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Anu Khan is pushing carbon credits to better serve the public good.
There’s a new player in carbon removal. It’s not another startup building machines to suck carbon from the air. And it’s not another trade association or consulting firm or marketplace peddling carbon removal credits. Instead, it wants to help establish a different system for advancing carbon removal — one where the challenging but important goal of scrubbing CO2 from the atmosphere is treated as a public good and not just a business opportunity.
It’s called the Carbon Removal Standards Initiative, and it’s run by Anu Khan, the former deputy director of science and innovation at Carbon180. CRSI (pronounced like the Lannister queen in Game of Thrones, “Cersei”) is a “financially unconflicted, independent nonprofit,” that will provide technical assistance to policymakers, regulators, and nongovernmental organizations in quantifying carbon removal outcomes.
A group providing technical assistance may not sound like a revolutionary development. But Khan hopes CRSI will be a fulcrum around which the entire industry can begin to pivot.
Today’s carbon removal industry is built on selling credits, each of which is supposed to represent one ton of CO2 pulled out of the atmosphere. But the market is almost entirely self-regulated. The standards for measuring and reporting how much carbon a given project is removing have either been developed by the carbon credit registries that take a cut of the sales or by the developers themselves — in both cases a conflict of interest, even if governed by the best of intentions. Plus, there’s a multitude of standards for every type of project, and they vary in quality.
Take carbon farming, for example. If a farmer alters their practices to increase the carbon stored in their soil, they can choose from more than a dozen standards to quantify the effects. In theory, the standards all produce an identical product — a fungible carbon credit equivalent to one ton of carbon removed from the atmosphere. In reality, they vary widely in quality, with some standards producing more accurate results than others.
In watching this environment develop over the past several years, I’ve often wondered if some independent, unbiased entity might eventually step forward to enact one set of standards to rule them all. Khan told me that about a year and a half ago, she had the same thought. “Oh, to be so young,” she said.
At the time, there was growing concern that the carbon removal industry would suffer from the same credibility issues that plagued the wider market for carbon credits. “You have a multiplicity of these verification entities driven by profit motives, some of which have very loose standards,” Wil Burns, the co-executive director of the Institute for Carbon Removal Law and Policy at American University, told me. “From the standpoint of those purchasing credits or those viewing whether companies are doing anything meaningful, nobody can really distinguish.”
In early 2023, dozens of carbon removal suppliers, buyers, verifiers, academics, and nonprofit staff — including Khan — signed an open letter that now reads like an early draft of CRSI’s missions statement. It called for the creation of “an independent, not-for-profit initiative that conscientiously avoids conflicts of interest and has funding that does not depend on issuing or selling carbon credits.” This new body would “provide a trusted, scientific stamp of approval for CDR protocols through an inclusive process to identify scientific consensus.”
The letter focused on the issues with measuring carbon removal in the context of the voluntary sale of carbon credits. But over the next year, it became clear to Khan that carbon removal won’t reach the scale necessary to make a dent in climate change without government policy. “Even the market enthusiasts recognize that we’re going to need policy as quickly as possible to shore this up,” she said, “and it’s going to be policy, long term, that gets us to gigaton scale.”
So instead of providing “a trusted, scientific stamp of approval” to private businesses, CRSI is laser focused on working with policymakers. It’s not entirely clear yet what that will look like, and it’s likely to evolve as CRSI finds its footing. But the group is launching with a few projects that are already underway. It has created a database of “quantification resources,” which is basically a list of all of the methodologies published by companies, academics, government agencies, and international standards organizations, for measuring different kinds of carbon removal. It also has a database of carbon removal policies, both those enacted and proposed. Eventually, Khan plans to have them link out to each other, so you can see which standards underpin which policies.
Khan wants CRSI to be a go-to resource for policymakers and agency staff to ensure that carbon removal programs actually result in climate benefits. “We are fundamentally a mission organization,” she told me. “We believe that carbon removal is a tool for climate justice. Justice requires accountability, and in carbon removal, that means knowing how to count the carbon. We want to make sure that if we're putting public dollars into these policies, that they are backed by the ability to actually measure the carbon.”
Khan isn’t the only one whose thinking on standards has shifted toward a government-led approach. Burns, who also signed the letter, told me he’s seeing more carbon removal companies pushing for a compliance market, where the government requires polluting businesses to buy carbon removal. “They would like to both have government standards that would provide more confidence, for example, to investors,” he said, “and they would like government mandates that generate more demand.”
Freya Chay is the program lead at the nonprofit Carbon Plan, which spearheaded the letter. She told me many in the industry are now thinking about carbon removal programs that don’t revolve around selling credits at all, and therefore may have very different measurement and verification needs.
