The Fiscal Year 2027 (FY27) budget request for the Office of Energy Dominance Financing (EDF) (formerly the Loan Programs Office) tracks in a familiar direction to its prior request to Congress, and echoes Fiscal Year 2026 (FY26)-enacted levels in several areas. Much like last year’s request, the FY27 request reflects the administration’s continued prioritization of supporting certain sectors – notably, advanced nuclear, some baseload renewables, advanced fossil, grid infrastructure, and critical minerals - while seeking to eliminate the ability to support advanced vehicles manufacturing and supply chain projects and deprioritize support for renewable technologies.
EDF is currently a combination of several loan programs, including:
Innovative Energy and Innovative Supply Chain Programs (aka Title 17, Section 1703) supports first-of-a-kind and innovative energy and manufacturing projects that face barriers to private capital;
Energy Dominance Financing Program (aka Title 17, Section 1706) – confusingly also called the same name as the office itself – focuses on repurposing or replacing existing energy infrastructure and prioritizes capacity expansion, reliability, and domestic supply including critical minerals supply.1
Advanced Technology Vehicles Manufacturing (ATVM) Loan Program finances domestic vehicle and component manufacturing tied to advanced technology vehicles (including light-, medium-, and heavy-duty vehicles, locomotives, maritime vessels, and aviation) and related supply chain components.
Tribal Energy Financing Program (TEFP) (also known as the Tribal Energy Loan Guarantee Program) supports direct loans and partial loan guarantees for energy development projects for federally recognized Tribes and tribal energy development organizations.
Carbon Dioxide Transportation Infrastructure Finance and Innovation Program (CIFIA), authorized through the Infrastructure Investment and Jobs Act (IIJA), provides financing for carbon dioxide transport, storage, and related infrastructure.2
This post briefly walks through the main three budgetary items common across each program—administrative expenses, credit subsidy, and loan authority—and how the office fares in the FY27 Request, and provides observations about loan prioritization and portfolio risk from the Office of Management and Budget (OMB) Budget Appendix.
Administrative Expenses, and Anticipated Collections, Highlight Support for Title 17 Programs
Administrative expenses, like Program Direction subprogram lines in other program offices, support the federal staff and contractor labor that sustains the office’s operations. For EDF, administrative expenses support a range of outreach, origination, technical due diligence, portfolio monitoring, and legal and risk management functions across the office’s underwriting and credit review processes.
Because administrative expenses support staffing, they reflect the administration’s prioritization of activities across loan programs, as they indicate the extent of personnel hours that will be dedicated to administering the body of work.
Innovative Energy and Innovative Supply Chain Programs (Title 17, Section 1703) and the Energy Dominance Financing Program (Title 17, Section 1706): Remaining Active for FY27
Overall the proposed budget signals DOE intends Title 17 to remain active in FY27. The full-time employees (FTEs) supported by the proposed budget are proposed to increase in FY27 to 115, which is up from 80 in FY26 but still down from 128 in Fiscal Year 2025 (FY25). This figure does not account for contractor support staff. And the office signals funds are to be used to help obligate a combined $76 billion in Section 1703 and Section 1706 projects in FY27. The combination of this signal in the request and the healthy request for staffing, if appropriated, indicates DOE intends the office to be very active in Title 17 in the coming year.
Unlike the office’s other loan programs, Title 17 has the ability to charge and use fees collected from closed loans and maintenance fees to offset administrative expenses otherwise appropriated by Congress, provided the use of those funds is provided for those purposes in advance. This always has the effect of making the Title 17 administrative expenses budget look odd and not easy to understand.
In this case, the FY27 Budget is requesting $59.27 million in appropriated administrative expenses and anticipates more than fully offsetting that amount with about $69 million in offsetting collections, should Congress choose to support that level in advance in appropriations. While a drop in the amount the office expects to collect in fees from last year’s projections, this is more on par with the expected fees and funds used to support staff in prior [e.g. Fiscal Year 2025 (FY25) enacted] budgets.
