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FEDERAL FUNDING LEARNING SERIES PART 5
PLAY YOUR PART: UNDERSTANDING HOW CITIES CAN TAKE
ADVANTAGE OF IRA GRANTS, NEW IRS PROVISIONS AND
DIRECT PAY MODELS TO ADVANCE COMMUNITYWIDE
CLEAN ENERGY PROJECTS
December 15, 2022
Introductions
Alex Dane
Senior Manager
Clean Energy Innovation & Partnerships
WRI
Matthew Popkin
Manager
Urban Transformation
RMI
Many Thanks to the rest of the RMI/WRI Funding Team:
Jingyi Tang & Ryan Warsing (RMI), Andrew Light (WRI)
Ian Goldsmith
Research Analyst
U.S. Energy
WRI
Kat Carroll
Research Analyst
U.S. Energy
WRI
Last time on our
Federal Funding
Learning Series...
3
What is the Inflation Reduction Act?
How New Market Incentives and Direct Pay
Unlock Opportunities for Municipalities
Key Tools to Help Navigate Federal Funding
Considerations As You Prepare for New IRA
and IIJA Programs
Agenda
Welcome & Introductions
Funding Guidance Update: Understanding Available Funding and Incentives
How Cities Can Seize the Moment
Preparing for Justice40: Integrating Equity into City Grant Applications
Deal Stacking: Maximizingthe Value from theIRA for Your Community
How Direct Pay Impacts City Roles and Creates New Models for Clean Energy Deployment
Q&A
4
Key Learning Objectives
5
1. Identify key roles cities can play to support
their own energy procurements and catalyze
clean energy adoption community-wide
2. Explore how different clean energy
projects can “stack” IRS tax provisions
and utilize direct pay models to take
advantage of a new and improved
economic landscape enabled by the IRA
Poll
Questions!
Poll Questions
• Welcome! Which municipal department do
you work within?
• Elected Official
• Finance/Grants
• Management/Administration
• Planning
• Public Works
• Sustainability/Resilience
• Transportation
• Technical advisor/consultant to
municipalities
• Non-profit/community organization
• Other (not listed)
• How would you describe the community
you represent or work for?
• Large City (200,000+ pop.)
• Medium City (50,000-200,000 pop.)
• Small City or Town (Under 50,000 pop.)
• County – Urbanized Area
• County – Rural Area
• Municipal Moon Outpost
• This is our 5th webinar in this learning
series. Have you joined us for previous
sessions?
• No, this is my first time!
• Yes, I’m a returning customer.
• Yes, I’ve seen every episode so far!
7
Poll Question
Why are you interested in pursuing federal funding?
• Because there is money available
• The leadership of my local government has asked me to do so
• To fill a budget gap for a project
• To accelerate a project that would otherwise take years to complete
• To leverage local dollars for greater impact
• To do something innovative, interdisciplinary, and ambitious
• No specific interest - I’m just here to learn today
• My favorite hobby is scrolling endlessly through Grants.gov
• Another reason (not listed)
8
Funding Guidance Update:
UnderstandingAvailable Funding and Incentives
204 funding opportunities are overwhelming, but FFOLD includes
5 filters to quickly down select to the most relevant to you
Our new Funding Guidance helps make navigating the
terms, strategies, and types of incentives digestible
11
12
This guidance is broken down into 3 main categories, with
brief information and insights to walk you through different
funding considerations
How Cities Can Seize the Moment
12/16/2022 13
With IIJA and IRA both enacted, communities need
to consider multiple buckets of federal funding
14
Tax
Credits
Grants
Rebates
Loans
The IRA, combined with the IIJA and CHIPS and Science Act,
offer historic levels of federal investment in decarbonization and
the energy transition
Source: RMI, Congress’s Triple Whammy: Innovation, Investment and Industrial Policy
IRA’s projected climate spend is $386B, but that could be far
higher since tax credits make up 70% of IRA and are uncapped
CleanElectricity Tax Credits
42%
Individual CleanEnergy
Incentives
9%
CleanManufacturing Tax
Credits
10%
CleanFuel and Vehicle
Tax Credits
9%
Other Energy and
Climate Spending
4%
Conservation, Rural
Development, Forestry
9%
Building Efficiency, Electrification, Transmission,
Industrial, DOEGrants andLoans
7%
Air Pollution, Hazardous Materials,
TransportationandInfrastructure
10%
Green = Tax Credits
Blue = Grant/Loan/Rebate
C40 Cities released an IRA implementation guide to help
mayors and their staffs understand the climate provisions
and grant programs included in the IRA:
17
Climateaction and the Inflation Reduction Act: A guide for local government leaders (c40knowledgehub.org)
18
Expansion of Ambition for Cities
2021 Clean
Energy Baseline
Bipartisan
Infrastructure
Law
Inflation
Reduction Act
Level of Federal Funding
• Educating residents, nonprofits and businesses about how to access tax credits,
rebates, and grants (ex: home energy efficiency grants)
• Creating incentives, policies and conditions to encourage businesses to participate in
the renewable energy, electrification, and decarbonization transition
• Encouraging growth of partnerships between universities, nonprofits, energy
businesses, the construction industry, etc. in order to catalyze innovation
Advocate - Facilitator
19
Policy and goal-setter
Incubator - Partner
With an influx of incentives, cities can take on new roles
in assisting residents and businesses in the community
Consider multiple strategies and metrics to help
increase and measure project ambition and impact
Align projectswith long-term plans and strategies
Partner with other municipal departments,businesses,
non-profits,utilities, etc.
