The IRA 2 Year Anniversary: By the Numbers

August -> September , 2024

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Welcome back from the long weekend – I hope everyone had a great summer!

August’s clean tech news was dominated by the two year anniversary of the Inflation Reduction Act. We’re celebrating with a special IRA Deep Dive issue with tons of fun charts and data you never knew you needed about the IRA. 

The Treasury Department marked the occasion by releasing a trove of info on the law’s uptake and a clearing house of IRA guidance and regulations on the law’s 26 new or modified clean energy tax credits. I started DCCleanTech because I wanted all the USG cleantech funding and policy information in one place, so I’m a huge fan of this Treasury data dump and it immediately earned a spot on the bookmark bar. 

A tireless effort

The Administration has done a truly impressive amount of work to translate the IRA’s tax incentives into rules and regulations that investors can bank on. Sure, there are some high-profile credits awaiting final rules, but the Administration has put in a herculean effort over the past two years to implement the law. 

  • 📹DOE alone has produced more than 10 hours of webinars and videos to help investors and technology developers understand how to take advantage of various tax incentives. 

  • ✍️Stakeholders have contributed more than 63,000 comments (nearly half of these for the 45V clean hydrogen credit).  

  • 📚Treasury has issued more than 3,000 pages of guidance, rules, FAQs, Revenue Procedures, Requests for Comments, and temporary, proposed, and final rules. In terms of page count, over the last 2 years Administration bureaucrats have written an IRA magnum opus that is 3 times the volume of “War and Peace” (or as it was originally titled, “War, What is it Good For” … Absolutely nothin!)

And those numbers reflect just a fraction of the work that goes into each tax credit. To take you behind the scenes, each tax credit regulation also includes press releases, blog posts, talking points for senior administration officials to brief the media, and for use in meetings with key stakeholders in industry, NGOs, and Congress. Some tax credits have implications for our international partners and allies, and the Administration will prepare briefings with embassies and guidance that gets cabled out to U.S. diplomats around the world.  All this paper needs to be reviewed by subject matter experts, public affairs specialists, and of course, lawyers. 

You can quibble with the substance - there are certainly elements of several tax credit regulations that could be improved– but this incredible output is a testament to the dedication and sacrifice of the Administration’s IRA policy team and I hope they can take a moment to reflect on everything they accomplished over the past two years.

Outperforming Expectations

💰Treasury has some evidence from 2023, the first full year of returns, to show that the hard work is paying off. The IRS announced that a whopping $8.4 billion was claimed on the Home Energy Efficiency and Energy Property tax credits in 2023, crushing the original official estimate of $2.3 billion.  Those numbers will grow as tax returns submitted with extensions continue to be tallied. Remember, the official estimates anticipated that the credits would grow in popularity over time. If they do, even at the relatively modest rates projected, we’d get a mind boggling $17.2 billion dollars claimed in 2031, the final year of the credits.

Source: DC CleanTech

Stacked up from 2023 until the credits expire in 2031, it would amount to $131.4 billion claimed, vs. the official estimate of $36.2 billion. That’s nearly half of the ENTIRE anticipated $270 billion expenditure across all 26 new or modified clean energy tax credits in the IRA, combined🤑!

Based on the limited data available, we’re seeing a similar trend across other IRA tax credits. Uptake of the new and used clean vehicle tax credits have outperformed expectations, with more than $1 billion claimed via point-of-sale rebates in the first 5 months of the year. And given that 10% of the new clean vehicle and 20% of used clean vehicle tax credits weren’t filed via point of sale, the amount ultimately claimed under those credits for the first 5 months of the year will be well above that $1 billion figure. If those trends persist through the end of the year, we could see as much as 5 times the originally estimated $547 million claimed in 2024. CBO also expected the uptake of these tax credits to increase until they expire in 2032. There are lots of reasons why that might not be the case, including the strict sourcing requirements that, among other things, disqualify new clean vehicles from the tax credits if certain critical minerals and battery components are sourced from China starting in 2025. Even so, the fact that these credits could hit $2.5 billion in claims this year alone is incredible; the official estimates never saw these credits surpassing more than $1.6 billion in any given year. 

Source: DC CleanTech

There was a lot of speculation that, given the sourcing requirements, the 30D new clean vehicle tax credits would be undermined by the 45W Commercial Clean Vehicle credit, which does not have sourcing criteria and can be applied to most conventional EV leases. So far, that has not happened, despite high anticipated uptake for 45W with preliminary data showing an 8% bump in EV leases vs sales since Treasury’s determination that leased vehicles can qualify. And speaking of those 30D sourcing requirements, DOE’s Office of Manufacturing and Energy Supply Chains (MESC) provided new Q&A to help explain how it will interpret the IRA’s Foreign Entity of Concern provision, most notably that OEMs need to take action now on sourcing FEOC-compliant graphite in order to qualify for the “impracticable-to-trace transition rule”.

New EV Retail Registrations by Finance Type

There’s also evidence of the IRA’s power to move markets in the growing clean energy tax transfer sector.  A new Crux report projects deal volume to more than double from $9 billion in 2023 to $20-25 billion in 2024.

Actual and Forecast Quarterly Deal Volume in 2024 Tax Credits

This is all corroborated by MIT and the Rhodium Group’s recent Clean Investment Monitor report on the impact of the IRA in its first two years. In addition to loads of great data about clean energy manufacturing investment by sector, it also included this really interesting table with its estimates of federal spending on the various IRA tax provisions, as well as government grants and loans. It’s worth noting that the CIM anticipates $9.14 billion to ultimately be spent for the Residential energy and efficiency tax credits in 2023 vs. Treasury’s initial $8.4 announcement.

