Climate Policy Analysis

On August 25, 2025, the Minnesota Public Utilities Commission (‘The Commission’) published a notice of public comment soliciting public feedback on its proposed use of regulatory costs of greenhouse gas (GHG) emissions in utility resource planning (Docket Number E999/CI-07-1199; G008,G002,G011/CI-23-117; G999/CI-21-565). Under the proposal, state natural gas utilities would be required to assign costs to the GHG emissions associated with their plans and operations. This is a significant development with precedent setting potential for other states, as well as potential federal policy. To EPRI’s knowledge, this is the first time GHG pricing has been suggested in gas utility resource planning. As such, there are new technical issues that are important for The Commission, utilities, and the public to consider.

On November 21, 2025, EPRI submitted the public comments in this document to The Commission and the related public docket. EPRI has been studying topics directly related to the issues at hand for nearly twenty years and has over fifty years of research experience in the relevant underlying science. EPRI’s comments identify the following important technical considerations if applying the costs of GHGs in natural gas utility resource planning:

1. Communicating the distinction between the cost of GHGs and the social cost of GHGs
2. Designing a study to estimate ranges of costs of GHG values for Minnesota to capture local emissions transition opportunities
3. Accounting for natural gas emissions abatement policies to avoid additional costs in reducing GHG emissions
4. Clarification on whether non-CO2 GHGs are being considered and subsequent public input
5. Technology portfolios when applying regulatory costs in gas planning
6. Clarification on the types of emissions being considered and subsequent public input
7. Emissions leakage when applying regulatory costs in gas planning
8. Evaluation of natural gas price implications

EPRI’s public comments include a detailed discussion for each topic, as well as references to supporting research and resources.

EPRI’s public comments primarily draw on its extensive research related to the estimation and use of the social costs of greenhouse gases (EPRI’s Social Cost of Greenhouse Gases Scientific Initiative) and related to the development of corporate climate targets and strategies (EPRI’s SMARTargets Initiative).

Market drivers (including data center load growth, shifting fuel prices, and evolving federal incentives) are reshaping energy system investments, while U.S. state clean energy and emissions policies are expanding. This analysis uses EPRI’s U.S. Regional Economy, Greenhouse Gas, and Energy Model (US-REGEN) energy systems model to evaluate how policy and market drivers could affect energy technology investments, fuel use, emissions, and costs through 2050. Model results suggest that state policies may accelerate the adoption of emerging fuels and technologies, with the scale and composition set by policy stringency and costs. Electric capacity additions and load growth exceed recent historical rates across most scenarios and regions. Key findings highlight planning needs across resources, sectors, fuels, and geographies to meet growing energy demand while achieving reliability, affordability, and energy and emissions goals.

In response to the U.S. Department of Energy’s (DOE’s) draft report, A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate, released in July 2025, EPRI submitted formal comments during the public review period. As an independent, non-profit research organization with a public-benefit mission, EPRI often develops objective, science-based comments grounded in its extensive R&D portfolio and its unique role as the electricity sector’s collaborative research organization.

EPRI’s comments in this case focus on the implications of the DOE report for the power sector, particularly in the areas of reliability, resilience, and adaptation. Drawing on research from EPRI’s Climate REsilience and ADaptation initiative (READi), as well as longstanding work in low-carbon pathways, air quality, and the social cost of carbon, the comments emphasize the importance of high-quality data, robust scientific foundations, and transparent methodologies. The report examines the DOE’s treatment of extreme weather, emissions policy, and socioeconomic risks, and offers constructive recommendations to improve the scientific rigor and practical relevance of the final report. EPRI’s contributions aim to support informed decision-making and continued public and scientific engagement on climate resilience and energy system planning.

This dashboard offers an interactive way to explore a curated collection of energy and end-use policies and incentives across the United States, spanning both state and federal levels. Users can interact with a hex map, pie chart, and searchable table to filter policies by state, policy type, sector, and more. Each policy entry includes a concise summary, key classifications (such as sector, date enacted, and policy type), and a direct link to the original source for further reading. This is a non-exhaustive list and we intend to update it with new releases over time. Whether you're conducting research, informing decision-making, or simply exploring the policy landscape, this tool provides a clear and accessible entry point.

Please visit https://apps.epri.com/energy-policy-dashboard to view this interactive dashboard.

