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Legal Updates
Treasury and the IRS released Notice-2025-08 modifying Notice 2024-41 and Notice 2023-38 . Notice 2025-08 provides material updates and clarifications to the New Elective Safe Harbor (introduced in Notice 2024-41, and covered by our prior Client Alert found here.)
On September 25, 2024, the Governor of California signed Senate Bill 347 into law, introducing a new exemption to the California Subdivision Map Act[1] (the “Act”) specifically for EV charging and hydrogen fueling leases (the “Exemption”). Generally speaking, the Act prohibits the transfer of any portion of a legal parcel, including through leases, without a formal legal subdivision. The Exemption offers clarity and reassurance to developers of EV charging and hydrogen fueling projects by confirming that such leases are compliant with the Act, as long as the associated project is subject to discretionary review by the local government. Whether any EV charging or hydrogen fueling project is subject to discretionary review is dependent on the jurisdiction and the permits required.
Earlier this year, Clean Energy Counsel issued a Client Alert regarding the proposed Revised Addendum to Final Proposal and CAISO’s initiative to adopt processes that build on the requirements established by FERC Order 2023. As the process changes continue to move forward, CAISO held a 2024 Resource Interconnection Standards Fair on September 17, 2024, to update stakeholders that have submitted interconnection requests for the Queue Cluster 15 study process (“Cluster 15”).