The Energy Infrastructure Reinvestment Opportunity: Accelerating the Transition of the Oil and Gas Sector
Introduction
The Energy Infrastructure Reinvestment (EIR) program of the Loan Program Office (LPO), coupled with Inflation Reduction Act (IRA) tax incentives, provides a unique and time-sensitive opportunity for the US oil and gas sector to accelerate its transition toward cleaner sources of energy and away from oil and gas.
Through the EIR, the LPO can provide financing for projects that retool, repower, repurpose or replace energy infrastructure that has ceased operations or projects that reduce operational emissions of existing energy infrastructure (for a detailed description see Appendix A), providing the opportunity not only for emissions reductions but also for reinvestment in energy communities. By lowering the cost of financing, the EIR creates more opportunities for oil and gas companies to reduce their operational emissions in the near term and more importantly, to transform their business models and advance the transition by pursuing eligible clean energy projects. This insight brief highlights examples of such opportunities.
Why apply for EIR financing and why now?
The ongoing high-interest rate environment makes investment in capital-intensive renewable energy projects more expensive. However, after a year of record oil and gas sector profits in 2022 and a resulting increase in cash availability and widespread deleveraging, coupled with substantial profits in 2023, oil and gas companies have more room on their balance sheets to invest in projects and take on more debt.
Through the Title XVII program (see Appendix A), the LPO offers loan guarantees and access to low-cost, long-tenor debt financing at or below commercial debt market rates. The loans provided through the program have a maximum tenor of 30 years, are priced at 37.5 basis points above Treasuries of the corresponding tenor, and can cover up to 80 percent of eligible project costs, with no ceiling on the project size and costs other than the program’s designated loan authority. Through the IRA, the EIR program was allocated $5 billion to cover the cost to government to provide up to $250 billion in lending for eligible projects, making it possible to finance large-scale energy infrastructure projects with meaningful emissions reductions impact.
Access to EIR financing combined with applicable IRA tax incentives make eligible projects more financially attractive while also providing economic and environmental benefit to local communities through the program’s focus on community benefit and mitigation of pollutants and emissions. More broadly, these IRA programs can help make a more robust internal business case for significant strategic investment of oil and gas company capital in pursuing emissions-reducing or clean energy projects. The EIR’s loan authority currently goes through September 2026 with loan disbursement possible through to 2031, making this a time-constrained opportunity and underscoring the need for companies to act quickly.
What are potential oil and gas sector transition activities that can be covered by EIR?
Potential oil and gas transition activities eligible for EIR financing cover upstream, midstream, and downstream activities, and could be broadly grouped into activities that accelerate the transition away from oil and gas and those that reduce the sector’s operational emissions in the near term.
Upstream:
Upstream oil and gas activities deal with petroleum exploration and production. The bulk of oil and gas value-chain methane emissions are from their upstream activities, making this a key segment to focus on for decarbonization.
Midstream:
The midstream sector is engaged primarily in the processing, transportation, storage, and trading of oil and natural gas.
Downstream:
The downstream oil and gas sector is responsible for crude oil refining, natural gas processing, petrochemical production, and the distribution and marketing of petroleum products. Downstream and end-use activities are significant contributors to the sector’s CO2
1. Activities that Accelerate the Transition Away from Oil and Gas
The transition activities discussed in this section would qualify for funding through EIR by being projects that would “retool, repower, repurpose, or replace energy infrastructure that has ceased operations.”
Transition activity
Position in oil & gas value chain
Applicable tax credits
Basis of EIR applicability
Lithium extraction from oilfield brine
Upstream
45X
Repurposing energy infrastructure that has ceased operations
Developing enhanced geothermal systems
Upstream
48E or 45Y
Repurposing energy infrastructure that has ceased operations
Repurposing offshore oil and gas infrastructure for offshore wind
Upstream
48E or 45Y
Repurposing energy infrastructure that has ceased operations
Remediating and repurposing abandoned onshore oil and gas fields and infrastructure for renewable energy and/or energy storage projects
Upstream
48E or 45Y, bonus adder for energy communities
Repurposing energy infrastructure that has ceased operations
Repurposing gas stations to build EV charging stations
Downstream
30C
Repurposing energy infrastructure that has ceased operations
Repurposing refineries for sustainable aviation fuel production
Downstream
40B (before 2025), 45Z (from 2025)
Repurposing energy infrastructure that has ceased operations
Upstream:
Lithium extraction from oilfield brine:
Lithium may be found in oilfield brine typically considered a liquid by-product of oil and gas drilling. Now, it yields the potential to be its own primary product. However, not all oil fields hold economical quantities. The amount and concentrations of lithium in brine vary by location and rock formation. If lithium extraction from oil field brine is successful at economical quantities, it would be a faster and cheaper production method than the more conventional hard rock mining and extraction from evaporation ponds. Some oil and gas companies have been involved in exploring the potential for oil field brine extraction as it relies on their core capability of drilling and because the market for lithium is significant and growing with the increase in demand for batteries for EVs, grid-scale batteries, and other applications.
The technology to extract lithium from brine—direct lithium extraction or DLE—is in its early stages and has not been applied on a commercial scale. However, pilot projects have been underway both within and outside the United States. Given the nascent stage of the extraction technology, other Title XVII funding geared toward innovative energy projects (section 1703) may be better suited. In instances where economical lithium concentrations have been identified and enabling infrastructure exists, such as in the Arkansas region of the Smackover rock formation, EIR funding may be applicable to repurposing pre-existing infrastructure. Additionally, the 45X Advanced Manufacturing Production tax credit would be applicable given lithium’s nature as a critical mineral. The environmental impact of DLE use on brine depends on a number of factors that would need to be assessed depending on the specific technology selected and the nature of its application.
Developing enhanced geothermal systems:
Enhanced geothermal systems (EGS) involve extracting geothermal resources in areas where stimulation (e.g., hydraulic fracturing) is required to develop the resource. Oil and gas companies have significant subsurface exploration and drilling expertise relevant to geothermal heat and power resource development.
In November 2023, Project Red, a 3.5 MW EGS pilot project plant developed by Fervo Energy and backed by Google, came online, demonstrating the technical feasibility of EGS. However, a number of challenges exist in deploying EGS, one of which is the economics. Right now, it is prohibitively expensive to generate electricity using the technology. So much so that the US Department of Energy, through its Enhanced Geothermal Shot initiative, has a goal of reducing the cost of EGS by 90% to $45/MWh by 2035. As more corporate buyers express demand for clean, firm power to meet renewable energy goals, a market for EGS-supplied clean firm power likely exists even at current prices.
Different financing options may be available depending on the nature of the project. Given the relative recency and innovativeness of EGS technology, section 1703 Innovative Energy Project financing could be applicable to a greenfield project. Where existing oil and gas fields and their associated equipment can be repurposed for EGS, EIR financing could be applicable. Additionally, the 48E or 45Y Clean Electricity tax credits would apply due to the clean electricity generation of the project.
Repurposing offshore oil and gas infrastructure for offshore wind:
Some of the infrastructure required in offshore drilling and offshore wind (ports, ships, platforms, etc.) overlap, creating an opportunity for a new business model for oil and gas companies. This model could take the form of setting up offshore wind turbines and selling power to electric utilities through long-term PPA contracts. The Gulf of Mexico is a hotbed for offshore oil and gas activity with the potential for harnessing offshore wind power (more than 100 GW of offshore wind by 2050) while also having the logisitical, manufacturing, transport, and skilled labor capabilities that could be translated to offshore wind. This makes it a potential region for this use case. To be eligible for EIR financing, these offshore projects could repurpose pre-existing oil and gas infrastructure that has ceased operations or through the use or upgrade of exisiting interconnections. Tax credits 48E or 45Y could be used to further enhance wind power project economics along with an additional energy community bonus credit for projects investing in port communities via port repurposing.