One of CRSI’s first projects is an illustrative example. Imagine if the Department of Agriculture developed a program to help farmers restore the pH of soils that have gotten too acidic, by adding basalt — a mineral that also happens to capture CO2 from the atmosphere as it dissolves. Today, carbon removal companies that sell carbon credits based on this process are taking hundreds of soil samples to measure the outcomes. The USDA likely wouldn’t need that level of precision — the captured CO2 is a co-benefit, not the entire point of the program — but “at some point you probably do want to know if you removed carbon through this policy,” said Khan. CRSI is working on figuring out how you would do that.
Similarly, we might see the development of building codes that encourage the use of concrete cured with CO2 from the atmosphere, or waste management regulations that govern the injection of carbon-rich organic waste into underground storage wells. Bigger picture, the U.S. will eventually have to measure and report how much carbon removal it’s doing across all of these little programs as part of its obligation under the Paris Agreement.
In many of these cases, those setting the rules won’t be experts in carbon removal science. “They’re going to need technical expertise,” said Khan. “We want to make sure that when they are doing that work, they have access to all of the relevant information, and that it’s organized in a way that’s legible for the expertise that they already have.”
Shuchi Talati, the former chief of staff in the office of fossil energy and carbon management at the Department of Energy, told me that having this kind of centralized resource would definitely have been useful. “The private sector has a lot of power right now in setting standards because the public sector doesn’t have the capacity,” she said. And since the field is so diverse, efforts are spread across a bunch of different agencies that don’t always talk to each other. Talati sits on the board of CRSI, and for her, the focus on government is not just about helping carbon removal scale.
“If we’re allowing the private sector to set standards and norms — and maybe they’re fine right now — but if we continue to let that happen, I can see the actual climate benefit of CDR slipping away,” Talati said. “That’s really where I see Anu’s organization fit in, where we are trying to set standards and norms from this core, foundational principle of a public good.”
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The rapid increase in demand for artificial intelligence is creating a seemingly vexing national dilemma: How can we meet the vast energy demands of a breakthrough industry without compromising our energy goals?
If that challenge sounds familiar, that’s because it is. The U.S. has a long history of rising to the electricity demands of innovative new industries. Our energy needs grew far more quickly in the four decades following World War II than what we are facing today. More recently, we have squared off against the energy requirements of new clean technologies that require significant energy to produce — most notably hydrogen.
Courtesy of Rhodium Group
The lesson we have learned time and again is that it is possible to scale technological innovation in a way that also scales energy innovation. Rather than accepting a zero-sum trade-off between innovation and our clean energy goals, we should focus on policies that leverage the growth of AI to scale the growth of clean energy.
At the core of this approach is the concept of additionality: Companies operating massive data centers — often referred to as “hyperscalers” — as well as utilities should have incentives to bring online new, additional clean energy to power new computing needs. That way, we leverage demand in one sector to scale up another. We drive innovation in key sectors that are critical to our nation’s competitiveness, we reward market leaders who are already moving in this direction with a stable, long-term regulatory framework for growth, and we stay on track to meet our nation’s climate commitments.
All of this is possible, but only if we take bold action now.
AI technologies have the potential to significantly boost America’s economic productivity and enhance our national security. AI also has the potential to accelerate the energy transition itself, from optimizing the electricity grid, to improving weather forecasting, to accelerating the discovery of chemicals and material breakthroughs that reduce reliance on fossil fuels. Powering AI, however, is itself incredibly energy intensive. Projections suggest that data centers could consume 9% of U.S. electricity generation by 2030, up from 4% today. Without a national policy response, this surge in energy demand risks increasing our long-term reliance on fossil fuels. By some estimates, around 20 gigawatts of additional natural gas generating capacity will come online by 2030, and coal plant retirements are already being delayed.
Avoiding this outcome will require creative focus on additionality. Hydrogen represents a particularly relevant case study here. It, too, is energy-intensive to produce — a single kilogram of hydrogen requires double the average household’s electricity consumption. And while hydrogen holds great promise to decarbonize parts of our economy, hydrogen is not per se good for our clean energy goals. Indeed, today’s fossil fuel-driven methods of hydrogen production generate more emissions than the entire aviation sector. While we can make zero-emissions hydrogen by using clean electricity to split hydrogen from water, the source of that electricity matters a lot. Similar to data centers, if the power for hydrogen production comes from the existing electricity grid, then ramping up electrolytic production of hydrogen could significantly increase emissions by growing overall energy demand without cleaning the energy mix.
This challenge led to the development of an “additionality” framework for hydrogen. The Inflation Reduction Act offers generous subsidies to hydrogen producers, but to qualify, they must match their electricity consumption with additional (read: newly built) clean energy generation close enough to them that they can actually use it.