Implement scalable and replicable programs to build long-
term capacity
Leverage funds into an effort that extends beyond initial
funding
Change the way officials, businesses, and local residents
think about energy use
Try innovative technologies or approaches
Energy savings
Jobs created
and/or
retained
Renewable
energy capacity
installed
Funds
leveraged
Greenhouse
gas emissions
reduced
Preparing for Justice40: Integrating
Equity into City Grant Applications
12/16/2022 21
22
Executive Order 14008 and Justice40 Interim
Implementation Guidance
40% of the benefits of investments in climate change, clean energy and energy efficiency, clean transit, affordable and
sustainablehousing, training and workforce development,remediationand reduction of legacy pollution,and the
developmentof critical clean water and wastewaterinfrastructure should flow to disadvantaged communities (Source).
23
Source: Lawyers for Good Government
• No single consistent
definition of a
disadvantaged
community – states
define disadvantaged
communities via
different criteria
• Some agencies, like
DOE, will accept state
definitions of DACs for
consideration when
awarding funding
Lawyers for Good Government Disadvantaged
Communities Criteria Report
24
Executive Order 14008 and Justice40 Interim
Implementation Guidance
40% of the benefits of investments in climate change, clean energy and energy efficiency, clean transit, affordable and
sustainablehousing, training and workforce development,remediationand reduction of legacy pollution,and the
developmentof critical clean water and wastewater infrastructureshould flow to disadvantagedcommunities (Source).
Agency Prioritization Criteria
Different agencies define a
‘disadvantaged’ community
according to their own criteria,
ex: DOT’s definition for
‘transportation burden’ or DOE’s
‘energy burden’
Department of
Transportation
Department of Energy Environmental ProtectionAgency Housing and Urban
Development
Priorities for Justice40
Inclusion into Overall
Planning
• Increaseaffordable
transportation options
that fight climate
change and connect
communities
• Identify and prioritize
projects that benefit
DACs
• Evaluate the negative
impacts of
transportation
projects on DACs
• Decreaseenergy burden in
DACs
• Decreaseenvironmental
exposureand burdens of
energy infrastructure
• Increaseparity in clean energy
technology
• Increaseaccess to low-cost
capital in DACs
• Increaseclean energy
enterpriseand jobs in DACs
• Increaseenergy resiliency and
democracy in DACs
• Develop comprehensive
framework for EJ impacts in
relevant EPA decisions
• Build capacity for community
participation
• Strengthen EPA’s external civil
rights compliance program
• Integratecommunity science
• Make procurementand
contracting moreequitable
• Help tribal communities
achieve safe, resilient
housing
• Pilot new models for Section
3 compliance
• Improveequity in
community planning and
engagement
• Reduce lead and radon
exposure
• Update HUD’s
environmentalreview
policies to include climate
hazards and environmental
justice
IndividualDepartment
Mapping Tool
Transportation
Disadvantaged Census
Tracts
DOEDisadvantaged Communities
Reporter
Climate and Economic Justice
Screening Tool; EJScreen
Climate and Economic Justice
Screening Tool
Clarity of Implementation
Pathway for Cities
Agency Implementation of Justice40
26
Executive Order 14008 and Justice40 Interim
Implementation Guidance
40% of the benefits of investments in climate change, clean energy and energy efficiency, clean transit, affordable and
sustainablehousing, training and workforce development,remediationand reduction of legacy pollution,and the
developmentof critical clean water and wastewater infrastructureshould flow to disadvantagedcommunities (Source).
Agency Prioritization Criteria
Different agencies define a
‘disadvantaged’ community
according to their own criteria,
ex: DOT’s definition for
‘transportation burden’ or DOE’s
‘energy burden’
Grant Program
Criteria
Within the prioritization criteria from an
agency, there are a) specific mapping
tools highlighting specific areas for
investment and/or b) individual criteria
within a program or funding opportunity
27
• Prioritized applications that advanced racial equity or provided 'significant
community benefit'
• Suggested that applicants use the DOT Transportation Disadvantaged
Census Tracts mapping tool, EJScreen or geographic or demographic
indicators including low income, high or persistent poverty, linguistic
isolation, etc., to identify disadvantaged communities when making their
application
• Takeaway: Because of a diversity of indicators available at the state
and federal level, and a need for flexibility, applicants to grant
programs will likely be required to make their own argument as to
whether the area where their project is located, or the people that it
will impact, could be considered disadvantaged.