Additionally, other entities in the oil and gas sector that currently own ports and shipping infrastructure for oil and gas applications could be eligible for EIR funding through supporting the deployment of offshore wind, but also as part of the supply chain for domestic clean energy components. This expands the repurposing opportunity from the coasts further inland to infrastructure on inland waterways.
Remediating and repurposing abandoned onshore oil and gas fields and infrastructure for renewable energy and/or energy storage projects:
Abandoned oil and gas well brownfield sites could be remediated and repurposed with renewable energy projects. An example is the RenuWell project in Alberta, Canada, which seeks to remediate and repurpose with renewable energy-generating projects implemented by fossil fuel industry and Indigenous workers trained in an associated workforce training program. Abandoned oil wells may also be repurposed for energy storage, as demonstrated by Renewell — a US-based company using idle oil and gas wells for gravity energy storage.
Similar remediation and repurposing solutions would be a good use case for EIR financing because they combine repurposing, improving air quality through remediation of the site, and avoiding CO2 emissions by generating clean electricity. Renewable energy generating projects would also benefit from 45Y or 48E clean electricity tax credits, which could have an additional energy community bonus credit applied due to the use of a brownfield site.
Downstream
Repurposing gas stations to build electric vehicle (EV) charging stations:
As the share of electric cars sold increases, the need for more widely distributed charging infrastructure grows. In its 2024 energy transition strategy, Shell cited plans to build out its EV public charging infrastructure globally, noting its existing network of service stations as a competitive advantage. This highlights a potential kind of EIR-supported transition case applicable to downstream sector companies in the United States.
With the 30C tax credit and access to low-cost EIR debt financing, companies can more cost-effectively convert existing gas stations to commercial EV fast charging stations.
In addition to providing more quick and accessible electric vehicle charging, repurposed charging stations can serve as part of a virtual power plant network, providing additional economic benefit to project owners and helping to support grid reliability.
The environmental and surrounding community benefits are enhanced when the station to be repurposed is an abandoned one considered to be a petroleum brownfield. This creates an opportunity for site remediation where needed, as well as revenue-generating reuse of these abandoned sites.
Repurposing of refineries for sustainable aviation fuel (SAF) production:
Existing infrastructure in oil refineries can be reused and repurposed to produce sustainable aviation fuel and other biofuels. The requisite technology for SAF production and refinery conversions is proven and production expansion and conversion plans are underway within and outside the United States. Converting an oil refinery to a SAF refinery requires meaningful capital expenditures, which can be made more economical with the support of EIR’s low-cost financing and the 40B sustainable aviation fuel tax credit (before 2025) or the 45Z clean fuel production tax credit (from 2025 onward). A future additional revenue stream is also possible through the sale of sustainable aviation fuel certificates.
SAF production is an even more attractive opportunity for smaller refineries. With the most common biorefinery feedstock (HEFA) in limited supply, the economics are particularly favorable for smaller capacity refineries, which require less feedstock amount for SAF production.
Activities that Lower Existing Operational Emissions
The transition activities discussed in this section, by lowering operational emissions, would qualify for funding through EIR by being projects that would “enable operating energy infrastructure to avoid, reduce, utilize, or sequester air pollutants or anthropogenic emissions of greenhouse gases.” It is important to note that these activities are not aimed at perpetuating the business-as-usual operations of the oil and gas sector, but rather, the rapid near-term reduction of the sector’s emissions carried out in tandem with efforts to reduce oil and gas demand across end-use sectors.
Transition activity
Position in oil & gas value chain
Applicable tax credits
Basis of EIR applicability
Monitoring and mitigation of methane emissions
Cross-cutting
n/a, however there is a methane fee for applicable facilities
Avoiding and reducing air pollutants or emissions of operating energy infrastructure
Electrification of operations with renewable energy
Cross-cutting
48E or 45Y
Avoiding and reducing emissions of operating energy infrastructure
Switching from gray to green hydrogen
Downstream
45V
Reducing emissions of operating energy infrastructure
Cross-cutting value-chain
Monitoring and mitigation of methane emissions:
Technology and strategies to monitor and reduce oil and gas methane emissions exist and have been implemented in different locations globally. With broader deployment, they have the potential to reduce oil and gas methane emissions by over 75%. EIR could be used to finance technological strategies that minimize fugitive methane emissions leaks all along the oil and gas value chain. This includes strategies such as the replacement and upgrading of leak detection and repair systems and vapor recovery units as well as equipment for monitoring flare gas systems for quicker leak source detection. Gas flaring emits CO2 and other harmful air pollutants posing public health risks. For that reason, routine gas flaring is not recommended. States like Alaska and Colorado have prohibited routine flaring. Unlit and inefficient flares have the added negative impact of emitting significant amounts of methane. Therefore, being able to quickly identify sources of unlit and inefficient flares provides the added benefit of addressing them quickly and mitigating emissions and pollution impacts.
As an oil and gas company in the United States, mitigating methane emissions is also important from an operational cost perspective in the form of avoiding fees and fines. The IRA includes a methane fee per ton of emissions for qualifying petroleum facilities beginning in 2024.[1] Additionally, in a show of commitment to the Global Methane Pledge, in December 2023 at COP 28, the United States announced a final EPA methane rule with stricter requirements for natural gas flaring, methane monitoring, and leak prevention in the oil and gas sector. EIR financing could support compliance with this new rule through improving project economics by providing low-cost financing to drive down the cost of implementation of relevant technologies in the United States within the EPA’s requisite timeline.
Electrification of operations with renewable energy:
Oil and gas operations across the value chain can reduce their emissions intensity of operations that were previously powered by fossil fuel sources through electrification with renewable energy. Examples include electrification of upstream drilling operations (e.g., using solar steam for thermal recovery), electrification of pipelines (e.g., the use of natural gas compressor stations powered by renewable energy instead of fossil fuel generators), and the electrification of refinery processes (e.g., electrification of coker units, electric boilers, and other high heat intensive units). Electrification can be combined with cross-training staff to perform the renewable energy installations, thus providing an opportunity for additional economic benefit through workforce retention, making a stronger case for EIR eligibility.
Implementing electrification of oil and gas operations with renewable energy requires meaningful up-front capital expenditure investment, especially in the case of offshore upstream operations. Through low-cost debt financing and the potential for higher project debt to equity ratio, EIR offers oil and gas companies the opportunity to drive down the costs of implementing electrification, improving operational efficiency and reducing emissions in the near term. EIR financing can also be combined with the 48E Clean Electricity Investment tax credit or the 45Y Clean Electricity Production Tax credit to further drive down project costs. An example of oil field electrification in action includes the Lost Hills oil field in Southern California which has 80% of its operations powered by a 29 MW solar plant developed by Chevron and SunPower.
Downstream
Switching from gray to green hydrogen:
One method by which oil refineries could reduce their emissions is by switching from gray to green hydrogen. Hydrogen is an essential input in the oil refining process (e.g., in desulfurizing oil and gas products). The hydrogen currently used in refineries is predominantly produced from natural gas without CO2 capture (i.e., gray hydrogen). To further reduce emissions, gray hydrogen could be replaced with green hydrogen produced using renewable energy on site. To generate green hydrogen, electrolyzers powered by renewable energy would take the place of steam methane reformers used in producing gray hydrogen. Producing green hydrogen requires significant up-front investment in the electrolyzer as well as the renewable array required to power it.
EIR financing allows for higher leverage as well as a lower cost and longer tenor debt financing. Therefore, EIR combined with the 45V clean hydrogen production tax credit would help improve the economics for such a project. Additionally, as the market for green hydrogen grows through its future use in harder-to-abate sectors of the economy, refinery operations could fully convert to green hydrogen production. This would lead to a new green hydrogen-reliant revenue stream.