This approach, which is being refined in proposed guidance from the U.S. Treasury Department, is designed to make sure that hydrogen’s energy demand becomes a catalyst for investment in new clean electricity generation and decarbonization technologies. Industry leaders are already responding, stating their readiness to build over 50 gigawatts of clean electrolyzer projects because of the long term certainty this framework provides.
While the scale and technology requirements are different, meeting AI’s energy needs presents a similar challenge. Powering data centers from the existing electricity grid mix means that more demand will create more emissions; even when data centers are drawing on clean electricity, if that energy is being diverted from existing sources rather than coming from new, additional clean electricity supply, the result is the same. Amazon’s recent $650 million investment in a data center campus next to an existing nuclear power plant in Pennsylvania illustrates the challenge: While diverting those clean electrons from Pennsylvania homes and businesses to the data center reduces Amazon’s reported emissions, by increasing demand on the grid without building additional clean capacity, it creates a need for new capacity in the region that will likely be met by fossil fuels (while also shifting up to $140 million of additional costs per year onto local customers).
Neither hyperscalers nor utilities should be expected to resolve this complex tension on their own. As with hydrogen, it is in our national interest to find a path forward.
What we need, then, is a national solution to make sure that as we expand our AI capabilities, we bring online new clean energy, as well, strengthening our competitive position in both industries and forestalling the economic and ecological consequences of higher electricity prices and higher carbon emissions.
In short, we should adopt a National AI Additionality Framework.
Under this framework, for any significant data center project, companies would need to show how they are securing new, additional clean power from a zero-emissions generation source. They could do this either by building new “behind-the-meter” clean energy to power their operations directly, or by partnering with a utility to pay a specified rate to secure new grid-connected clean energy coming online.
If companies are unwilling or unable to secure dedicated additional clean energy capacity, they would pay a fee into a clean deployment fund at the Department of Energy that would go toward high-value investments to expand clean electricity capacity. These could range from research and deployment incentives for so-called “clean firm electricity generation technologies like nuclear and geothermal, to investments in transmission capacity in highly congested areas, to expanding manufacturing capacity for supply-constrained electrical grid equipment like transformers, to cleaning up rural electric cooperatives that serve areas attractive to data centers. Given the variance in grid and transmission issues, the fund would explicitly approach its investment with a regional lens.
Several states operate similar systems: Under Massachusetts’ Renewable Portfolio Standard, utilities are required to provide a certain percentage of electricity they serve from clean energy facilities or pay an “alternative compliance payment” for every megawatt-hour they are short of their obligation. Dollars collected from these payments go toward the development and expansion of clean energy projects and infrastructure in the state. Facing increasing capacity constraints on the PJM grid, Pennsylvania legislators are now exploring a state Baseload Energy Development Fund to provide low-interest grants and loans for new electricity generation facilities.
A national additionality framework should not only challenge the industry to scale innovation in a way that scales clean technology, it must also clear pathways to build clean energy at scale. We should establish a dedicated fast-track approval process to move these clean energy projects through federal, state, and local permitting and siting on an accelerated basis. This will help companies already investing in additional clean energy to move faster and more effectively – and make it more difficult for anyone to hide behind the excuse that building new clean energy capacity is too hard or too slow. Likewise, under this framework, utilities that stand in the way of progress should be held accountable and incentivized to adopt innovative new technologies and business models that enable them to move at historic speed.
For hyperscalers committed to net-zero goals, this national approach provides both an opportunity and a level playing field — an opportunity to deliver on those commitments in a genuine way, and a reliable long-term framework that will reward their investments to make that happen. This approach would also build public trust in corporate climate accountability and diminish the risk that those building data centers in the U.S. stand accused of greenwashing or shifting the cost of development onto ratepayers and communities. The policy clarity of an additionality requirement can also encourage cutting edge artificial intelligence technology to be built here in the United States. Moreover, it is a model that can be extended to address other sectors facing growing energy demand.
The good news is that many industry players are already moving in this direction. A new agreement between Google and a Nevada utility, for example, would allow Google to pay a higher rate for 24/7 clean electricity from a new geothermal project. In the Carolinas, Duke Energy announced its intent to explore a new clean tariff to support carbon-free energy generation for large customers like Google and Microsoft.
A national framework that builds on this progress is critical, though it will not be easy; it will require quick Congressional action, executive leadership, and new models of state and local partnership. But we have a unique opportunity to build a strange bedfellow coalition to get it done – across big tech, climate tech, environmentalists, permitting reform advocates, and those invested in America’s national security and technology leadership. Together, this framework can turn a vexing trade-off into an opportunity. We can ensure that the hundreds of billions of dollars invested in building an industry of the future actually accelerates the energy transition, all while strengthening the U.S.’s position in innovating cutting- edge AI and clean energy technology.
Almost half of developers believe it is “somewhat or significantly harder to do” projects on farmland, despite the clear advantages that kind of property has for harnessing solar power.