Low- or No-Emissions Vehicle Program
Deal Stacking: Maximizing Value from
the IRA for Your Community
12/16/2022 28
The IRA's updated energy tax credits provide an
opportunity for communities to "stack" incentives
• On top of the base PTC and ITC, IRA adds
incentives for:
• Paying good wages for workers
• Using American-made components
• Siting in "energy communities," including
brownfield sites and historically fossil fuel
dependent areas
• Siting in a low-income or tribal community (ITC)
• Built as a part of a low-income residential building
(ITC)
• Having 50% of the financial benefits flow to low-
income households (ITC)
• Maximum possible benefits:
• $31/MWh for the PTC
• 70% of eligible project costs for the ITC!
29
Your community can be the support and resource hub for tax
credit deal stacking
New IRA-powered roles, along with existing expertise and
connections, make city governments well-suited to be deal stack hubs for
their communities.
Incubator - Partner
• Finding and recommending
solar installers who use
American-made materials
• Partnering on research with
local higher education
institutions
• Connecting with non-profit
housing developers
Policy and Goal Setter
• Prioritizing
initiatives and projects that
fulfill adders
• Easing solar permitting and
zoning regulations
• Engaging in utility resource
planning and regulatory
process to support DERs
Advocate - Facilitator
• Identifying "energy
community" sites
• Educating local businesses
and non-profits
• Holding community
engagement sessions on
renewable energy
development
Deal Stacking Example
• A for-profit housing developer in Western Pennsylvania
plans to develop a new multifamily property with HUD
project-basedrental assistance.
• Knowing the potential for IRAdeal stacks, the city
Department of Housing connects the developer to the
city Department of Sustainability.
• The Department of Sustainability provides
resources, guidance, and connections to help
meeting adders.
• The new building installs a rooftop solar array with 70%
of its costs reimbursed, quickly turning it into a source
of revenue!
31
File:Vienna and Earl Apartment Buildings.JPG - Wikimedia Commons
Deal Stack Diagram
32
30% InvestmentTax Credit
+10% Domestic Content
Bonus
+10% Energy Community
Adder
+20% QualifiedLow-
Income Residential
Building Project (through
1.8 GW environmental
justice capacity)
70% of rooftop
solar costs
reimbursedunder
ITC!
With assistanceand guidance from the city,
the housingdeveloper is able to achieve:
Start preparing for deal stacks by learning more and
incorporating them into your development strategy
33
Identify and map areas
in your municipality
that will qualify for IRA
“adders”
Help your community
partners and institutions
understand these new
opportunities
Proactively engage
with your finance
departments to prepare
them for new financial
opportunities
Build relationships with
community-based
partners to share these
opportunities for
equitable development
Embrace complexity as
an opportunity for
incentive stacking
Consider all the newIRA
incentives in context
with your community’s
strategy
How Direct Pay Impacts Cities and
Creates New Models for Clean Energy
Deployment
12/16/2022 34
The IRA created a new mechanism called “Direct Pay” (aka
“Elective Pay”) that unlocks the benefits of tax credits for tax-
exempt entities
35
What does this do?
• Enables tax exempt
entities to directly
capture tax credit
incentives for clean
energy
How will this work?
• Direct Pay will likely
work like a regular
income tax refund
where eligible parties
are treated as if they
"overpaid" on a tax
return
• This is non-
competitive funding
Why does this matter?
• Project directly
owned by tax exempt
entities are now
significantly more
affordable than ever
before
Direct pay strengthens the role cities play in community
clean energy deployment because:
• In the private sector, tax credits must be monetized as reductions of tax
liability, leading to complicated tax equity structures.
• Direct pay guarantees a cash payment from IRS.
Tax credits are received
as cash paymentsdirectly from
the federal government.
• The "adders" to tax credits align funding with many public policy goals,
like supporting American businesses and having clean
energy benefit low-income communities.
Tax credits and adders align
with public policy goals.
• Direct pay is open to all state, local, and tribagovernment subdivisions,
as well as any 501(c)(3) organization.
• This opens new partnershipsand alignments of clean energy funding.
Cities can directly partner with
other tax-exempt entities to
advance clean energy.