Conclusion
In the current high-interest rate environment, the EIR presents a unique opportunity for oil and gas companies to invest in energy transition projects while reducing the sector’s operational emissions, giving a new life to aging or abandoned infrastructure, or exploring new renewable energy-focused business models. The transition activities mentioned in this brief have the potential to not only help the sector transition away from oil and gas and lower operation emissions but also to bring economic and environmental benefits to the local community.
The EIR program’s loan authority currently goes through September 2026, making this a time-constrained opportunity for companies to apply for financing.
Appendix A: Title XVII and The Energy Infrastructure Reinvestment Program (EIR)
Under Title XVII of the 2005 Energy Policy Act, the DOE Loan Program’s Office (LPO) was granted the authority to provide loan guarantees for clean energy deployment and energy infrastructure reinvestment projects in the United States. Through the program, the LPO can make long-term senior debt more accessible to projects that experience difficulty in obtaining commercial financing on attractive terms. The Title XVII program is applicable to projects at different stages of deployment from first-of-a-kind to established and larger scale.
What are the criteria for project eligibility under Title XVII?
As listed in the Program Guidance for Title XVII Clean Energy Financing Program, all Title XVII projects must meet the criteria of:
- Being an energy-related project located in the United States
- Demonstrating significant and credible greenhouse gas or air pollution avoidance, reduction, utilization, or sequestration that will be achieved through the project activity
- Having a reasonable prospect of loan repayment
- Involving technically viable and commercially ready technology
- Including analysis of the project’s impact on affected communities and a plan for engagement with those communities
- Not benefiting from other federal support that is restricted under the Title XVII program
In 2022, the Inflation Reduction Act (IRA) established the Energy Infrastructure Reinvestment program as an addition to the Department of Energy’s Title XVII loan program authority.
In addition to meeting the Title XVII loan program’s criteria for project eligibility, EIR-eligible projects are required to either:
- Retool, repower, repurpose, or replace American energy infrastructure that has ceased operations.
- Enable energy infrastructure in operation to avoid, reduce, utilize, or sequester air pollutants or anthropogenic greenhouse gas emissions.
How is energy infrastructure defined under EIR?
In the context of EIR, energy infrastructure is defined as “a facility, and associated equipment, used for (1) the generation or transmission of electric energy; or (2) the production, processing, and delivery of fossil fuels, fuels derived from petroleum, or petrochemical feedstocks.”
For projects involving energy infrastructure that has ceased operations, the following additional criteria must be met:
- The replacement needs to be sited at or near the original infrastructure location, and a link needs to be demonstrated between the benefits of the original and those of the replacement infrastructures (e.g., grid capacity and workforce retention).
- Any electricity generation project powered by fossil fuels must include controls or technologies to avoid, reduce, utilize, or sequester pollutants and emissions.
Note, however, that unlike other authorities under Title XVII, these projects are not subject to the requirement that they be “innovative,” opening the door for the program to finance projects that deploy or use commercially available technologies to reinvest in energy communities across the country.
Appendix B: Applicable IRA Tax Credits for Listed Transition Activities
What are some applicable tax credits for transition activities?
Below is a list of tax credits for energy projects that are relevant to the oil and gas transition activities that are covered in this piece. It is important to note that there are rules around how these credits can be stacked. Additionally, certain tax credits are eligible for incremental increases if prevailing wage and apprenticeship requirements or domestic content requirements are met or if the project is sited in an energy community.
Tax Credit
Description
30C
Alternative Fuel Vehicle Refueling Property Credit
A tax credit for alternative fuel vehicle refueling property in low-income community and non-urban census tracts.
40B
Sustainable Aviation Fuel Credit
A tax credit for the sale or use of sustainable aviation fuel with lifecycle emissions reductions of at least 50% compared to petroleum-based jet fuel (viable only before 2025).
45Z
Clean Fuel Production Credit
A tax credit for the production of low-emission transportation fuels (including sustainable aviation fuel). Applicable beginning in 2025.
45V
Clean Hydrogen Production Tax Credit
A tax credit that may be applied to qualified clean hydrogen projects.
45X
Advanced Manufacturing Production Credit
A tax credit for domestic manufacturing of clean energy components of solar, wind, batteries, and critical minerals.
48C
Advanced Energy Project Credit
A tax credit that may be applied to investment in qualified advanced energy projects (e.g., one that “re-equips, expands or establishes an industrial or a manufacturing facility for the production or recycling of specified advanced energy property.” )
45Y
Clean Electricity Production Tax Credit
A technology-neutral tax credit for qualifying facilities producing clean electricity. Applicable beginning in 2025.
48E
Clean Electricity Investment Tax Credit
A technology-neutral tax credit for investment in qualifying facilities producing clean electricity. Applicable beginning in 2025.
The Energy Infrastructure Reinvestment (EIR) program of the Loan Program Office (LPO), coupled with Inflation Reduction Act (IRA) tax incentives, provides a unique and time-sensitive opportunity for the US oil and gas sector to accelerate its transition toward cleaner sources of energy and away from oil and gas.
Through the EIR, the LPO can provide financing for projects that retool, repower, repurpose or replace energy infrastructure that has ceased operations or projects that reduce operational emissions of existing energy infrastructure (for a detailed description see Appendix A), providing the opportunity not only for emissions reductions but also for reinvestment in energy communities. By lowering the cost of financing, the EIR creates more opportunities for oil and gas companies to reduce their operational emissions in the near term and more importantly, to transform their business models and advance the transition by pursuing eligible clean energy projects. This insight brief highlights examples of such opportunities.
The ongoing high-interest rate environment makes investment in capital-intensive renewable energy projects more expensive. However, after a year of record oil and gas sector profits in 2022 and a resulting increase in cash availability and widespread deleveraging, coupled with substantial profits in 2023, oil and gas companies have more room on their balance sheets to invest in projects and take on more debt.
Through the Title XVII program (see Appendix A), the LPO offers loan guarantees and access to low-cost, long-tenor debt financing at or below commercial debt market rates. The loans provided through the program have a maximum tenor of 30 years, are priced at 37.5 basis points above Treasuries of the corresponding tenor, and can cover up to 80 percent of eligible project costs, with no ceiling on the project size and costs other than the program’s designated loan authority. Through the IRA, the EIR program was allocated $5 billion to cover the cost to government to provide up to $250 billion in lending for eligible projects, making it possible to finance large-scale energy infrastructure projects with meaningful emissions reductions impact.
Access to EIR financing combined with applicable IRA tax incentives make eligible projects more financially attractive while also providing economic and environmental benefit to local communities through the program’s focus on community benefit and mitigation of pollutants and emissions. More broadly, these IRA programs can help make a more robust internal business case for significant strategic investment of oil and gas company capital in pursuing emissions-reducing or clean energy projects. The EIR’s loan authority currently goes through September 2026 with loan disbursement possible through to 2031, making this a time-constrained opportunity and underscoring the need for companies to act quickly.
What are potential oil and gas sector transition activities that can be covered by EIR?
Potential oil and gas transition activities eligible for EIR financing cover upstream, midstream, and downstream activities, and could be broadly grouped into activities that accelerate the transition away from oil and gas and those that reduce the sector’s operational emissions in the near term.
Upstream:
Upstream oil and gas activities deal with petroleum exploration and production. The bulk of oil and gas value-chain methane emissions are from their upstream activities, making this a key segment to focus on for decarbonization.
Midstream:
The midstream sector is engaged primarily in the processing, transportation, storage, and trading of oil and natural gas.
Downstream:
The downstream oil and gas sector is responsible for crude oil refining, natural gas processing, petrochemical production, and the distribution and marketing of petroleum products. Downstream and end-use activities are significant contributors to the sector’s CO2
1. Activities that Accelerate the Transition Away from Oil and Gas
The transition activities discussed in this section would qualify for funding through EIR by being projects that would “retool, repower, repurpose, or replace energy infrastructure that has ceased operations.”