The solar energy industry has a big farm problem cropping up. And if it isn’t careful, it’ll be dealing with it for years to come.
Researchers at SI2, an independent research arm of the Solar Energy Industries Association, released a study of farm workers and solar developers this morning that said almost half of all developers believe it is “somewhat or significantly harder to do” projects on farmland, despite the clear advantages that kind of property has for harnessing solar power.
Unveiled in conjunction with RE+, the largest renewable energy conference in the U.S., the federally-funded research includes a warning sign that permitting is far and away the single largest impediment for solar developers trying to build projects on farmland. If this trend continues or metastasizes into a national movement, it could indefinitely lock developers out from some of the nation’s best land for generating carbon-free electricity.
“If a significant minority opposes and perhaps leads to additional moratoria, [developers] will lose a foot in the door for any future projects,” Shawn Rumery, SI2’s senior program director and the survey lead, told me. “They may not have access to that community any more because that moratoria is in place.”
SI2’s research comes on the heels of similar findings from Heatmap Pro. A poll conducted for the platform last month found 70% of respondents who had more than 50 acres of property — i.e. the kinds of large landowners sought after by energy developers — are concerned that renewable energy “takes up farmland,” by far the greatest objection among that cohort.
Good farmland is theoretically perfect for building solar farms. What could be better for powering homes than the same strong sunlight that helps grow fields of yummy corn, beans and vegetables? And there’s a clear financial incentive for farmers to get in on the solar industry, not just because of the potential cash in letting developers use their acres but also the longer-term risks climate change and extreme weather can pose to agriculture writ large.
But not all farmers are warming up to solar power, leading towns and counties across the country to enact moratoria restricting or banning solar and wind development on and near “prime farmland.” Meanwhile at the federal level, Republicans and Democrats alike are voicing concern about taking farmland for crop production to generate renewable energy.
Seeking to best understand this phenomena, SI2 put out a call out for ag industry representatives and solar developers to tell them how they feel about these two industries co-mingling. They received 355 responses of varying detail over roughly three months earlier this year, including 163 responses from agriculture workers, 170 from solar developers as well as almost two dozen individuals in the utility sector.
A key hurdle to development, per the survey, is local opposition in farm communities. SI2’s publicity announcement for the research focuses on a hopeful statistic: up to 70% of farmers surveyed said they were “open to large-scale solar.” But for many, that was only under certain conditions that allow for dual usage of the land or agrivoltaics. In other words, they’d want to be able to keep raising livestock, a practice known as solar grazing, or planting crops unimpeded by the solar panels.
The remaining percentage of farmers surveyed “consistently opposed large-scale solar under any condition,” the survey found.
“Some of the messages we got were over my dead body,” Rumery said.
Meanwhile a “non-trivial” number of solar developers reported being unwilling or disinterested in adopting the solar-ag overlap that farmers want due to the increased cost, Rumery said. While some companies expect large portions of their business to be on farmland in the future, and many who responded to the survey expect to use agrivoltaic designs, Rumery voiced concern at the percentage of companies unwilling to integrate simultaneous agrarian activities into their planning.
In fact, Rumery said some developers’ reticence is part of what drove him and his colleagues to release the survey while at RE+.
As we discussed last week, failing to address the concerns of local communities can lead to unintended consequences with industry-wide ramifications. Rumery said developers trying to build on farmland should consider adopting dual-use strategies and focus on community engagement and education to avoid triggering future moratoria.
“One of the open-ended responses that best encapsulated the problem was a developer who said until the cost of permitting is so high that it forces us to do this, we’re going to continue to develop projects as they are,” he said. “That’s a cold way to look at it.”
Meanwhile, who is driving opposition to solar and other projects on farmland? Are many small farm owners in rural communities really against renewables? Is the fossil fuel lobby colluding with Big Ag? Could building these projects on fertile soil really impede future prospects at crop yields?
These are big questions we’ll be tackling in far more depth in next week’s edition of The Fight. Trust me, the answers will surprise you.
Here are the most notable renewable energy conflicts over the past week.
1. Worcester County, Maryland –Ocean City is preparing to go to court “if necessary” to undo the Bureau of Ocean Energy Management’s approval last week of U.S. Wind’s Maryland Offshore Wind Project, town mayor Rick Meehan told me in a statement this week.
2. Magic Valley, Idaho – The Lava Ridge Wind Project would be Idaho’s biggest wind farm. But it’s facing public outcry over the impacts it could have on a historic site for remembering the impact of World War II on Japanese residents in the United States.
3. Kossuth County, Iowa – Iowa’s largest county – Kossuth – is in the process of approving a nine-month moratorium on large-scale solar development.
Here’s a few more hotspots I’m watching…