Just months after the wind power production tax credit won a last-minute renewal by Congress, opponents of the subsidy are circling the wagons to make sure it doesn't happen again.
The loose coalition of anti-PTC groups has just begun meeting to map out an advocacy and lobbying strategy. The credit will expire at the end of this year without congressional intervention.
They're seeking to attract like-minded members of Congress and the public, raise the issue's profile and take aim at wind power jobs claims from the industry.
Benjamin Cole, a spokesman for the conservative American Energy Alliance, said PTC opponents see themselves on stronger footing than last year because the credit is receiving even more attention now.
Still, they aren't taking any chances, and with wind PTC supporters beginning to consider their own strategy, PTC opponents are working on and off the Hill to head off another end-of-the-year surprise.
The first salvo comes in the form of a study to be released Thursday by the conservative National Center for Public Policy Research and AEA, which is connected to the free-market think tank Institute for Energy Research.
According to the study , figures put out by the American Wind Energy Association inflated the number of jobs that would be created by a PTC extension - as well as the projected jobs lost if the PTC had expired at the end of 2012.
Gathering new allies - particularly in grass-roots organizations that can lean on members of Congress - is a key goal for the anti-PTC forces.
That includes outreach efforts to the press and across social media, where the groups say they can connect with like-minded people unfamiliar with the PTC.
The groups involved in anti-PTC efforts in the past have included AEA, the Competitive Enterprise Institute, the American Conservative Union, the Independent Women's Forum, the R Street Institute, the Alliance for Wise Energy Decisions, Heritage Action, Freedom Action, and American Commitment.
And they are looking to add more organizations to their coalition.
They also plan to set up shop next week at the high-profile Conservative Political Action Conference.
On the Hill, PTC foes are hoping to nab a few more outspoken opponents, particularly in the Senate, where prominent new conservative members like Ted Cruz of Texas and Tim Scott of South Carolina could bring a higher national profile to the cause.
One action the groups will take soon is to circulate a letter to the Internal Revenue Service and key Hill committee members pressing for the narrowest possible interpretation of new language enacted as part of the fiscal cliff deal.
The one-year extension changed the requirements that allowed projects to qualify for the PTC. Previously, projects had to be actively generating electricity by the subsidy deadline to qualify for the credit, which lasts for ten years.
Now, projects need only to have "commenced construction" - a vague term that has yet to be defined in detail by the IRS.
Earlier this week, senators who support the PTC wrote to the IRS asking for guidance "to allow all projects begun before 2014 to take advantage of the provision."
Previous tax provisions have had relatively easy-to-meet requirements to qualify. The 1603 Treasury grant program, for example, required that renewable-energy projects have invested 5 percent of the cost of the project or to have started "physical work of a significant nature" by the deadline. More than a year after expiring, there are still projects under construction that qualify for 1603 grants.
Adopting a similar requirement for the PTC that companies make only a small investment in the project and finish it later "does not reflect what Congress intended," the anti-PTC groups will write, according to a draft letter reviewed by POLITICO.
"The only interpretation that would honor both the letter and the purpose of the law would be to determine that construction requires ‘physical work,'" the letter adds.