Transition activity
Position in oil & gas value chain
Applicable tax credits
Basis of EIR applicability
Lithium extraction from oilfield brine
Upstream
45X
Repurposing energy infrastructure that has ceased operations
Developing enhanced geothermal systems
Upstream
48E or 45Y
Repurposing energy infrastructure that has ceased operations
Repurposing offshore oil and gas infrastructure for offshore wind
Upstream
48E or 45Y
Repurposing energy infrastructure that has ceased operations
Remediating and repurposing abandoned onshore oil and gas fields and infrastructure for renewable energy and/or energy storage projects
Upstream
48E or 45Y, bonus adder for energy communities
Repurposing energy infrastructure that has ceased operations
Repurposing gas stations to build EV charging stations
Downstream
30C
Repurposing energy infrastructure that has ceased operations
Repurposing refineries for sustainable aviation fuel production
Downstream
40B (before 2025), 45Z (from 2025)
Repurposing energy infrastructure that has ceased operations
Upstream:
Lithium extraction from oilfield brine:
Lithium may be found in oilfield brine typically considered a liquid by-product of oil and gas drilling. Now, it yields the potential to be its own primary product. However, not all oil fields hold economical quantities. The amount and concentrations of lithium in brine vary by location and rock formation. If lithium extraction from oil field brine is successful at economical quantities, it would be a faster and cheaper production method than the more conventional hard rock mining and extraction from evaporation ponds. Some oil and gas companies have been involved in exploring the potential for oil field brine extraction as it relies on their core capability of drilling and because the market for lithium is significant and growing with the increase in demand for batteries for EVs, grid-scale batteries, and other applications.
The technology to extract lithium from brine—direct lithium extraction or DLE—is in its early stages and has not been applied on a commercial scale. However, pilot projects have been underway both within and outside the United States. Given the nascent stage of the extraction technology, other Title XVII funding geared toward innovative energy projects (section 1703) may be better suited. In instances where economical lithium concentrations have been identified and enabling infrastructure exists, such as in the Arkansas region of the Smackover rock formation, EIR funding may be applicable to repurposing pre-existing infrastructure. Additionally, the 45X Advanced Manufacturing Production tax credit would be applicable given lithium’s nature as a critical mineral. The environmental impact of DLE use on brine depends on a number of factors that would need to be assessed depending on the specific technology selected and the nature of its application.
Developing enhanced geothermal systems:
Enhanced geothermal systems (EGS) involve extracting geothermal resources in areas where stimulation (e.g., hydraulic fracturing) is required to develop the resource. Oil and gas companies have significant subsurface exploration and drilling expertise relevant to geothermal heat and power resource development.
In November 2023, Project Red, a 3.5 MW EGS pilot project plant developed by Fervo Energy and backed by Google, came online, demonstrating the technical feasibility of EGS. However, a number of challenges exist in deploying EGS, one of which is the economics. Right now, it is prohibitively expensive to generate electricity using the technology. So much so that the US Department of Energy, through its Enhanced Geothermal Shot initiative, has a goal of reducing the cost of EGS by 90% to $45/MWh by 2035. As more corporate buyers express demand for clean, firm power to meet renewable energy goals, a market for EGS-supplied clean firm power likely exists even at current prices.
Different financing options may be available depending on the nature of the project. Given the relative recency and innovativeness of EGS technology, section 1703 Innovative Energy Project financing could be applicable to a greenfield project. Where existing oil and gas fields and their associated equipment can be repurposed for EGS, EIR financing could be applicable. Additionally, the 48E or 45Y Clean Electricity tax credits would apply due to the clean electricity generation of the project.
Repurposing offshore oil and gas infrastructure for offshore wind:
Some of the infrastructure required in offshore drilling and offshore wind (ports, ships, platforms, etc.) overlap, creating an opportunity for a new business model for oil and gas companies. This model could take the form of setting up offshore wind turbines and selling power to electric utilities through long-term PPA contracts. The Gulf of Mexico is a hotbed for offshore oil and gas activity with the potential for harnessing offshore wind power (more than 100 GW of offshore wind by 2050) while also having the logisitical, manufacturing, transport, and skilled labor capabilities that could be translated to offshore wind. This makes it a potential region for this use case. To be eligible for EIR financing, these offshore projects could repurpose pre-existing oil and gas infrastructure that has ceased operations or through the use or upgrade of exisiting interconnections. Tax credits 48E or 45Y could be used to further enhance wind power project economics along with an additional energy community bonus credit for projects investing in port communities via port repurposing.
Additionally, other entities in the oil and gas sector that currently own ports and shipping infrastructure for oil and gas applications could be eligible for EIR funding through supporting the deployment of offshore wind, but also as part of the supply chain for domestic clean energy components. This expands the repurposing opportunity from the coasts further inland to infrastructure on inland waterways.
Remediating and repurposing abandoned onshore oil and gas fields and infrastructure for renewable energy and/or energy storage projects:
Abandoned oil and gas well brownfield sites could be remediated and repurposed with renewable energy projects. An example is the RenuWell project in Alberta, Canada, which seeks to remediate and repurpose with renewable energy-generating projects implemented by fossil fuel industry and Indigenous workers trained in an associated workforce training program. Abandoned oil wells may also be repurposed for energy storage, as demonstrated by Renewell — a US-based company using idle oil and gas wells for gravity energy storage.
Similar remediation and repurposing solutions would be a good use case for EIR financing because they combine repurposing, improving air quality through remediation of the site, and avoiding CO2 emissions by generating clean electricity. Renewable energy generating projects would also benefit from 45Y or 48E clean electricity tax credits, which could have an additional energy community bonus credit applied due to the use of a brownfield site.
Downstream
Repurposing gas stations to build electric vehicle (EV) charging stations:
As the share of electric cars sold increases, the need for more widely distributed charging infrastructure grows. In its 2024 energy transition strategy, Shell cited plans to build out its EV public charging infrastructure globally, noting its existing network of service stations as a competitive advantage. This highlights a potential kind of EIR-supported transition case applicable to downstream sector companies in the United States.
With the 30C tax credit and access to low-cost EIR debt financing, companies can more cost-effectively convert existing gas stations to commercial EV fast charging stations.
In addition to providing more quick and accessible electric vehicle charging, repurposed charging stations can serve as part of a virtual power plant network, providing additional economic benefit to project owners and helping to support grid reliability.
The environmental and surrounding community benefits are enhanced when the station to be repurposed is an abandoned one considered to be a petroleum brownfield. This creates an opportunity for site remediation where needed, as well as revenue-generating reuse of these abandoned sites.
Repurposing of refineries for sustainable aviation fuel (SAF) production:
Existing infrastructure in oil refineries can be reused and repurposed to produce sustainable aviation fuel and other biofuels. The requisite technology for SAF production and refinery conversions is proven and production expansion and conversion plans are underway within and outside the United States. Converting an oil refinery to a SAF refinery requires meaningful capital expenditures, which can be made more economical with the support of EIR’s low-cost financing and the 40B sustainable aviation fuel tax credit (before 2025) or the 45Z clean fuel production tax credit (from 2025 onward). A future additional revenue stream is also possible through the sale of sustainable aviation fuel certificates.
SAF production is an even more attractive opportunity for smaller refineries. With the most common biorefinery feedstock (HEFA) in limited supply, the economics are particularly favorable for smaller capacity refineries, which require less feedstock amount for SAF production.
Activities that Lower Existing Operational Emissions
The transition activities discussed in this section, by lowering operational emissions, would qualify for funding through EIR by being projects that would “enable operating energy infrastructure to avoid, reduce, utilize, or sequester air pollutants or anthropogenic emissions of greenhouse gases.” It is important to note that these activities are not aimed at perpetuating the business-as-usual operations of the oil and gas sector, but rather, the rapid near-term reduction of the sector’s emissions carried out in tandem with efforts to reduce oil and gas demand across end-use sectors.