Advanced Technology Vehicles Manufacturing: Reduced Levels of Administrative Expenses and FTEs
The picture is a lot different for the ATVM Loan Program, but this tracks with the administration’s posture from the prior fiscal year. Like last year, the FY27 request notes that “ATVM has primarily subsidized the financing of electric vehicle and related components manufacturing projects in a manner inconsistent with Executive Order 14154, Unleashing American Energy,” and uses that justification to keep ATVM administrative expenses flat with enacted levels at $9.5 million, focused on “portfolio monitoring” and “not […] originating or underwriting new loans.” ATVM FTEs are correspondingly held flat in FY27 at 20 (down from 39 FTEs in FY25 enacted).
ATVM saw the greatest real-world decrease in administrative expenses from FY25 to FY26 enacted levels (-27%) of any of the office’s programs—both TEFP and Title 17 on net were flat or saw increases. The lower request likely reflects a program posture focused on portfolio monitoring and no new origination and, possibly, because some relevant supply chain technologies such as critical minerals deals could flow instead through Title 17 programs.
To put this into perspective among recent requests and enacted figures, ATVM’s FY25 request for administrative expenses (from the last year of the prior administration) was $27.5 million; the FY25 House mark was $18 million, and the FY25 Senate mark was $20 million. Then the FY25 Continuing Resolution kept these figures flat at $13 million, a notable contrast from the original request. That level is now persisting (actually decreasing) across budgets. One open question is whether administrative expenses requested at these lower levels will continue to be sufficient going forward to monitor a portfolio of more than $37 billion in ATVM obligations to date.
Tribal Energy Financing Program (TEFP): Continued Status Quo
For TEFP, administrative expenses are continued at $2 million, up from $1 million in the FY26 request, but down from $6.3 million in FY26 enacted. Funds are focused on the “existing” portfolio and “limited outreach and origination activities.” This is a notable departure from the posture for qualifying Tribal applicants in the office’s prior year budget, which had proposed that Congress rescind unobligated credit subsidy and carryover administrative expense funds. Congress didn’t react well to that last year, providing marks that were flat with FY25, and the House Committee on Appropriations making clear it opposed “the closure of this important office” (p. 126). TEFP FTEs in the FY27 Request are flat with FY26 levels.
Credit Subsidy Proposed Changes Show Continued Support in Section 1703, No Support of ATVM
When the federal government issues loans or loan guarantees, it must calculate and budget for the expected cost of potential losses, known as the credit subsidy cost, which accounts for factors like default probability, recovery rates, and the time value of money. This mechanism is essential because it allows agencies like DOE, and its credit programs like EDF, to responsibly take on the financial risk inherent in high-impact energy lending, ensuring that expected losses are appropriated and budgeted for upfront.
Treatment of credit subsidy in the FY27 request offers other parallels to the FY26 budget request, with a requested increase in credit subsidies for nuclear energy (albeit smaller than the requested FY26 increase), some small rescissions requested for other technologies—and a very large rescission in the ATVM program.
New Credit Subsidy for Nuclear in Title 17 Programs
To meet strong applicant interest, the request proposes $200 million in new credit subsidy appropriation for nuclear, both small modular reactors (SMRs) and advanced reactors within Title 17 programs. At the credit subsidy rate (3.33%) estimated in the FY27 OMB credit supplement, this would be associated with at least $6 billion in loan authority obligated for projects (not accounting for projects where credit subsidy is closer to 0% or negative).
This is on top of $150 million from FY26 enacted for those purposes, effectively supported by a transfer of unobligated CIFIA appropriations from IIJA to Title 17. This reflects a moderated request from the FY26 budget, where $750 million was requested, to perhaps put this more in line with a figure Congress can stomach. Outside of nuclear, there is no other new appropriation called for in the other innovative Title 17 Section 1703 eligible technology categories, and the FY27 request repeats the office’s call from the FY26 budget for the rescission of a small amount of Section 1703 unobligated credit subsidy ($10.68 million) from prior appropriations that spans a few technology categories. Congress ultimately rejected that proposal.
