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Utilities in the Southeast, especially, may have to rethink.
Utilities all over the country have proposed to build a slew of new natural gas-fired power plants in recent months, citing an anticipated surge in electricity demand from data centers, manufacturing, and electric vehicles. But on Thursday, the Environmental Protection Agency finalized new emissions limits on power plants that throw many of those plans into question.
The rules require that newly built natural gas plants that are designed to help meet the grid’s daily, minimum needs, will have to slash their carbon emissions by 90% by 2032, an amount that can only be achieved with the use of carbon capture equipment. But carbon capture will be cost-prohibitive in many cases — especially in the Southeast, where much of that expected demand growth is concentrated, but which lacks the geology necessary to store captured carbon underground.
“With this rule, it’s kind of back to square one,” Tyler Norris, an electric power systems researcher, told me. “I think most likely, you're gonna see the regulators really push back and call upon them to redo all their modeling.”
This is the first federal mandate to curb carbon from the electricity sector since President Obama’s 2015 Clean Power Plan, which never went into effect. Despite growing investment in renewable energy, power generation is responsible for about a quarter of the country’s greenhouse gas emissions.
The Biden administration is guaranteed to face legal challenges from Republican attorneys general and electric utilities. The Edison Electric Institute, the largest trade group for electric utilities, asserted that carbon capture “is not yet ready for full-scale, economy-wide deployment” and expressed worry over the timelines for permitting and financing. Duke Energy, one of the Southeast’s largest utilities, issued a statement after the rule came out saying that it “presents significant challenges to customer reliability and affordability – as well as limits the potential of our ability to be a global leader in chips, artificial intelligence and advanced manufacturing,” echoing concerns from the National Rural Electric Cooperative Association. The EPA, however, maintains that recent federal investments in carbon capture — including an $85 tax credit for every ton of CO2 captured and stored — render it both “technically feasible and cost-reasonable.”
As part of the same announcement on Thursday, the Environmental Protection Agency finalized several additional regulations to rein in air and water pollution from coal-fired power plants, including mercury and toxic metals, wastewater, and coal ash, in addition to carbon emissions. During a call with reporters on Wednesday, EPA administrator Michael Regan argued that by finalizing all of these rules at once, the agency was providing the highest degree of regulatory certainty for the power industry. “This approach is both strategic and innovative,” he said. “We are ensuring that the power sector has the information needed to prepare for the future with confidence, enabling strong investment and planning decisions.”
Initially the EPA was going to require emissions cuts at existing natural gas plants, too, but the agency announced in February that it was delaying that rule in order to develop a “stronger, more durable approach.” EPA officials offered no new details on the timeline on Wednesday.
The two other biggest changes the agency made between the proposed and final rules were to push forward and shorten the timeline for coal plant compliance, and to lower the threshold determining how many natural gas plants have to meet the toughest standard — which means more plants will have to control their emissions.
The agency projects the new standards will prevent a total of nearly 1.4 billion metric tons of carbon emissions through 2047, which is about equal to the amount the power sector emits in a year. That’s significant, but it’s far less than the clean car rules the EPA finalized in March, which are expected to avoid 7.2 billion metric tons of carbon between 2027 and 2055. The EPA also estimates that the power plant rules will produce $370 billion in climate and health benefits over the next two decades, in terms of avoided deaths, hospital visits, and asthma cases.
The new emissions limits for coal plants are tied to how much longer a given coal plant is slated to operate. Those that plan to shut down before 2032 are exempt altogether. Those that plan to retire by 2039 have to reduce the amount of CO2 they emit per megawatt hour by replacing some of the coal they burn with natural gas beginning in 2030. Coal plants with no plans to retire before 2039 are subject to the highest standard, requiring a 90% drop in emissions by 2032 — which would require capturing the emissions and storing them underground.
These standards are certain to lead to more plant closures, but coal plants are already shutting down at a rapid pace purely based on economics and the fact that so many of them are so old. Getting the rules in place is less about tackling coal emissions, per se, and more about “getting utilities thinking more proactive about how they are going to replace these coal plants,” Michelle Solomon, a senior policy advisor at the nonprofit think tank Energy Innovation, told me.