Transition activity
Position in oil & gas value chain
Applicable tax credits
Basis of EIR applicability
Monitoring and mitigation of methane emissions
Cross-cutting
n/a, however there is a methane fee for applicable facilities
Avoiding and reducing air pollutants or emissions of operating energy infrastructure
Electrification of operations with renewable energy
Cross-cutting
48E or 45Y
Avoiding and reducing emissions of operating energy infrastructure
Switching from gray to green hydrogen
Downstream
45V
Reducing emissions of operating energy infrastructure
Cross-cutting value-chain
Monitoring and mitigation of methane emissions:
Technology and strategies to monitor and reduce oil and gas methane emissions exist and have been implemented in different locations globally. With broader deployment, they have the potential to reduce oil and gas methane emissions by over 75%. EIR could be used to finance technological strategies that minimize fugitive methane emissions leaks all along the oil and gas value chain. This includes strategies such as the replacement and upgrading of leak detection and repair systems and vapor recovery units as well as equipment for monitoring flare gas systems for quicker leak source detection. Gas flaring emits CO2 and other harmful air pollutants posing public health risks. For that reason, routine gas flaring is not recommended. States like Alaska and Colorado have prohibited routine flaring. Unlit and inefficient flares have the added negative impact of emitting significant amounts of methane. Therefore, being able to quickly identify sources of unlit and inefficient flares provides the added benefit of addressing them quickly and mitigating emissions and pollution impacts.
As an oil and gas company in the United States, mitigating methane emissions is also important from an operational cost perspective in the form of avoiding fees and fines. The IRA includes a methane fee per ton of emissions for qualifying petroleum facilities beginning in 2024.[1] Additionally, in a show of commitment to the Global Methane Pledge, in December 2023 at COP 28, the United States announced a final EPA methane rule with stricter requirements for natural gas flaring, methane monitoring, and leak prevention in the oil and gas sector. EIR financing could support compliance with this new rule through improving project economics by providing low-cost financing to drive down the cost of implementation of relevant technologies in the United States within the EPA’s requisite timeline.
Electrification of operations with renewable energy:
Oil and gas operations across the value chain can reduce their emissions intensity of operations that were previously powered by fossil fuel sources through electrification with renewable energy. Examples include electrification of upstream drilling operations (e.g., using solar steam for thermal recovery), electrification of pipelines (e.g., the use of natural gas compressor stations powered by renewable energy instead of fossil fuel generators), and the electrification of refinery processes (e.g., electrification of coker units, electric boilers, and other high heat intensive units). Electrification can be combined with cross-training staff to perform the renewable energy installations, thus providing an opportunity for additional economic benefit through workforce retention, making a stronger case for EIR eligibility.
Implementing electrification of oil and gas operations with renewable energy requires meaningful up-front capital expenditure investment, especially in the case of offshore upstream operations. Through low-cost debt financing and the potential for higher project debt to equity ratio, EIR offers oil and gas companies the opportunity to drive down the costs of implementing electrification, improving operational efficiency and reducing emissions in the near term. EIR financing can also be combined with the 48E Clean Electricity Investment tax credit or the 45Y Clean Electricity Production Tax credit to further drive down project costs. An example of oil field electrification in action includes the Lost Hills oil field in Southern California which has 80% of its operations powered by a 29 MW solar plant developed by Chevron and SunPower.
Downstream
Switching from gray to green hydrogen:
One method by which oil refineries could reduce their emissions is by switching from gray to green hydrogen. Hydrogen is an essential input in the oil refining process (e.g., in desulfurizing oil and gas products). The hydrogen currently used in refineries is predominantly produced from natural gas without CO2 capture (i.e., gray hydrogen). To further reduce emissions, gray hydrogen could be replaced with green hydrogen produced using renewable energy on site. To generate green hydrogen, electrolyzers powered by renewable energy would take the place of steam methane reformers used in producing gray hydrogen. Producing green hydrogen requires significant up-front investment in the electrolyzer as well as the renewable array required to power it.
EIR financing allows for higher leverage as well as a lower cost and longer tenor debt financing. Therefore, EIR combined with the 45V clean hydrogen production tax credit would help improve the economics for such a project. Additionally, as the market for green hydrogen grows through its future use in harder-to-abate sectors of the economy, refinery operations could fully convert to green hydrogen production. This would lead to a new green hydrogen-reliant revenue stream.
Conclusion
In the current high-interest rate environment, the EIR presents a unique opportunity for oil and gas companies to invest in energy transition projects while reducing the sector’s operational emissions, giving a new life to aging or abandoned infrastructure, or exploring new renewable energy-focused business models. The transition activities mentioned in this brief have the potential to not only help the sector transition away from oil and gas and lower operation emissions but also to bring economic and environmental benefits to the local community.
The EIR program’s loan authority currently goes through September 2026, making this a time-constrained opportunity for companies to apply for financing.
Appendix A: Title XVII and The Energy Infrastructure Reinvestment Program (EIR)
Under Title XVII of the 2005 Energy Policy Act, the DOE Loan Program’s Office (LPO) was granted the authority to provide loan guarantees for clean energy deployment and energy infrastructure reinvestment projects in the United States. Through the program, the LPO can make long-term senior debt more accessible to projects that experience difficulty in obtaining commercial financing on attractive terms. The Title XVII program is applicable to projects at different stages of deployment from first-of-a-kind to established and larger scale.
What are the criteria for project eligibility under Title XVII?
As listed in the Program Guidance for Title XVII Clean Energy Financing Program, all Title XVII projects must meet the criteria of:
- Being an energy-related project located in the United States
- Demonstrating significant and credible greenhouse gas or air pollution avoidance, reduction, utilization, or sequestration that will be achieved through the project activity
- Having a reasonable prospect of loan repayment
- Involving technically viable and commercially ready technology
- Including analysis of the project’s impact on affected communities and a plan for engagement with those communities
- Not benefiting from other federal support that is restricted under the Title XVII program
In 2022, the Inflation Reduction Act (IRA) established the Energy Infrastructure Reinvestment program as an addition to the Department of Energy’s Title XVII loan program authority.
In addition to meeting the Title XVII loan program’s criteria for project eligibility, EIR-eligible projects are required to either:
- Retool, repower, repurpose, or replace American energy infrastructure that has ceased operations.
- Enable energy infrastructure in operation to avoid, reduce, utilize, or sequester air pollutants or anthropogenic greenhouse gas emissions.
How is energy infrastructure defined under EIR?
In the context of EIR, energy infrastructure is defined as “a facility, and associated equipment, used for (1) the generation or transmission of electric energy; or (2) the production, processing, and delivery of fossil fuels, fuels derived from petroleum, or petrochemical feedstocks.”
For projects involving energy infrastructure that has ceased operations, the following additional criteria must be met:
- The replacement needs to be sited at or near the original infrastructure location, and a link needs to be demonstrated between the benefits of the original and those of the replacement infrastructures (e.g., grid capacity and workforce retention).
- Any electricity generation project powered by fossil fuels must include controls or technologies to avoid, reduce, utilize, or sequester pollutants and emissions.
Note, however, that unlike other authorities under Title XVII, these projects are not subject to the requirement that they be “innovative,” opening the door for the program to finance projects that deploy or use commercially available technologies to reinvest in energy communities across the country.
Appendix B: Applicable IRA Tax Credits for Listed Transition Activities
What are some applicable tax credits for transition activities?
Below is a list of tax credits for energy projects that are relevant to the oil and gas transition activities that are covered in this piece. It is important to note that there are rules around how these credits can be stacked. Additionally, certain tax credits are eligible for incremental increases if prevailing wage and apprenticeship requirements or domestic content requirements are met or if the project is sited in an energy community.