36
Direct pay unlocks new models for bringing the benefits
of clean energy to your community
DirectOwnership for Municipal Benefit
• Cities fund and own clean energy projects
for their own direct benefit
• Roles:Policy and goal setting
DirectOwnership for Community Benefit
• Cities fund and own a clean energy project
for community members to utilize
• Roles:Policy and goal setting, Incubator
37
Direct Pay Facilitation
• Cities help other eligible entities take
advantage of direct pay by providing technical
and strategic assistance
• Roles: Advocate, Incubator
Direct Pay "Plug-in"
• Cities "plug-in" direct pay as a funding source
into a new or previously ideated program or
project
• Roles: Policy and goal setting
Direct Ownership for
Municipal Benefit: A
School Goes Solar
• A school district in New Mexico
decides to install a solar carport.
• Because of direct pay, it receives
30% of its costs back
through electing to take the ITC.
• Over the next 10 years, the district
saves about 30% on its municipal
energy bills and offsets a
significant portion of its
emissions.
38
39
Direct Ownership for Municipal Benefit Diagram
Federal
Government
Local Utility
Ownership
Green – Dollars
Blue – Ownership
Gold – Electricity
Orange - Assistance
Direct Ownership
for Community
Benefit: Making a
Brightfield
• A Midwestern town builds a
community solar array on a
brownfield site in a low-income
neighborhood.
• The town receives 60% of
eligible
project costs back through
claiming the ITC plus eligible
adders.
• The lower project costs mean
lower community solar
subscription fees for low-income
neighborhood households.
40
Direct Ownership for Community Benefit Diagram
41
Federal
Government
Owner-
ship
Green – Dollars
Blue – Ownership
Gold – Electricity
Orange - Assistance
Local Government
Community
Residents
Direct Pay Facilitation: Connecting the Dots
• A southeastern city wants build resilience
hubs with solar and storage solutions.
• The city reaches out to a large local church
and a library, who are both direct pay
eligible.
• The city connects the organizations to
their trusted local developer. Providing
technical assistance, the city helps them
claim direct pay tax credits for the
solar and storage system.
42
Direct Pay Facilitation Diagram
43
Ownership
Ownership
Green – Dollars
Blue – Ownership
Gold – Electricity
Orange - Assistance
Local Church
Town Library
Federal
Government
Local Government
Direct Pay "Plug-In"
• A medium-size Great Plains town with a municipal
utility plans to develop a community wind project.
• While the project was proposed before IRA, newly
available tax credits immediately reduce the overall
cost and shorten the payback period.
• With the budget savings generated from the tax credits,
the utility reduces subscriber fees even further than
planned, producing greater savings for consumers.
44
Direct Pay "Plug-in" Diagram
45
Municipal Utility
Ownership
Green – Dollars
Blue – Ownership
Gold – Electricity
Orange - Assistance
Federal
Government
Local Government
Community
Residents
Direct Pay presents certain challenges, meaning it
won't be right for every program
Direct Pay electing entities cannot take advantage of asset depreciation
benefits, which is a key part of recovering costs for private business.
Projects funded by tax-exempt bonds can see their credit reduced by up to 15%.
After 2025, all projects electing for Direct Pay must meet domestic content
requirements on steel, iron, and manufactured products.
Projects must ensure funding to cover upfront planning, permitting, and
installation costs.
46
Next steps to get ready for Direct Pay
47
1. Review your community's clean energy strategy
• Look for ways direct pay can "plug-in" to an existing or planned initiative.
• Consider previous ideas limited by financing constraints.
• Identify areas that may qualify for extra incentives.
2. Identify and build relationships with key partners
• Engage private developers, workforce training agencies, and educational institutions to discuss workforce and domestic
content requirements.
• Talk to your utility about Direct Pay and other IRA incentives about their implications for clean energy in your
community.
• Reach out to newly eligible entities in your community to gauge interest and needs.
3. Prepare for working with the IRS
• Stay tuned for updated guidance.
• Brief your finance department on the changes and opportunities (aka “why this matters”)to
prepare them for dealing with new processes,
The IRA enables cities to make real progress on their
community-wide clean energy goals
48
Grants allow cities to
advance clean energy
and environmental
justice in particular
projects
Deal stacking leverages
city knowledge,
capacity, and expertise
Direct pay opens new
possibilities for clean
energy ownership
models, including direct
city ownership
Cities can work with local
utilities, businesses, and
community institutions and to
ensure awareness of
expanded options for funding
the energy transition
Near-term resources to keep you going!
• USDN’s Inflation Reduction Act Miniguide
• NACO’s Inflation Reduction Act Legislative Analysis for Counties
• RMI - 4 Ways the IRA Speeds the Shift to a Cleaner, More Affordable Energy Future
• WRI - Beyond Climate: 6 Big Benefits of the IRA
• C40 Climate Action and the Inflation Reduction Act: A Guide for Local Government Leaders
Understanding the IRA
• FFOLD Tool (Updated 9/23/2022)
• Electrification Coalition EV Funding and Financing Guide
Understanding Federal Funding Opportunities
• Equity Design Considerations for Federal Funding
• White House CEQ Justice40 Guidance
Understanding Equity& Federal Funding
Questions & Discussion
Type directly in the Zoom Q&A.