ATVM Budget Proposal Would Functionally Prevent Any New Projects
In ATVM, for the policy reasons stated above, the request similarly repeats the request from the prior year to rescind all unobligated credit subsidy ($2.3 billion), which reflects the balance of available appropriations for ATVM since the One Big Beautiful Bill Act rescinded Inflation Reduction Act (IRA)-appropriated ATVM credit subsidy in 2025. Because ATVM loan authority remains uncapped post-IRA, bound only by the ability of credit subsidy available to stretch to new projects, a rescission of these balances would gut the ability of the program to do anything under ATVM short of monitoring the existing portfolio. Also, unlike Title 17, borrowers are not allowed to pay credit subsidy. Congress didn’t go along with that rescission last year. Because these funds were appropriated as emergency appropriations originally (see: Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009), they could only be repurposed in another emergency measure or by being reappropriated and carrying the “emergency requirement” language in a new appropriations act (as was the case for repurposing CIFIA dollars in FY26, discussed below). This means they’re likely not a good candidate for any actual savings if rescinded, though they are a perennial target for rescission to pay for other programs prioritized by appropriators.
As long as these credit subsidy balances persist, it remains an open question for policymakers as to how or when to utilize ATVM for deals moving forward, especially given that 1) its credit subsidy appropriations or loan authority aren’t time limited, like they are for some programs appropriated for in budget reconciliation measures, and 2) it is an uncapped program, as previously mentioned. It’s a flexible tool that could be used to support areas of bipartisan interest.
This represents a gap in DOE’s energy project finance toolkit, possibly due to the incorrect assumption that it can only support electric vehicle projects. In reality, it’s a supply chain program at its core, and even in spite of the current administration’s opposition to it, advances this administration’s critical minerals supply chain agenda. For example, Thacker Pass, one of ATVM’s largest critical minerals projects, has been a Trump administration priority since the president’s first term.
No New Credit Subsidy for Tribal, or Carbon Management Infrastructure Financing
Similarly to its adjusted posture for the Tribal Energy Financing Program administrative expenses, the office’s FY27 budget does not seek to rescind available Tribal credit subsidy. And the budget does not repeat the FY26 direction of “no new loan obligations.”
The Carbon Dioxide Transportation Infrastructure Finance and Innovation (CIFIA) Program doesn’t show up in annual budget requests since there has not been an appropriation outside of funds originally provided by IIJA. Where it does show up is in proposed rescissions. Because of the lack of loan activity through the program, it’s been a target of both Congress and the current administration for transfer or straight rescission, respectively. The FY27 request echoes its FY26 intent in canceling remaining unobligated balances ($588 million) (OMB Budget Appendix, p. 434). Instead of just rescinding those funds, Congress in FY26 repurposed $1.5 billion from CIFIA for nuclear (SMRs and Advanced Reactor Demonstration Program) and grid investments, and drew from these amounts for the $150 million in Title 17 credit subsidy for nuclear mentioned above. Short of actual projects coming to fruition, or some other creative use of these funds to get applicants in the pipeline, this could be the same posture Congress takes in FY27 with the remaining CIFIA unobligated balances.
Loan Authority Technology Restrictions Proposed
The FY27 budget request proposes new major restrictions to the Innovative Technology Loan Guarantee Program (Title 17, section 1703). The 1703 program was established and authorized to finance a large range of eligible technologies. Enacting the proposed changes on eligibility under 1703 financing authority, would undercut the administration’s ability to address emerging energy challenges while also handicapping its ability to partner with the private sector to regain U.S. energy technology leadership.
The only impact in the FY27 request on loan authority—again similar to the FY26 budget—is in Title 17 Section 1703. The FY27 budget repeats a request for $30 billion in new loan authority for a few Section 1703 categories (geothermal, hydropower, bioenergy, grid infrastructure, advanced fossil, advanced nuclear, refining, and critical minerals),3 while again calling for the cancellation of Section 1703 loan authority from FY07, FY09, FY11, and FY23—some of which was appropriated for specific technologies, like just renewable and energy efficiency projects, just nuclear, or just fossil.4 Cancellation of previous loan authority while providing a new loan limitation across a subset of eligible technology sectors would have the effect of barring 1703 debt from annual appropriations to hydrogen, storage, carbon capture and storage, industrial efficiency, and other renewable energy projects.
The net effect of the request, beyond messaging, is avoiding projects in some renewable energy areas, hydrogen, and carbon capture. But other technologies like nuclear, grid technologies, advanced fossil, and geothermal have been and continue to be projects in the applicant pipeline, or have had projects get underwritten.