Tax Credit
Description
30C
Alternative Fuel Vehicle Refueling Property Credit
A tax credit for alternative fuel vehicle refueling property in low-income community and non-urban census tracts.
40B
Sustainable Aviation Fuel Credit
A tax credit for the sale or use of sustainable aviation fuel with lifecycle emissions reductions of at least 50% compared to petroleum-based jet fuel (viable only before 2025).
45Z
Clean Fuel Production Credit
A tax credit for the production of low-emission transportation fuels (including sustainable aviation fuel). Applicable beginning in 2025.
45V
Clean Hydrogen Production Tax Credit
A tax credit that may be applied to qualified clean hydrogen projects.
45X
Advanced Manufacturing Production Credit
A tax credit for domestic manufacturing of clean energy components of solar, wind, batteries, and critical minerals.
48C
Advanced Energy Project Credit
A tax credit that may be applied to investment in qualified advanced energy projects (e.g., one that “re-equips, expands or establishes an industrial or a manufacturing facility for the production or recycling of specified advanced energy property.” )
45Y
Clean Electricity Production Tax Credit
A technology-neutral tax credit for qualifying facilities producing clean electricity. Applicable beginning in 2025.
48E
Clean Electricity Investment Tax Credit
A technology-neutral tax credit for investment in qualifying facilities producing clean electricity. Applicable beginning in 2025.
Potential oil and gas transition activities eligible for EIR financing cover upstream, midstream, and downstream activities, and could be broadly grouped into activities that accelerate the transition away from oil and gas and those that reduce the sector’s operational emissions in the near term.
Upstream:
Upstream oil and gas activities deal with petroleum exploration and production. The bulk of oil and gas value-chain methane emissions are from their upstream activities, making this a key segment to focus on for decarbonization.
Midstream:
The midstream sector is engaged primarily in the processing, transportation, storage, and trading of oil and natural gas.
Downstream:
The downstream oil and gas sector is responsible for crude oil refining, natural gas processing, petrochemical production, and the distribution and marketing of petroleum products. Downstream and end-use activities are significant contributors to the sector’s CO2
1. Activities that Accelerate the Transition Away from Oil and Gas
The transition activities discussed in this section would qualify for funding through EIR by being projects that would “retool, repower, repurpose, or replace energy infrastructure that has ceased operations.”
Transition activity | Position in oil & gas value chain | Applicable tax credits | Basis of EIR applicability |
---|---|---|---|
Lithium extraction from oilfield brine | Upstream | 45X | Repurposing energy infrastructure that has ceased operations |
Developing enhanced geothermal systems | Upstream | 48E or 45Y | Repurposing energy infrastructure that has ceased operations |
Repurposing offshore oil and gas infrastructure for offshore wind | Upstream | 48E or 45Y | Repurposing energy infrastructure that has ceased operations |
Remediating and repurposing abandoned onshore oil and gas fields and infrastructure for renewable energy and/or energy storage projects | Upstream | 48E or 45Y, bonus adder for energy communities | Repurposing energy infrastructure that has ceased operations |
Repurposing gas stations to build EV charging stations | Downstream | 30C | Repurposing energy infrastructure that has ceased operations |
Repurposing refineries for sustainable aviation fuel production | Downstream | 40B (before 2025), 45Z (from 2025) | Repurposing energy infrastructure that has ceased operations |
Upstream:
Lithium extraction from oilfield brine:
Lithium may be found in oilfield brine typically considered a liquid by-product of oil and gas drilling. Now, it yields the potential to be its own primary product. However, not all oil fields hold economical quantities. The amount and concentrations of lithium in brine vary by location and rock formation. If lithium extraction from oil field brine is successful at economical quantities, it would be a faster and cheaper production method than the more conventional hard rock mining and extraction from evaporation ponds. Some oil and gas companies have been involved in exploring the potential for oil field brine extraction as it relies on their core capability of drilling and because the market for lithium is significant and growing with the increase in demand for batteries for EVs, grid-scale batteries, and other applications.
The technology to extract lithium from brine—direct lithium extraction or DLE—is in its early stages and has not been applied on a commercial scale. However, pilot projects have been underway both within and outside the United States. Given the nascent stage of the extraction technology, other Title XVII funding geared toward innovative energy projects (section 1703) may be better suited. In instances where economical lithium concentrations have been identified and enabling infrastructure exists, such as in the Arkansas region of the Smackover rock formation, EIR funding may be applicable to repurposing pre-existing infrastructure. Additionally, the 45X Advanced Manufacturing Production tax credit would be applicable given lithium’s nature as a critical mineral. The environmental impact of DLE use on brine depends on a number of factors that would need to be assessed depending on the specific technology selected and the nature of its application.
Developing enhanced geothermal systems:
Enhanced geothermal systems (EGS) involve extracting geothermal resources in areas where stimulation (e.g., hydraulic fracturing) is required to develop the resource. Oil and gas companies have significant subsurface exploration and drilling expertise relevant to geothermal heat and power resource development.
In November 2023, Project Red, a 3.5 MW EGS pilot project plant developed by Fervo Energy and backed by Google, came online, demonstrating the technical feasibility of EGS. However, a number of challenges exist in deploying EGS, one of which is the economics. Right now, it is prohibitively expensive to generate electricity using the technology. So much so that the US Department of Energy, through its Enhanced Geothermal Shot initiative, has a goal of reducing the cost of EGS by 90% to $45/MWh by 2035. As more corporate buyers express demand for clean, firm power to meet renewable energy goals, a market for EGS-supplied clean firm power likely exists even at current prices.
Different financing options may be available depending on the nature of the project. Given the relative recency and innovativeness of EGS technology, section 1703 Innovative Energy Project financing could be applicable to a greenfield project. Where existing oil and gas fields and their associated equipment can be repurposed for EGS, EIR financing could be applicable. Additionally, the 48E or 45Y Clean Electricity tax credits would apply due to the clean electricity generation of the project.
Repurposing offshore oil and gas infrastructure for offshore wind:
Some of the infrastructure required in offshore drilling and offshore wind (ports, ships, platforms, etc.) overlap, creating an opportunity for a new business model for oil and gas companies. This model could take the form of setting up offshore wind turbines and selling power to electric utilities through long-term PPA contracts. The Gulf of Mexico is a hotbed for offshore oil and gas activity with the potential for harnessing offshore wind power (more than 100 GW of offshore wind by 2050) while also having the logisitical, manufacturing, transport, and skilled labor capabilities that could be translated to offshore wind. This makes it a potential region for this use case. To be eligible for EIR financing, these offshore projects could repurpose pre-existing oil and gas infrastructure that has ceased operations or through the use or upgrade of exisiting interconnections. Tax credits 48E or 45Y could be used to further enhance wind power project economics along with an additional energy community bonus credit for projects investing in port communities via port repurposing.
Additionally, other entities in the oil and gas sector that currently own ports and shipping infrastructure for oil and gas applications could be eligible for EIR funding through supporting the deployment of offshore wind, but also as part of the supply chain for domestic clean energy components. This expands the repurposing opportunity from the coasts further inland to infrastructure on inland waterways.
Remediating and repurposing abandoned onshore oil and gas fields and infrastructure for renewable energy and/or energy storage projects:
Abandoned oil and gas well brownfield sites could be remediated and repurposed with renewable energy projects. An example is the RenuWell project in Alberta, Canada, which seeks to remediate and repurpose with renewable energy-generating projects implemented by fossil fuel industry and Indigenous workers trained in an associated workforce training program. Abandoned oil wells may also be repurposed for energy storage, as demonstrated by Renewell — a US-based company using idle oil and gas wells for gravity energy storage.
