Planning to Harness the Inflation Reduction Act: A Toolkit for Regulators
Summary
The document serves as a regulatory guide, offering a structured set of inquiries to help Public Utility Commissions (PUCs) assess utility resource planning in the context of the Inflation Reduction Act (IRA). It organizes questions into five exhibits covering common IRA considerations, assumptions, forecasts, objectives/scenarios, and solution identification. Key areas of focus include the application of Investment Tax Credits (ITC) and Production Tax Credits (PTC), bonus adders for energy communities and domestic content, the integration of hydrogen and carbon capture and sequestration (CCS) technologies, and the utilization of Energy Infrastructure Reinvestment (EIR) financing. The toolkit also emphasizes the need for utilities to account for IRA-driven changes in load forecasts related to building and transportation electrification, energy efficiency, and distributed energy resources (DERs).
Key insights
- Regulators are encouraged to investigate how utilities are maximizing IRA benefits for ratepayers, specifically regarding infrastructure investment, emerging technologies like carbon capture and hydrogen, methane monitoring, and public-private partnerships.
- The toolkit provides detailed questions to verify if utilities have updated cost assumptions for clean energy tax credits through 2032 and how they have modeled the transferability of ITCs and PTCs (or 'direct pay' for non-profits and cooperatives).
- There is a specific focus on whether utilities are optimizing 'bonus adders' for Energy Communities and domestic content to reduce costs for ratepayers.
- The guide prompts regulators to scrutinize the technical and economic assumptions for hydrogen and carbon capture and sequestration (CCS), including the risk of tax credit ineligibility if capture thresholds (e.g., 75%) are not met.
- Regulators should assess if utilities have integrated IRA incentives into load forecasts for energy efficiency, demand-side management (EE/DSM), transportation electrification (EVs), and building electrification.
- The toolkit emphasizes the use of Energy Infrastructure Reinvestment (EIR) loan financing to lower the costs of new generation, transmission capacity increases, and the retirement/replacement of existing units.
- The document suggests that utilities should be evaluated on their coordination with state, city, and tribal entities to utilize IRA funding for rural and low-income communities, such as through the Greenhouse Gas Reduction Fund or the Solar for All program.
Cite the original document
- APA
- RMI (n.d.). Planning to Harness the Inflation Reduction Act: A Toolkit for Regulators. https://rmi.org/app/uploads/2024/03/Appendix_A_regulatory_collaborative_updates_and_insight_brief.pdf
- Chicago
- RMI. Planning to Harness the Inflation Reduction Act: A Toolkit for Regulators. n.d. https://rmi.org/app/uploads/2024/03/Appendix_A_regulatory_collaborative_updates_and_insight_brief.pdf.
- Wikipedia
- {{cite report |author=RMI |title=Planning to Harness the Inflation Reduction Act: A Toolkit for Regulators |url=https://rmi.org/app/uploads/2024/03/Appendix_A_regulatory_collaborative_updates_and_insight_brief.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{rmindplanning, author = {{RMI}}, title = {{Planning to Harness the Inflation Reduction Act: A Toolkit for Regulators}}, institution = {RMI}, url = {https://rmi.org/app/uploads/2024/03/Appendix_A_regulatory_collaborative_updates_and_insight_brief.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }
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