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"Retroactive rebates should not be allowed", State Energy Officials tell DOE

October 9, 2023

Capitol Hill

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The National Association of State Energy Officials (NASEO) sent a letter to the Department of Energy opposing retroactive rebates within the IRA’s residential rebate programs.

Refresher: The two programs, HOMES and HEEHR, are provisions of the Inflation Reduction Act designed to encourage energy-efficient home upgrades. They’re not active in any state, as states are reviewing DOE guidelines and putting together individual applications.

Note: As of now, retroactive rebates are technically allowed under the HOMES program.

So, why oppose retroactivity? State officials say it would have damaging implications for consumers and taxpayers, including:

  • Implementation delays. The complex process of creating retroactivity guidance would “substantially delay” overall program implementation.

  • Increased fraud risk. While most private-sector energy providers are good, the few that prey on consumers “will take advantage of a confusing retroactive approach”.

  • Increased administrative costs. Verifying retroactive rebates would necessitate higher administrative costs, reducing the rebate funds for consumers.

Looking ahead: In the letter, NASEO says retroactive rebates are “needlessly complex, risky, and without public benefit”. The result is unclear, but if states prevail, rebates will be straightforward and only available for projects completed after the programs launch in each state.

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