While several factors influence the percentage of generation that renewable production makes up in a given year (including variability in solar and wind resources, but also other resources like hydropower and demand for electricity), this increasing share of net generation from solar and wind generation (much of which likely came from new investment) occurred without a strong federal policy in place. In some states, like Texas and Iowa, growth in clean energy generation occurred even without aggressive state incentives in place. In these states, projects mainly have relied on federal tax credits, such as the investment tax credit for solar and the production tax credit for wind, which have been phased down in recent years and have lapsed in the past.
With expanded support from the federal government, the scale of growth described by the CEPP certainly seems possible, especially since the reconciliation proposal from the House Committee on Energy and Commerce supports extensions for the production tax credit and investment tax credit at their full values for the next decade. That proposal also includes provisions for direct pay—meaning that renewable energy developers can reap the benefits without finding a tax equity investor, thus reducing another barrier to development.
Even if the goals of the CEPP are theoretically achievable, design questions around the program persist. For instance, how much will federal support of the CEPP help add new renewables—or will federal support fund projects that would have happened anyway? In a hearing on September 28, Senator Joe Manchin (D-WV) expressed concerns in his closing remarks about the CEPP potentially “paying utilities for what they’re going to do, anyway.”
The CEPP anticipates this concern by crediting only the clean generation that exceeds the previous year’s clean generation plus 1.5 percent. At the national level, according to the US Energy Information Administration’s Electricity Data Browser, renewables have been growing by about 0.5 percent to over 2 percent annually as a share of net generation. Thus, for most states, paying utilities to reach 4 percent may not result in paying for what the suppliers would do in the absence of the policy, given that the payments only start at 1.5 percent growth, and most utilities probably do not currently meet that level of growth. However, this issue of redundancy could be a valid concern for states that consistently meet higher targets, such as Massachusetts and California.
Overall, concerns about the CEPP either being too ambitious or providing unnecessary funds may not be very worrisome. States have shown that a target of 4 percent annual growth in renewables is possible, and 4 percent growth is even more likely with the CEPP in place along with extensions for the renewable tax credits. Also, while some states are exceeding 1.5 percent annual growth (driven largely by state policy incentives), national data show that most states are not. Thus, in most cases, the CEPP likely will provide support for additional investment in renewables, rather than subsidize existing investments.