THANK YOU FOR JOINING US FOR THIS
LEARNING SERIES!
For more info, please contact:
Matthew Popkin at mpopkin@rmi.org
Alex Dane at alex.dane@wri.org

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Play Your Part: Understanding How Cities Can Take Advantage of IRA Grants, New IRS Provisions and Direct Pay Models

  • 1. FEDERAL FUNDING LEARNING SERIES PART 5 PLAY YOUR PART: UNDERSTANDING HOW CITIES CAN TAKE ADVANTAGE OF IRA GRANTS, NEW IRS PROVISIONS AND DIRECT PAY MODELS TO ADVANCE COMMUNITYWIDE CLEAN ENERGY PROJECTS December 15, 2022
  • 2. Introductions Alex Dane Senior Manager Clean Energy Innovation & Partnerships WRI Matthew Popkin Manager Urban Transformation RMI Many Thanks to the rest of the RMI/WRI Funding Team: Jingyi Tang & Ryan Warsing (RMI), Andrew Light (WRI) Ian Goldsmith Research Analyst U.S. Energy WRI Kat Carroll Research Analyst U.S. Energy WRI
  • 3. Last time on our Federal Funding Learning Series... 3 What is the Inflation Reduction Act? How New Market Incentives and Direct Pay Unlock Opportunities for Municipalities Key Tools to Help Navigate Federal Funding Considerations As You Prepare for New IRA and IIJA Programs
  • 4. Agenda Welcome & Introductions Funding Guidance Update: Understanding Available Funding and Incentives How Cities Can Seize the Moment Preparing for Justice40: Integrating Equity into City Grant Applications Deal Stacking: Maximizingthe Value from theIRA for Your Community How Direct Pay Impacts City Roles and Creates New Models for Clean Energy Deployment Q&A 4
  • 5. Key Learning Objectives 5 1. Identify key roles cities can play to support their own energy procurements and catalyze clean energy adoption community-wide 2. Explore how different clean energy projects can “stack” IRS tax provisions and utilize direct pay models to take advantage of a new and improved economic landscape enabled by the IRA
  • 7. Poll Questions • Welcome! Which municipal department do you work within? • Elected Official • Finance/Grants • Management/Administration • Planning • Public Works • Sustainability/Resilience • Transportation • Technical advisor/consultant to municipalities • Non-profit/community organization • Other (not listed) • How would you describe the community you represent or work for? • Large City (200,000+ pop.) • Medium City (50,000-200,000 pop.) • Small City or Town (Under 50,000 pop.) • County – Urbanized Area • County – Rural Area • Municipal Moon Outpost • This is our 5th webinar in this learning series. Have you joined us for previous sessions? • No, this is my first time! • Yes, I’m a returning customer. • Yes, I’ve seen every episode so far! 7
  • 8. Poll Question Why are you interested in pursuing federal funding? • Because there is money available • The leadership of my local government has asked me to do so • To fill a budget gap for a project • To accelerate a project that would otherwise take years to complete • To leverage local dollars for greater impact • To do something innovative, interdisciplinary, and ambitious • No specific interest - I’m just here to learn today • My favorite hobby is scrolling endlessly through Grants.gov • Another reason (not listed) 8
  • 10. 204 funding opportunities are overwhelming, but FFOLD includes 5 filters to quickly down select to the most relevant to you
  • 11. Our new Funding Guidance helps make navigating the terms, strategies, and types of incentives digestible 11
  • 12. 12 This guidance is broken down into 3 main categories, with brief information and insights to walk you through different funding considerations
  • 13. How Cities Can Seize the Moment 12/16/2022 13
  • 14. With IIJA and IRA both enacted, communities need to consider multiple buckets of federal funding 14 Tax Credits Grants Rebates Loans
  • 15. The IRA, combined with the IIJA and CHIPS and Science Act, offer historic levels of federal investment in decarbonization and the energy transition Source: RMI, Congress’s Triple Whammy: Innovation, Investment and Industrial Policy
  • 16. IRA’s projected climate spend is $386B, but that could be far higher since tax credits make up 70% of IRA and are uncapped CleanElectricity Tax Credits 42% Individual CleanEnergy Incentives 9% CleanManufacturing Tax Credits 10% CleanFuel and Vehicle Tax Credits 9% Other Energy and Climate Spending 4% Conservation, Rural Development, Forestry 9% Building Efficiency, Electrification, Transmission, Industrial, DOEGrants andLoans 7% Air Pollution, Hazardous Materials, TransportationandInfrastructure 10% Green = Tax Credits Blue = Grant/Loan/Rebate
  • 17. C40 Cities released an IRA implementation guide to help mayors and their staffs understand the climate provisions and grant programs included in the IRA: 17 Climateaction and the Inflation Reduction Act: A guide for local government leaders (c40knowledgehub.org)
  • 18. 18 Expansion of Ambition for Cities 2021 Clean Energy Baseline Bipartisan Infrastructure Law Inflation Reduction Act Level of Federal Funding
  • 19. • Educating residents, nonprofits and businesses about how to access tax credits, rebates, and grants (ex: home energy efficiency grants) • Creating incentives, policies and conditions to encourage businesses to participate in the renewable energy, electrification, and decarbonization transition • Encouraging growth of partnerships between universities, nonprofits, energy businesses, the construction industry, etc. in order to catalyze innovation Advocate - Facilitator 19 Policy and goal-setter Incubator - Partner With an influx of incentives, cities can take on new roles in assisting residents and businesses in the community
