In Utility Dive's analysis of the voluntary CO2 trading model for the CPP, AEE's comments are cited. From the article:
Some clean energy advocates called for the EPA to go further to reward early renewable energy investments. Comments from Advanced Energy Economy, a trade group, called on the agency to expand eligibility for clean energy programs and push the start date for incentives forward a year, to 2019. All CEIP comments are available on the Federal Register website.