However, the request if enacted wouldn’t limit projects in these or other sectors for consideration for Section 1703 or Section 1706 loan authority provided through the IRA, for which there are tens of billions of dollars or more than $100 billion in loan authority available, respectively. However, since the obligation of these funds is time limited by their reconciliation vehicles, the constraints on loan authority to certain sectors remains a ripe concern in the annual appropriations process.
“Federal Participation” in Title 17 Loans
One item to monitor for FY27 is language on “federal participation” in the office’s programs and whether there’s any budgetary impact. This phrase and $1 billion for these purposes showed up only in a budget table accompanying the FY26 conference report language (Joint Explanatory Statement, p. 195) and was not broken down in the FY26 budget request. “Federal participation” sounds like federal support, or funds that may have been signaled for use to cover the cost of federal support (e.g. federal offtake) in federal loan guarantees. This has typically come up in the nuclear context, including with other federal offtakers, like the Department of Defense, where scorekeepers including both OMB and the Congressional Budget Office have expressed concern about use of federal proceeds in paying some or all of a loan obligation’s repayments and how that would impact the score of the underlying budget authority, which otherwise is typically repaid by private borrowers.
There is common “federal support restriction” or “double dipping” language that serves as a guardrail against this practice today. As such, the potential additional cost of “federal participation” in a loan hasn’t been accounted for in this manner. It’s also notable that the both House and Senate energy and water development subcommittee marks were silent on this, as was the Joint Explanatory Statement’s recommendation, perhaps because of the longstanding prohibition on this practice.
It doesn’t appear to show up in the FY27 budget request at this stage, but will be something to continue to monitor as the FY27 request is socialized more with appropriators and works its way through Congress.
Budget Estimates Indicate Loan Portfolio is Carrying a Conservative Amount of Risk
Two last observations derive from observations from the OMB Appendix accompanying DOE’s FY27 budget request.
First, the General Fund receipt account estimates show a jump in FY27 Title 17 estimated negative subsidies ($355 million) over FY26 estimates ($157 million). FY26 estimates for negative subsidies jumped from last year’s estimate ($66 million) to this year’s estimate of $157 million as well. One theory for why this could be showing up is the relative creditworthiness of deals the office anticipates to originate in FY26 and FY27, which may carry less risk if they’re of the investor-owned utility variety, as we’ve started to see under Section 1706 in the current administration.
Second, these same receipt account estimates show both ATVM and Title 17 loans with healthy “downward reestimate” account balances. This effectively means the original risk premium attributed to these deals (through appropriated credit subsidy obligated at the time of obligation) was appropriate (maybe even conservative), that the risk is being managed, that repayments are better than expected, or that projects are performing within or better than the range of allowable risk attributable to their potential default—or a combination of these factors. Since they’re not needed, these funds are swept and returned to the General Fund, essentially lowering the cost of the USG providing those loans in the first place. This also could be an indicator that the program is taking too little risk—otherwise reestimates wouldn’t consistently appear to tick downwards, or may show a positive value.
The FY27 request makes the administration’s priorities clear: Title 17 remains open for business in sectors like nuclear, grid, advanced fossil, and critical minerals. For ATVM and Tribal, the posture is maintenance only, leaving substantial financing capacity on the table. Whether that untapped capacity gets a second look from Congress again, as it did in last year’s FY26 enacted energy and water appropriations, remains one of the more consequential open questions in DOE energy finance.
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This piece was drafted by trusted and vetted alumni of the U.S. Department of Energy. Any views and opinions expressed are that of the author(s) and do not reflect those of the DOE Alumni Network.
Note: while Section 1703 retains statutory requirements for innovativeness and avoided emissions, Section 1706 does not require innovation and, post-OBBBA, dropped emissions reduction requirements, among other changes.
Note: CIFIA historically has not requested a budget through the annual appropriations process, either for credit subsidy or administrative expenses, since it has relied to date on funds from the IIJA.
Note, the score for that appropriation would likely be 1% of the face value of the loan authority, or $300M, based on the Congressional Budget Office’s treatment of the FY26 Budget’s requested loan authority.