Similar remediation and repurposing solutions would be a good use case for EIR financing because they combine repurposing, improving air quality through remediation of the site, and avoiding CO2 emissions by generating clean electricity. Renewable energy generating projects would also benefit from 45Y or 48E clean electricity tax credits, which could have an additional energy community bonus credit applied due to the use of a brownfield site.
Downstream
Repurposing gas stations to build electric vehicle (EV) charging stations:
As the share of electric cars sold increases, the need for more widely distributed charging infrastructure grows. In its 2024 energy transition strategy, Shell cited plans to build out its EV public charging infrastructure globally, noting its existing network of service stations as a competitive advantage. This highlights a potential kind of EIR-supported transition case applicable to downstream sector companies in the United States.
With the 30C tax credit and access to low-cost EIR debt financing, companies can more cost-effectively convert existing gas stations to commercial EV fast charging stations.
In addition to providing more quick and accessible electric vehicle charging, repurposed charging stations can serve as part of a virtual power plant network, providing additional economic benefit to project owners and helping to support grid reliability.
The environmental and surrounding community benefits are enhanced when the station to be repurposed is an abandoned one considered to be a petroleum brownfield. This creates an opportunity for site remediation where needed, as well as revenue-generating reuse of these abandoned sites.
Repurposing of refineries for sustainable aviation fuel (SAF) production:
Existing infrastructure in oil refineries can be reused and repurposed to produce sustainable aviation fuel and other biofuels. The requisite technology for SAF production and refinery conversions is proven and production expansion and conversion plans are underway within and outside the United States. Converting an oil refinery to a SAF refinery requires meaningful capital expenditures, which can be made more economical with the support of EIR’s low-cost financing and the 40B sustainable aviation fuel tax credit (before 2025) or the 45Z clean fuel production tax credit (from 2025 onward). A future additional revenue stream is also possible through the sale of sustainable aviation fuel certificates.
SAF production is an even more attractive opportunity for smaller refineries. With the most common biorefinery feedstock (HEFA) in limited supply, the economics are particularly favorable for smaller capacity refineries, which require less feedstock amount for SAF production.
Activities that Lower Existing Operational Emissions
The transition activities discussed in this section, by lowering operational emissions, would qualify for funding through EIR by being projects that would “enable operating energy infrastructure to avoid, reduce, utilize, or sequester air pollutants or anthropogenic emissions of greenhouse gases.” It is important to note that these activities are not aimed at perpetuating the business-as-usual operations of the oil and gas sector, but rather, the rapid near-term reduction of the sector’s emissions carried out in tandem with efforts to reduce oil and gas demand across end-use sectors.
Transition activity | Position in oil & gas value chain | Applicable tax credits | Basis of EIR applicability |
---|---|---|---|
Monitoring and mitigation of methane emissions | Cross-cutting | n/a, however there is a methane fee for applicable facilities | Avoiding and reducing air pollutants or emissions of operating energy infrastructure |
Electrification of operations with renewable energy | Cross-cutting | 48E or 45Y | Avoiding and reducing emissions of operating energy infrastructure |
Switching from gray to green hydrogen | Downstream | 45V | Reducing emissions of operating energy infrastructure |
Cross-cutting value-chain
Monitoring and mitigation of methane emissions:
Technology and strategies to monitor and reduce oil and gas methane emissions exist and have been implemented in different locations globally. With broader deployment, they have the potential to reduce oil and gas methane emissions by over 75%. EIR could be used to finance technological strategies that minimize fugitive methane emissions leaks all along the oil and gas value chain. This includes strategies such as the replacement and upgrading of leak detection and repair systems and vapor recovery units as well as equipment for monitoring flare gas systems for quicker leak source detection. Gas flaring emits CO2 and other harmful air pollutants posing public health risks. For that reason, routine gas flaring is not recommended. States like Alaska and Colorado have prohibited routine flaring. Unlit and inefficient flares have the added negative impact of emitting significant amounts of methane. Therefore, being able to quickly identify sources of unlit and inefficient flares provides the added benefit of addressing them quickly and mitigating emissions and pollution impacts.
As an oil and gas company in the United States, mitigating methane emissions is also important from an operational cost perspective in the form of avoiding fees and fines. The IRA includes a methane fee per ton of emissions for qualifying petroleum facilities beginning in 2024.[1] Additionally, in a show of commitment to the Global Methane Pledge, in December 2023 at COP 28, the United States announced a final EPA methane rule with stricter requirements for natural gas flaring, methane monitoring, and leak prevention in the oil and gas sector. EIR financing could support compliance with this new rule through improving project economics by providing low-cost financing to drive down the cost of implementation of relevant technologies in the United States within the EPA’s requisite timeline.
Electrification of operations with renewable energy:
Oil and gas operations across the value chain can reduce their emissions intensity of operations that were previously powered by fossil fuel sources through electrification with renewable energy. Examples include electrification of upstream drilling operations (e.g., using solar steam for thermal recovery), electrification of pipelines (e.g., the use of natural gas compressor stations powered by renewable energy instead of fossil fuel generators), and the electrification of refinery processes (e.g., electrification of coker units, electric boilers, and other high heat intensive units). Electrification can be combined with cross-training staff to perform the renewable energy installations, thus providing an opportunity for additional economic benefit through workforce retention, making a stronger case for EIR eligibility.
Implementing electrification of oil and gas operations with renewable energy requires meaningful up-front capital expenditure investment, especially in the case of offshore upstream operations. Through low-cost debt financing and the potential for higher project debt to equity ratio, EIR offers oil and gas companies the opportunity to drive down the costs of implementing electrification, improving operational efficiency and reducing emissions in the near term. EIR financing can also be combined with the 48E Clean Electricity Investment tax credit or the 45Y Clean Electricity Production Tax credit to further drive down project costs. An example of oil field electrification in action includes the Lost Hills oil field in Southern California which has 80% of its operations powered by a 29 MW solar plant developed by Chevron and SunPower.
Downstream
Switching from gray to green hydrogen:
One method by which oil refineries could reduce their emissions is by switching from gray to green hydrogen. Hydrogen is an essential input in the oil refining process (e.g., in desulfurizing oil and gas products). The hydrogen currently used in refineries is predominantly produced from natural gas without CO2 capture (i.e., gray hydrogen). To further reduce emissions, gray hydrogen could be replaced with green hydrogen produced using renewable energy on site. To generate green hydrogen, electrolyzers powered by renewable energy would take the place of steam methane reformers used in producing gray hydrogen. Producing green hydrogen requires significant up-front investment in the electrolyzer as well as the renewable array required to power it.
EIR financing allows for higher leverage as well as a lower cost and longer tenor debt financing. Therefore, EIR combined with the 45V clean hydrogen production tax credit would help improve the economics for such a project. Additionally, as the market for green hydrogen grows through its future use in harder-to-abate sectors of the economy, refinery operations could fully convert to green hydrogen production. This would lead to a new green hydrogen-reliant revenue stream.
In the current high-interest rate environment, the EIR presents a unique opportunity for oil and gas companies to invest in energy transition projects while reducing the sector’s operational emissions, giving a new life to aging or abandoned infrastructure, or exploring new renewable energy-focused business models. The transition activities mentioned in this brief have the potential to not only help the sector transition away from oil and gas and lower operation emissions but also to bring economic and environmental benefits to the local community.
The EIR program’s loan authority currently goes through September 2026, making this a time-constrained opportunity for companies to apply for financing.
Appendix A: Title XVII and The Energy Infrastructure Reinvestment Program (EIR)
Under Title XVII of the 2005 Energy Policy Act, the DOE Loan Program’s Office (LPO) was granted the authority to provide loan guarantees for clean energy deployment and energy infrastructure reinvestment projects in the United States. Through the program, the LPO can make long-term senior debt more accessible to projects that experience difficulty in obtaining commercial financing on attractive terms. The Title XVII program is applicable to projects at different stages of deployment from first-of-a-kind to established and larger scale.
