Utility Transition Hub^TM

Advocates and other stakeholders can play an important role in informing PUCs about the potential benefits of the IRA. Before a proceeding begins, regulators can often engage with stakeholders through less formal channels like ex parte briefings and technical conferences, which allow for information exchange and Q&A.

Advocates and other stakeholders can leverage these channels to ensure that regulators and regulatory staff have a strong foundational understanding of the IRA and its potential benefits before they make decisions on litigated issues in a proceeding. The stakeholders can use tools like RMI's Docket Opportunity Tracker and IRA Opportunity Map to prioritize IRP dockets based on potential impact and the presence of strong IRA opportunities, such as clean repowering.

By sharing information in advance of an opening order, advocates and other stakeholders can encourage regulators to issue proactive guidance. This guidance can communicate minimum expectations for information sharing and outline the approaches utilities should include in their filings, ultimately saving time and resources.

Resources:

• Read Page 32 in RMI's Harnessing the IRA report to understand what regulators can to do to direct utilities to maximize IRA potential in IRP planning.
• Read RMI's article "How Regulators Can Direct Utilities to Leverage IRA Savings" to learn more about recent progress from PUCs on directing utilities to leverage IRA savings.
• Read the Policy Statement from the Washington Utilities and Transportation Commission (UTC) to learn how a PUC can communicate general expectations of IRA implementation in a regulatory proceeding.

If utilities have a stakeholder engagement process in IRPs or other relevant planning proceedings, advocates can engage with or submit comments to encourage utilities to take actions that incorporate or assess IRA opportunities.

Resources:

• Read Page 12 in RMI's Harnessing the IRA report for a detailed list of recommended actions for utilities to include the IRA in each IRP element.
• Read RMI's insight brief "Modeling the DOE’s Energy Infrastructure Reinvestment Program in Resource Planning" to understand how to encourage utilities to employ comprehensive strategies to model the full breadth of the savings opportunity offered by the EIR.

Intervenors, in proceedings where they are allowed to submit discovery questions to request data and information from the utilities, can use discovery to clarify how utilities have incorporated assessments of IRA opportunities in their filings.

Resources:

• Read Page 43 in RMI's Harnessing the IRA report for discovery questions to use in IRP proceedings to help establish an initial understanding of how utilities incorporate IRA into their filings.

Intervenors, in proceedings where they are allowed to submit comments and/or testimony, can collaborate with experts to conduct modeling and incorporate the results into the submission. This will demonstrate the ratepayer savings benefits that may be realized if the utility has failed to identify them in its filing.

These comments and testimonies can help inform regulators as they evaluate utility filings. They can help ensure that utilities have carefully evaluated the economics of alternative options in planning proceedings, passed along IRA savings to ratepayers, and included a comprehensive assessment of community benefits in the portfolio selection process.

Resources:

• Read RMI's articles on the EIR to understand what types of quantitative analysis insights can be derived from financial modeling to support EIR deployment in planning conversations:
  • The Energy Infrastructure Reinvestment Program: Federal financing for an equitable, clean economy
  • Maximizing the Value of the Energy Infrastructure Reinvestment Program for Utility Customers
• Read RMI's insight brief (link forthcoming) to understand how to conduct alternative IRP modeling with an expert consultant to support arguments of the best use case of the EIR.
• Review RMI's Co-op Tax Credit calculator and associated resources to understand how to engage co-ops in leveraging IRA benefits.