Source: Clean Investment Monitor: Tallying the Two-Year Impact of the Inflation Reduction Act

Treasury wasn’t the only one celebrating the IRA’s birthday - 18 House Republicans (mostly in Democrat stronghold states) wrote to Speaker Johnson urging him not to repeal the law.

Government Financing: August’s Awards

The U.S. Government opened the spigots in August, announcing more than $34 billion in grants, loans, and loan conditional commitments. This more than tripled the massive $10 billion investment in July.

August’s Spotlight Deal ☀️ DOE Loan Programs Office (LPO) announces $1.45 billion conditional commitment for a loan to QCells to support its solar manufacturing facility in Georgia which will produce ingots, wafers, cells and finished solar panels. The facility will be the largest ingot and wafer plant ever built in the United States. It will also be the first fully integrated silicon-based solar manufacturing facility constructed in the United States in over a decade. Given the global dominance of Chinese companies in the solar manufacturing sector, the loan package to QCells, a subsidiary of South Korea-headquartered Hanwa, has important energy security and manufacturing onshoring ramifications. 

🇺🇲+🇰🇷LPO Facilitates Massive Korean Clean Tech Investment into U.S.

The announcement is its latest in an impressive list of LPO deals with Korean-based firms. LPO’s financing of more than $13 billion to projects supported by these companies could unlock multiples more of foreign direct investment from Korea into the U.S. clean energy manufacturing sector and attract jobs, skills, and financing into sectors with few U.S. participants. LPO funding for Korean-backed projects amounts to nearly 44% of the more than $31 billion total in LPO conditional commitments and closed loans under the Biden Administration. Clean tech is clearly becoming a key pillar of the U.S.-Korea bilateral relationship.   

  • ⚡DOE Grid Deployment Office (GDO): $2.2 billion first 8 selections for the second round of GRIP funding for Grid Innovation Program. Funding will support 8 projects across 18 states, catalyzing more than $8 billion in additional private investment:

    • $600,561,319: California Energy Commission: Charge 2T: California Harnessing Advanced Reliable Grid Enhancing Technologies for Transmission. 

    • $389,345,755: Massachusetts Department of Energy Resources: Power Up New England Transmission and Storage project in Massachusetts, Connecticut, Maine, Rhode Island, New Hampshire, and Vermont

    • $700,000,000: Montana Department of Commerce: North Plains Interregional Innovation Transmission project in Montana and North Dakota

    • $30,000,000: New York Power Authority: Clean Path New York underground/underwater HVDC transmission line in New York

    • $57,099,386: North Carolina Department of Environmental Quality State Energy Office: North Carolina Innovative Transmission Rebuild project, in partnership with Duke Energy

    • $87,629,455: Redwood Coast Energy Authority: Tribal Energy Resilience and Sovereignty Project will develop Tribe owned and operated microgrids in partnership with four Tribes in California

    • $249,557,047: Utah Office of Energy Development: Reliable Electric Lines: Infrastructure Expansion Framework Project to deploy advanced conductor cables to boost transmission capacity across Utah, Oregon, Wyoming, Idaho, Arizona, California, and five tribal nations. 

    • $85,433,351: Virginia Department of Energy: Data Center Flexibility as a Grid Enhancing Technology project in Virginia and South Carolina. 

  • ☢️DOE LPO: $1.5 billion closed loan with Holtec for restoration of Palisades Nuclear Power Plant in Michigan 

Government Financing: August’s Opportunities

The Federal Government announced more than $1.6 billion in new funding opportunities in August across several clean tech sectors.  

Engage in the Debate

  • Treasury issued a Notice of Proposed Rulemaking for the IRA’s 48E(h) Clean Electricity Low-Income Communities Bonus Credit Program. Comments due October 3. 

    Why it matters: The allocated credit (1.8 GW available annually) provides a 10 or 20 percentage point bonus in addition to the 30% 48E Clean Electricity Investment Tax Credit if prevailing wage and apprenticeship requirements are also met. Under the proposed rule, additional types of clean electricity would be eligible for the credit, including geothermal, nuclear, and hydroelectric, among others.

Upcoming Events

  • September 4: DOE OTT webinar for industrial decarbonization lab call. Register here

In the News

Graphite Sector Shows Mixed Reactions to Proposed Changes to 301 Tariffs

EV Tax Credit Savings hit $1.5B, Treasury says

US Senators seek to exclude Chinese PV manufacturers from IRA tax benefits

DOE Greenlights Wisconsin to Disburse Climate Law’s Energy Rebates

China’s BYD seeks entry to Canada EV market despite likely tariffs

Drumbeat grows louder on hill for looser hydrogen rules

Business & Human Rights Resource Centre Report on Climate and Human Rights Impacts of Indonesia’s Nickel Supply Chain

Treasury Issues Warning About Solar Company “Scams”

Around a third of Carbon Credits Fail New Benchmark Test

DOE announces Principles for Responsible Carbon Management Projects

House Republicans Urge Speaker Johnson not to Repeal IRA

Clean Energy Tax Breaks more popular than expected

DHS Places Additional PRC-Based Companies on the UFLPA Entity List

China and Russia Account for 60% of new Nuclear Construction last Decade

Canada Matches U.S. 100% Tariff on Chinese EV Imports

Biden bumps number of soar cells that can enter country tariff-free

DOE Report: Clean Energy Jobs Grew at More than Twice the Rate of Overall U.S. Employment

Indian Solar Panels face Scrutiny under UFLPA

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The $10 Billion Cleantech Financing Spree