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Many countries are using investment- and subsidy-based climate policy approaches such as tax credits and grants. However, evidence is limited about the impacts of these policy instruments on energy systems and emissions. This analysis highlights potential issues in assessing the impacts of investment-based policies and brings together empirical and modeling estimates of impacts of the U.S. Inflation Reduction Act (IRA) as a case study. Data on clean energy manufacturing projects, household clean technology uptake, and public expenditures in the U.S. show record levels of investment after IRA’s passage—including a 64% increase from 2022 to 2024—and analysis suggests that further increases are expected in the future. Although IRA incentives could amplify trends of increased deployment of renewables, energy storage, and zero-emitting vehicles, there has been a notable trend break in announced investments in emerging technologies such as electrolytic hydrogen and carbon management. Modeled projections suggest that IRA could lower household energy bills by $85 to $430 per year and roughly double emissions reductions over the next decade.

This is an update to the Net-Zero 2050: U.S. Economy-Wide Deep Decarbonization Scenario Analysis, originally published in 2022. The 2024 update includes revised technology assumptions, representation of current policies, emerging trends in data center loads, and a broader perspective on uncertainty with a range of technology and sensitivity cases.

To access LCRI Net-Zero 2050: Sensitivity Analysis and Updated Scenarios v2.0, click here: https://lcri-netzero.epri.com

Platform Requirements

Modern web browsers for desktop or mobile operating systems, including recent versions of:

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• Safari
• Firefox
• EDGE

In 2024, the U.S. Securities and Exchange Commission (SEC) issued a final climate risk disclosure rule; however, its future is uncertain. Nonetheless, climate risk assessment is valuable for company planning and there is increasing demand for climate risk information and disclosure. Company-level climate risk assessment and disclosure are new activities for most companies and stakeholders, with significant scientific and analytical needs and challenges. This publication identifies the technical requirements, analytical needs, and technical issues associated with preparing for and responding to the SEC’s rule, as well as climate disclosure in general. Overall, this publication provides technical perspectives to inform (1) potential future disclosure, (2) climate risk assessment analytical activities and communications, and (3) internal and external engagement.

Many electric companies have announced voluntary CO2 reduction targets, including goals to reach net-zero emissions from their generating units. Approximately 90% of 2005 power sector emissions are subject to either a utility target or state emissions policy. This deliverable tracks the implications of company CO2 targets and state-level decarbonization policies on U.S. power sector emissions using public data sources. This analysis indicates that power sector CO2 would decline by 75% by 2050 from 2005 levels if utilities and states meet their stated targets. Since the 2020 version of this analysis, the number of companies with net-zero targets not covered by existing state-level targets increased from 18 to 24, and many utilities increased the reduction percentages for interim targets. The analysis also documents that 58% of companies included in the analysis (covering 72% of emissions) mention environmental justice or equity in their climate reports.

The Inflation Reduction Act offers potentially beneficial tax credits for deploying new generation and storage assets, but some tax credit bonuses require compliance with certain criteria that may entail additional costs. Understanding the expected net benefit of the credits as well as some aspects of the market for apprenticeship labor and domestic content will help resource planners develop better cost assumptions for their planning efforts. This report begins with a brief overview of the Inflation Reduction Act of 2022 and an analysis of some of the key requirements for tax credit bonuses: the market for apprenticeship labor and domestic content in the United States. It then presents the findings of a cost study on compliance with the IRA’s labor and domestic content bonus requirements. The results indicate that compliance with the labor bonus requirements (prevailing wages and apprenticeships) may result in significant savings across technologies and credit types, whereas compliance with the domestic content bonus requirements (domestically sourced iron, steel, and manufactured products) may cost nearly as much or more than the value of the bonus.

Hydrogen and low-carbon fuels could play important roles in reaching economy-wide net-zero emissions, especially for applications in industry, transport, and energy storage. The Inflation Reduction Act (IRA) contains novel production tax credits for clean hydrogen (45V), which can have complex impacts on hydrogen production, electric generation, and emissions. This report describes an analysis using EPRI’s US-REGEN model to quantify potential impacts of the 45V subsidy under scenarios that vary qualification criteria and the scope of the demand response for hydrogen. The analysis indicates that 45V credits could lead to significant deployment of electrolytic hydrogen across all scenarios, while net emissions effects depend on the qualification criteria. Projected fiscal costs imply higher outlay per tonne of CO2 reduced than for other IRA provisions.