics industry I implore you to consider submitting an official comment to OSHA.  OSHA is accepting comments through THIS FRIDAY, September the 23rd.  Click HERE to submit a comment or download the proposed regulations. Comments made to these proposed rules really can affect OSHA’s actions!

Whether you are in the Explosives industry and would like to submit an official comment or you just want to make sure your business is compliant with existing OSHA requirements Prince Law Offices is happy to be of assistance.  Just call 888-313-0416 to schedule an appointment.


Jonathan Moore  served as Manager of Corrective Actions and Director of Corporate Compliance for an Aerospace Manufacturing Company. He  now serves as Prince Law Offices in-house OSHA Consultant while attending law school at the Pennsylvania State University School of Law.

 

 

Leave a comment

Filed under Business Law, Firearms Law, OSHA, Uncategorized

6th Circuit Acknowledges Second Amendment As-Applied Challenges To Mental Health Commitments

As our readers are aware, in July, I was successful in arguing in Keyes, et al. v. Lynch, et al., before the Middle District of Pennsylvania that a life long prohibition on an individual as a result of a single, isolated mental health commitment violated his Second Amendment rights, as-applied to him. Today, the 6th Circuit Court of Appeals has issued a decision in Tyler v. Hillsdale County Sheriff’s Dept., et al., acknowledging the same.

The 6th Circuit agreed with an argument that I made in Keyes that the Heller Court’s pronouncement that it was not casting doubt on the ability of the Congress to limit possession of firearms to “the mentally ill” was specific to those who are currently mentally ill, as opposed to those who might, at one time, have a bout of depression or decompression.

As the U.S. Government has now appealed Keyes to the Third Circuit, even after the Binderup/Suarez decision, we expect that the Third Circuit will rule identically to the 6th Circuit and affirm the Middle District’s decision.

If you are prohibited under federal law as a result of a mental health commitment, contact us today to discuss your options. Together, we can fight for your inalienable right to Keep and Bear Arms.

1 Comment

Filed under Constitutional Law, Firearms Law

First Step to Starting Your Business

sbdc_header_text
Prince Law Offices, P.C. attorney Jeffrey A. Franklin will be presenting at “First Step to Starting Your Business” in cooperation with the Kutztown University of Pennsylvania Small Business Development Center.  
First Step to Starting Your Business (Lancaster, PA)
Date: Nov 4, 2016 10:30am – 12:30pm
Registration Deadline: 11/4/2016 8:00 AM (EDT)
Point of Contact: Kutztown SBDC (877) 472-7232
Center: Kutztown SBDC
Fee: None
Location: 454 New Holland Ave Suite 300 Lancaster, PA 17602 , Lancaster PA 17602
 
This workshop covers a number of critical issues relevant to starting and operating a small business. Professional presenters include attorneys, insurance agents, accountants, financial specialists and zoning and codes staff. The workshop is designed for both entrepreneurs thinking about opening their first business and existing business owners looking for a “checkup”.
Desire more specific assistance regarding your business formation, agreements, intellectual property, trademarks, zoning, real estate law, cyber security, insurance, etc., contact attorney Jeffrey A. Franklin at Prince Law Offices, P.C.

Leave a comment

Filed under Business Law, Computer Law, Consumer Advocacy, Immigration Law, Landlord/Tenant, News & Events, Real Estate, Trademark and Copyright, Uncategorized

$107 Million for Solar and Renewable Projects – $65 Million Available This Year

sunshotSeptember 14, 2016 the U.S. Energy Department announced up to $107 million in new projects and planned funding in order to support America’s continued leadership in clean energy innovation through solar technology. Under the Office of Energy Efficiency and Renewable Energy’s (EERE) SunShot Initiative, the Department will fund 40 projects with a total of $42 million to improve PV performance, reliability, manufacturability and to enable greater market penetration for solar technologies. In addition to the new projects announced today, the Department intends to make up to $65 million, subject to appropriation, in additional funding available for upcoming solar research and development projects to continue driving down the cost of solar energy and accelerating widespread national deployment.

One of SunShot’s goals is to drive down the levelized cost of utility-scale solar electricity to $0.06 per kilowatt-hour without incentives by 2020. 