What are the criteria for project eligibility under Title XVII?
As listed in the Program Guidance for Title XVII Clean Energy Financing Program, all Title XVII projects must meet the criteria of:
- Being an energy-related project located in the United States
- Demonstrating significant and credible greenhouse gas or air pollution avoidance, reduction, utilization, or sequestration that will be achieved through the project activity
- Having a reasonable prospect of loan repayment
- Involving technically viable and commercially ready technology
- Including analysis of the project’s impact on affected communities and a plan for engagement with those communities
- Not benefiting from other federal support that is restricted under the Title XVII program
In 2022, the Inflation Reduction Act (IRA) established the Energy Infrastructure Reinvestment program as an addition to the Department of Energy’s Title XVII loan program authority.
In addition to meeting the Title XVII loan program’s criteria for project eligibility, EIR-eligible projects are required to either:
- Retool, repower, repurpose, or replace American energy infrastructure that has ceased operations.
- Enable energy infrastructure in operation to avoid, reduce, utilize, or sequester air pollutants or anthropogenic greenhouse gas emissions.
How is energy infrastructure defined under EIR?
In the context of EIR, energy infrastructure is defined as “a facility, and associated equipment, used for (1) the generation or transmission of electric energy; or (2) the production, processing, and delivery of fossil fuels, fuels derived from petroleum, or petrochemical feedstocks.”
For projects involving energy infrastructure that has ceased operations, the following additional criteria must be met:
- The replacement needs to be sited at or near the original infrastructure location, and a link needs to be demonstrated between the benefits of the original and those of the replacement infrastructures (e.g., grid capacity and workforce retention).
- Any electricity generation project powered by fossil fuels must include controls or technologies to avoid, reduce, utilize, or sequester pollutants and emissions.
Note, however, that unlike other authorities under Title XVII, these projects are not subject to the requirement that they be “innovative,” opening the door for the program to finance projects that deploy or use commercially available technologies to reinvest in energy communities across the country.
Appendix B: Applicable IRA Tax Credits for Listed Transition Activities
What are some applicable tax credits for transition activities?
Below is a list of tax credits for energy projects that are relevant to the oil and gas transition activities that are covered in this piece. It is important to note that there are rules around how these credits can be stacked. Additionally, certain tax credits are eligible for incremental increases if prevailing wage and apprenticeship requirements or domestic content requirements are met or if the project is sited in an energy community.
Tax Credit
Description
30C
Alternative Fuel Vehicle Refueling Property Credit
A tax credit for alternative fuel vehicle refueling property in low-income community and non-urban census tracts.
40B
Sustainable Aviation Fuel Credit
A tax credit for the sale or use of sustainable aviation fuel with lifecycle emissions reductions of at least 50% compared to petroleum-based jet fuel (viable only before 2025).
45Z
Clean Fuel Production Credit
A tax credit for the production of low-emission transportation fuels (including sustainable aviation fuel). Applicable beginning in 2025.
45V
Clean Hydrogen Production Tax Credit
A tax credit that may be applied to qualified clean hydrogen projects.
45X
Advanced Manufacturing Production Credit
A tax credit for domestic manufacturing of clean energy components of solar, wind, batteries, and critical minerals.
48C
Advanced Energy Project Credit
A tax credit that may be applied to investment in qualified advanced energy projects (e.g., one that “re-equips, expands or establishes an industrial or a manufacturing facility for the production or recycling of specified advanced energy property.” )
45Y
Clean Electricity Production Tax Credit
A technology-neutral tax credit for qualifying facilities producing clean electricity. Applicable beginning in 2025.
48E
Clean Electricity Investment Tax Credit
A technology-neutral tax credit for investment in qualifying facilities producing clean electricity. Applicable beginning in 2025.
Under Title XVII of the 2005 Energy Policy Act, the DOE Loan Program’s Office (LPO) was granted the authority to provide loan guarantees for clean energy deployment and energy infrastructure reinvestment projects in the United States. Through the program, the LPO can make long-term senior debt more accessible to projects that experience difficulty in obtaining commercial financing on attractive terms. The Title XVII program is applicable to projects at different stages of deployment from first-of-a-kind to established and larger scale.
What are the criteria for project eligibility under Title XVII?
As listed in the Program Guidance for Title XVII Clean Energy Financing Program, all Title XVII projects must meet the criteria of:
- Being an energy-related project located in the United States
- Demonstrating significant and credible greenhouse gas or air pollution avoidance, reduction, utilization, or sequestration that will be achieved through the project activity
- Having a reasonable prospect of loan repayment
- Involving technically viable and commercially ready technology
- Including analysis of the project’s impact on affected communities and a plan for engagement with those communities
- Not benefiting from other federal support that is restricted under the Title XVII program
In 2022, the Inflation Reduction Act (IRA) established the Energy Infrastructure Reinvestment program as an addition to the Department of Energy’s Title XVII loan program authority.
In addition to meeting the Title XVII loan program’s criteria for project eligibility, EIR-eligible projects are required to either:
- Retool, repower, repurpose, or replace American energy infrastructure that has ceased operations.
- Enable energy infrastructure in operation to avoid, reduce, utilize, or sequester air pollutants or anthropogenic greenhouse gas emissions.
How is energy infrastructure defined under EIR?
In the context of EIR, energy infrastructure is defined as “a facility, and associated equipment, used for (1) the generation or transmission of electric energy; or (2) the production, processing, and delivery of fossil fuels, fuels derived from petroleum, or petrochemical feedstocks.”
For projects involving energy infrastructure that has ceased operations, the following additional criteria must be met:
- The replacement needs to be sited at or near the original infrastructure location, and a link needs to be demonstrated between the benefits of the original and those of the replacement infrastructures (e.g., grid capacity and workforce retention).
- Any electricity generation project powered by fossil fuels must include controls or technologies to avoid, reduce, utilize, or sequester pollutants and emissions.
Note, however, that unlike other authorities under Title XVII, these projects are not subject to the requirement that they be “innovative,” opening the door for the program to finance projects that deploy or use commercially available technologies to reinvest in energy communities across the country.
What are some applicable tax credits for transition activities?
Below is a list of tax credits for energy projects that are relevant to the oil and gas transition activities that are covered in this piece. It is important to note that there are rules around how these credits can be stacked. Additionally, certain tax credits are eligible for incremental increases if prevailing wage and apprenticeship requirements or domestic content requirements are met or if the project is sited in an energy community.
Tax Credit | Description | |
---|---|---|
30C | Alternative Fuel Vehicle Refueling Property Credit | A tax credit for alternative fuel vehicle refueling property in low-income community and non-urban census tracts. |
40B | Sustainable Aviation Fuel Credit | A tax credit for the sale or use of sustainable aviation fuel with lifecycle emissions reductions of at least 50% compared to petroleum-based jet fuel (viable only before 2025). |
45Z | Clean Fuel Production Credit | A tax credit for the production of low-emission transportation fuels (including sustainable aviation fuel). Applicable beginning in 2025. |
45V | Clean Hydrogen Production Tax Credit | A tax credit that may be applied to qualified clean hydrogen projects. |
45X | Advanced Manufacturing Production Credit | A tax credit for domestic manufacturing of clean energy components of solar, wind, batteries, and critical minerals. |
48C | Advanced Energy Project Credit | A tax credit that may be applied to investment in qualified advanced energy projects (e.g., one that “re-equips, expands or establishes an industrial or a manufacturing facility for the production or recycling of specified advanced energy property.” ) |
45Y | Clean Electricity Production Tax Credit | A technology-neutral tax credit for qualifying facilities producing clean electricity. Applicable beginning in 2025. |
48E | Clean Electricity Investment Tax Credit | A technology-neutral tax credit for investment in qualifying facilities producing clean electricity. Applicable beginning in 2025. |