  • 20. Consider multiple strategies and metrics to help increase and measure project ambition and impact Align projectswith long-term plans and strategies Partner with other municipal departments,businesses, non-profits,utilities, etc. Implement scalable and replicable programs to build long- term capacity Leverage funds into an effort that extends beyond initial funding Change the way officials, businesses, and local residents think about energy use Try innovative technologies or approaches Energy savings Jobs created and/or retained Renewable energy capacity installed Funds leveraged Greenhouse gas emissions reduced
  • 21. Preparing for Justice40: Integrating Equity into City Grant Applications 12/16/2022 21
  • 22. 22 Executive Order 14008 and Justice40 Interim Implementation Guidance 40% of the benefits of investments in climate change, clean energy and energy efficiency, clean transit, affordable and sustainablehousing, training and workforce development,remediationand reduction of legacy pollution,and the developmentof critical clean water and wastewaterinfrastructure should flow to disadvantaged communities (Source).
  • 23. 23 Source: Lawyers for Good Government • No single consistent definition of a disadvantaged community – states define disadvantaged communities via different criteria • Some agencies, like DOE, will accept state definitions of DACs for consideration when awarding funding Lawyers for Good Government Disadvantaged Communities Criteria Report
  • 24. 24 Executive Order 14008 and Justice40 Interim Implementation Guidance 40% of the benefits of investments in climate change, clean energy and energy efficiency, clean transit, affordable and sustainablehousing, training and workforce development,remediationand reduction of legacy pollution,and the developmentof critical clean water and wastewater infrastructureshould flow to disadvantagedcommunities (Source). Agency Prioritization Criteria Different agencies define a ‘disadvantaged’ community according to their own criteria, ex: DOT’s definition for ‘transportation burden’ or DOE’s ‘energy burden’
  • 25. Department of Transportation Department of Energy Environmental ProtectionAgency Housing and Urban Development Priorities for Justice40 Inclusion into Overall Planning • Increaseaffordable transportation options that fight climate change and connect communities • Identify and prioritize projects that benefit DACs • Evaluate the negative impacts of transportation projects on DACs • Decreaseenergy burden in DACs • Decreaseenvironmental exposureand burdens of energy infrastructure • Increaseparity in clean energy technology • Increaseaccess to low-cost capital in DACs • Increaseclean energy enterpriseand jobs in DACs • Increaseenergy resiliency and democracy in DACs • Develop comprehensive framework for EJ impacts in relevant EPA decisions • Build capacity for community participation • Strengthen EPA’s external civil rights compliance program • Integratecommunity science • Make procurementand contracting moreequitable • Help tribal communities achieve safe, resilient housing • Pilot new models for Section 3 compliance • Improveequity in community planning and engagement • Reduce lead and radon exposure • Update HUD’s environmentalreview policies to include climate hazards and environmental justice IndividualDepartment Mapping Tool Transportation Disadvantaged Census Tracts DOEDisadvantaged Communities Reporter Climate and Economic Justice Screening Tool; EJScreen Climate and Economic Justice Screening Tool Clarity of Implementation Pathway for Cities Agency Implementation of Justice40
  • 26. 26 Executive Order 14008 and Justice40 Interim Implementation Guidance 40% of the benefits of investments in climate change, clean energy and energy efficiency, clean transit, affordable and sustainablehousing, training and workforce development,remediationand reduction of legacy pollution,and the developmentof critical clean water and wastewater infrastructureshould flow to disadvantagedcommunities (Source). Agency Prioritization Criteria Different agencies define a ‘disadvantaged’ community according to their own criteria, ex: DOT’s definition for ‘transportation burden’ or DOE’s ‘energy burden’ Grant Program Criteria Within the prioritization criteria from an agency, there are a) specific mapping tools highlighting specific areas for investment and/or b) individual criteria within a program or funding opportunity
  • 27. 27 • Prioritized applications that advanced racial equity or provided 'significant community benefit' • Suggested that applicants use the DOT Transportation Disadvantaged Census Tracts mapping tool, EJScreen or geographic or demographic indicators including low income, high or persistent poverty, linguistic isolation, etc., to identify disadvantaged communities when making their application • Takeaway: Because of a diversity of indicators available at the state and federal level, and a need for flexibility, applicants to grant programs will likely be required to make their own argument as to whether the area where their project is located, or the people that it will impact, could be considered disadvantaged. Low- or No-Emissions Vehicle Program
