The Inflation Reduction Act (IRA) Home Energy Rebates offer state energy offices (SEOs) opportunities for unprecedented investments in electrification and decarbonization across the residential sector. Implementing IRA Home Energy Rebates with existing energy efficiency programs can expand the impact of the rebates and increase efficiency in program delivery. This leads to smoother experiences for customers and provides opportunities to coordinate with programs that will last beyond IRA Home Energy Rebates on program design and goals to unlock longer-term market transformation.
Combining IRA rebates with existing energy efficiency programs may also require states to adjust the regulatory requirements for energy efficiency program administrators (PAs). These discussions will largely focus on the questions of whether program administrators can credit savings from IRA funds toward their own portfolio, known as attribution of savings. This issue is important for current program administrators that have energy efficiency resource standards (EERS) or performance incentive mechanisms (PIMs), as program administrators are required to meet savings goals or receive financial incentives for achieving certain levels of savings.
To help state energy offices, utility regulators, and other stakeholders navigate discussions of attribution with IRA Home Energy Rebates, NEEP convened a group of experts in the field of evaluation, measurement, and verification (EM&V). This group helped NEEP to establish four frameworks to help states determine to attribute savings from programs that combine IRA Home Energy Rebates with existing energy efficiency efforts, whether administered by a utility or third party. The four frameworks are: Full Attribution, Proportional Attribution, Negotiated Attribution, and No Attribution.
How a state applies each framework will be unique and can depend on many factors, including the current energy and climate policy landscape, expertise of the current program administrator, and goals of the state. This paper is meant to help guide states and other stakeholders as they identify and apply the appropriate framework for their programs.