“Since 2008, the commitments made by the Department of Energy have contributed to solar PV’s deployment growing 30-fold and overall costs falling more than 60 percent,” said Under Secretary for Science and Energy Franklin Orr. “Continuing to invest in solar technologies will help to drive down costs even further for American consumers and ensure that the U.S. maintains global leadership in this century’s clean energy economy.”

PV Research and Development Program: $17 Million for 19 Advanced PV Technologies

SunShot selected 19 projects to receive a total of $17 million under the PV Research and Development Program to improve the performance, reliability and manufacturability of existing PV technology while seeking to advance next generation solar technology development. The new research and development projects focus on both current and emerging PV technologies aimed at improving power conversion efficiency and energy output, while also enhancing service lifetime and decreasing hardware costs. These projects could significantly lower solar PV costs from SunShot’s 2020 targets to support even more widespread deployment of PV technologies across the nation. Click here to view the list of awardees.

Two projects are from neighboring Delaware.  Congratulations U-Del:  

UNIVERSITY OF DELAWARE

Project Name: Rapid Patterning and Advanced Device Structures for Low Cost Manufacturable Crystalline Silicon IBC Cells
Location: Newark, DE
SunShot Award Amount: $1,124,491
Awardee Cost Share: $125,084
Principal Investigator: Steven Hegedus
Project Summary: This project is developing a new method for the manufacturing of interdigitated back contact (IBC) solar cells with metal contacts on the backside of the wafer, which allows for greater light harvesting on the front surface due to the absence of grid shadowing. The new process will use direct laser patterning of the metal electrodes to isolate the positive and negative contacts, as well as laser firing of dopants to create localized contacts regions between the metal and the silicon wafer. The result will be a lower cost silicon manufacturing process and device structure that will lead to an IBC cell with 25% efficiency.

UNIVERSITY OF DELAWARE

Project Name: Improved Performance and Reliability of PV Modules using the Reaction of Metal Precursors
Location: Newark, DE
SunShot Award Amount: $800,000
Awardee Cost Share: $88,889
Principal Investigator: William Shafarman
Project Summary: This project is working to improve the performance and reliability of thin-film copper indium gallium sulfide selenide (CIGSS) cells. The team is developing innovative approaches to improve the deposition and device fabrication to provide a pathway to significant reduction in LCOE. By focusing on processes and materials with low manufacturing cost and that are already used in commercial production, the project expects to directly impact the market and advance CIGSS technology toward and beyond the SunShot 2020 goal of $0.06 per kilowatt hour LCOE.

Technology to Market Program:  $25 Million for 21 Rapid Solar Innovation Projects

To accelerate the current growth trajectory of solar energy in America, the Department is also announcing nearly $25 million for 21 new projects under SunShot’s Technology to Market Program. The funding will support the development of new tools, technologies and services for the solar industry by helping to reduce hardware costs, improve business operational efficiency and broaden the investor pool for project development. Additionally, the projects will yield products that can leverage new, emerging technologies and assist in streamlining regulatory processes. Click here to view the list of awardees.  One project is from neighboring New Jersey.  

QADO ENERGY, INC.

Location: Summit, NJ
SunShot Award Amount: $700,000
Awardee Cost Share: $700,000
Project Summary: This project enables large utilities to conduct rapid forecasting and planning of distributed energy resource (DER) deployment combinations through the use of hybrid distribution/transmission models. The rapid addition of distributed generation creates concerns among utilities and regional transmission operators about impacts on transmission. The development of transmission impact functionality will drive down interconnection times of large commercial and small utility projects, which are known for their lengthy queues.

Future Funding for PV Technology, Technology to Market and Systems Integration Programs

Later this year, SunShot intends to make up to $65 million, subject to appropriation, in additional funding available under the PV Research and Development Program, Technology to Market Program and its Systems Integration Program. The PV Research and Development Program is expected to make up to $25 million available in funding to improve PV module and system design, including hardware and software solutions that facilitate the rapid installation and interconnection of PV systems. The Technology to Market Program expects up to $30 million to be made available for projects that accelerate the commercialization of products and solutions that can help to drive down the cost of solar energy. Finally, SunShot will make up to $10 million available under its Systems Integration Program for projects that are focused on improving solar irradiance and power forecasts that will accelerate data integration into energy management systems used by utilities.

Desire more specific assistance regarding CHP, renewable energy projects, energy law, or real estate law, contact attorney Jeffrey A. Franklin at Prince Law Offices, P.C.

Leave a comment

Filed under Business Law, Energy Law