  • 28. Deal Stacking: Maximizing Value from the IRA for Your Community 12/16/2022 28
  • 29. The IRA's updated energy tax credits provide an opportunity for communities to "stack" incentives • On top of the base PTC and ITC, IRA adds incentives for: • Paying good wages for workers • Using American-made components • Siting in "energy communities," including brownfield sites and historically fossil fuel dependent areas • Siting in a low-income or tribal community (ITC) • Built as a part of a low-income residential building (ITC) • Having 50% of the financial benefits flow to low- income households (ITC) • Maximum possible benefits: • $31/MWh for the PTC • 70% of eligible project costs for the ITC! 29
  • 30. Your community can be the support and resource hub for tax credit deal stacking New IRA-powered roles, along with existing expertise and connections, make city governments well-suited to be deal stack hubs for their communities. Incubator - Partner • Finding and recommending solar installers who use American-made materials • Partnering on research with local higher education institutions • Connecting with non-profit housing developers Policy and Goal Setter • Prioritizing initiatives and projects that fulfill adders • Easing solar permitting and zoning regulations • Engaging in utility resource planning and regulatory process to support DERs Advocate - Facilitator • Identifying "energy community" sites • Educating local businesses and non-profits • Holding community engagement sessions on renewable energy development
  • 31. Deal Stacking Example • A for-profit housing developer in Western Pennsylvania plans to develop a new multifamily property with HUD project-basedrental assistance. • Knowing the potential for IRAdeal stacks, the city Department of Housing connects the developer to the city Department of Sustainability. • The Department of Sustainability provides resources, guidance, and connections to help meeting adders. • The new building installs a rooftop solar array with 70% of its costs reimbursed, quickly turning it into a source of revenue! 31 File:Vienna and Earl Apartment Buildings.JPG - Wikimedia Commons
  • 32. Deal Stack Diagram 32 30% InvestmentTax Credit +10% Domestic Content Bonus +10% Energy Community Adder +20% QualifiedLow- Income Residential Building Project (through 1.8 GW environmental justice capacity) 70% of rooftop solar costs reimbursedunder ITC! With assistanceand guidance from the city, the housingdeveloper is able to achieve:
  • 33. Start preparing for deal stacks by learning more and incorporating them into your development strategy 33 Identify and map areas in your municipality that will qualify for IRA “adders” Help your community partners and institutions understand these new opportunities Proactively engage with your finance departments to prepare them for new financial opportunities Build relationships with community-based partners to share these opportunities for equitable development Embrace complexity as an opportunity for incentive stacking Consider all the newIRA incentives in context with your community’s strategy
  • 34. How Direct Pay Impacts Cities and Creates New Models for Clean Energy Deployment 12/16/2022 34
  • 35. The IRA created a new mechanism called “Direct Pay” (aka “Elective Pay”) that unlocks the benefits of tax credits for tax- exempt entities 35 What does this do? • Enables tax exempt entities to directly capture tax credit incentives for clean energy How will this work? • Direct Pay will likely work like a regular income tax refund where eligible parties are treated as if they "overpaid" on a tax return • This is non- competitive funding Why does this matter? • Project directly owned by tax exempt entities are now significantly more affordable than ever before
  • 36. Direct pay strengthens the role cities play in community clean energy deployment because: • In the private sector, tax credits must be monetized as reductions of tax liability, leading to complicated tax equity structures. • Direct pay guarantees a cash payment from IRS. Tax credits are received as cash paymentsdirectly from the federal government. • The "adders" to tax credits align funding with many public policy goals, like supporting American businesses and having clean energy benefit low-income communities. Tax credits and adders align with public policy goals. • Direct pay is open to all state, local, and tribagovernment subdivisions, as well as any 501(c)(3) organization. • This opens new partnershipsand alignments of clean energy funding. Cities can directly partner with other tax-exempt entities to advance clean energy. 36
  • 37. Direct pay unlocks new models for bringing the benefits of clean energy to your community DirectOwnership for Municipal Benefit • Cities fund and own clean energy projects for their own direct benefit • Roles:Policy and goal setting DirectOwnership for Community Benefit • Cities fund and own a clean energy project for community members to utilize • Roles:Policy and goal setting, Incubator 37 Direct Pay Facilitation • Cities help other eligible entities take advantage of direct pay by providing technical and strategic assistance • Roles: Advocate, Incubator Direct Pay "Plug-in" • Cities "plug-in" direct pay as a funding source into a new or previously ideated program or project • Roles: Policy and goal setting
  • 38. Direct Ownership for Municipal Benefit: A School Goes Solar • A school district in New Mexico decides to install a solar carport. • Because of direct pay, it receives 30% of its costs back through electing to take the ITC. • Over the next 10 years, the district saves about 30% on its municipal energy bills and offsets a significant portion of its emissions. 38
  • 39. 39 Direct Ownership for Municipal Benefit Diagram Federal Government Local Utility Ownership Green – Dollars Blue – Ownership Gold – Electricity Orange - Assistance
  • 40. Direct Ownership for Community Benefit: Making a Brightfield • A Midwestern town builds a community solar array on a brownfield site in a low-income neighborhood. • The town receives 60% of eligible project costs back through claiming the ITC plus eligible adders. • The lower project costs mean lower community solar subscription fees for low-income neighborhood households. 40
  • 41. Direct Ownership for Community Benefit Diagram 41 Federal Government Owner- ship Green – Dollars Blue – Ownership Gold – Electricity Orange - Assistance Local Government Community Residents
  • 42. Direct Pay Facilitation: Connecting the Dots • A southeastern city wants build resilience hubs with solar and storage solutions. • The city reaches out to a large local church and a library, who are both direct pay eligible. • The city connects the organizations to their trusted local developer. Providing technical assistance, the city helps them claim direct pay tax credits for the solar and storage system. 42
  • 43. Direct Pay Facilitation Diagram 43 Ownership Ownership Green – Dollars Blue – Ownership Gold – Electricity Orange - Assistance Local Church Town Library Federal Government Local Government
  • 44. Direct Pay "Plug-In" • A medium-size Great Plains town with a municipal utility plans to develop a community wind project. • While the project was proposed before IRA, newly available tax credits immediately reduce the overall cost and shorten the payback period. • With the budget savings generated from the tax credits, the utility reduces subscriber fees even further than planned, producing greater savings for consumers. 44
  • 45. Direct Pay "Plug-in" Diagram 45 Municipal Utility Ownership Green – Dollars Blue – Ownership Gold – Electricity Orange - Assistance Federal Government Local Government Community Residents
  • 46. Direct Pay presents certain challenges, meaning it won't be right for every program Direct Pay electing entities cannot take advantage of asset depreciation benefits, which is a key part of recovering costs for private business. Projects funded by tax-exempt bonds can see their credit reduced by up to 15%. After 2025, all projects electing for Direct Pay must meet domestic content requirements on steel, iron, and manufactured products. Projects must ensure funding to cover upfront planning, permitting, and installation costs. 46
  • 47. Next steps to get ready for Direct Pay 47 1. Review your community's clean energy strategy • Look for ways direct pay can "plug-in" to an existing or planned initiative. • Consider previous ideas limited by financing constraints. • Identify areas that may qualify for extra incentives. 2. Identify and build relationships with key partners • Engage private developers, workforce training agencies, and educational institutions to discuss workforce and domestic content requirements. • Talk to your utility about Direct Pay and other IRA incentives about their implications for clean energy in your community. • Reach out to newly eligible entities in your community to gauge interest and needs. 3. Prepare for working with the IRS • Stay tuned for updated guidance. • Brief your finance department on the changes and opportunities (aka “why this matters”)to prepare them for dealing with new processes,
  • 48. The IRA enables cities to make real progress on their community-wide clean energy goals 48 Grants allow cities to advance clean energy and environmental justice in particular projects Deal stacking leverages city knowledge, capacity, and expertise Direct pay opens new possibilities for clean energy ownership models, including direct city ownership Cities can work with local utilities, businesses, and community institutions and to ensure awareness of expanded options for funding the energy transition
  • 49. Near-term resources to keep you going! • USDN’s Inflation Reduction Act Miniguide • NACO’s Inflation Reduction Act Legislative Analysis for Counties • RMI - 4 Ways the IRA Speeds the Shift to a Cleaner, More Affordable Energy Future • WRI - Beyond Climate: 6 Big Benefits of the IRA • C40 Climate Action and the Inflation Reduction Act: A Guide for Local Government Leaders Understanding the IRA • FFOLD Tool (Updated 9/23/2022) • Electrification Coalition EV Funding and Financing Guide Understanding Federal Funding Opportunities • Equity Design Considerations for Federal Funding • White House CEQ Justice40 Guidance Understanding Equity& Federal Funding
  • 50. Questions & Discussion Type directly in the Zoom Q&A.
  • 51. THANK YOU FOR JOINING US FOR THIS LEARNING SERIES! For more info, please contact: Matthew Popkin at mpopkin@rmi.org Alex Dane at alex.dane@wri.org