Gas, however, is another story. Utilities have been sounding the alarm about a coming surge in electricity demand. Electric companies throughout the Southeast, as well as Texas, Wisconsin, and elsewhere, have proposed building dozens of new natural gas plants, arguing that renewables and batteries aren’t up to the task of providing a reliable, dispatchable source of power.
Whether that coming demand is real or inflated is a matter of debate. But regardless, clean energy researchers and advocates dispute the idea that gas plants are needed for reliability.
“Utilities are seeing an additional need for peak capacity, not an additional need for capacity throughout the day,” Solomon told me, asserting it was possible to meet those peaks with solar and storage, or even by improving efficiency so that the peaks aren’t as high. The trick is making sure we can bring those resources online fast enough. To that end, the Department of Energy also announced a number of initiatives to boost transmission infrastructure on Thursday.
The EPA’s regulations for new gas plants are tied to how frequently they are intended to operate. Plants that are designed to switch on during times of peak demand — a variety called a “simple cycle” combustion turbine plant — won’t have to do anything differently. Plants that run a bit more often — so-called “intermediate” resources that might run daily from mid-morning till the evening, at 20% to 40% of their annual capacity — will be required to install the most efficient equipment available on the market. Any that operate more frequently than that will be subject to the 90% emissions reduction standard by 2032. This primarily affects “combined cycle” plants, which are more efficient than simple cycle but can’t ramp up and down as quickly or easily.
Utilities with recently hatched plans to build simple cycle plants, including Georgia Power, are unlikely to be affected by the rule at all. “I do think that makes sense, given the focus of these rules, which are on carbon emissions,” Amanda Levin, a director of policy analysis at the Natural Resources Defense Council, told me. “Given the frequency and type of operation for [simple cycle], they’re not as significant as sources of CO2.”
But those utilities that are planning to build combined cycle projects — and many of them are — could be forced to go back to the drawing board. Norris noted that Duke Energy, which serves customers in North and South Carolina and has proposed building more than 6 gigawatts of combined cycle capacity, will be especially exposed.
For combined cycle plants, there are essentially two options to comply: Install carbon capture, or plan to run your plant a lot less frequently. In either case, it “dramatically increases the levelized cost of those units,” Norris told me. “So I think any reasonable regulator would say we've got to go back and do a much more rigorous comparative analysis to other least-cost solutions.”
Solomon has a more cynical view of the recent panic over electricity demand and rush to build new gas plants. “We’ve known that demand is growing, is going to grow, for a long time,” she told me. “The fact that there’s quite a lot of news about this just as the rules are coming out is unlikely to be a total coincidence.”
Editor’s note: This story has been updated to reflect statements from Duke Energy and trade groups.
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The Ways and Means Committee released its proposed budget language, and it’s not pretty for clean energy.
The House Ways and Means Committee, which oversees tax policy, released its initial proposal to overhaul the nation’s clean energy tax credits on Monday afternoon. These are separate and in addition to the extensive cuts to Inflation Reduction Act grant programs proposed by the Energy and Commerce Committee, Transportation Committee, and Natural Resources Committee in the past few weeks.
Here’s a rundown of the tax credit proposal, which, at first glance, appears to amount to a back-door full repeal of the climate law. There’s a lot that could change before we get to a final budget, let alone have a text head to the Senate. We’ll have more analysis on what these changes would mean in the days and weeks to come.
The text proposes ending the tax credit for new EVs (that is, 30D) on December 31, 2025 — with one exception. The credit would remain in effect for one year, through the end of 2026, for vehicles produced by automakers that have sold fewer than 200,000 tax credit-qualified cars between 2010 and the end of this year. That means that no Teslas would qualify for the tax credit next year, as the company has sold far more than 200,000 tax credit-eligible vehicles. A new entrant to EVs, like Honda with its Prologue model, will likely still qualify.
The committee also proposes ending the tax credit for used EVs (25E) and commercial EVs (45W) by the end of this year. This would effectively end the “leasing loophole” that allowed Americans to redeem the tax credit on vehicles that didn’t qualify for 30D because they didn’t meet domestic content requirements, meaning consumers could get discounts on leases of a wide range of makes and models.
Lastly, the draft proposes terminating the tax credit for residential EV chargers (30C) at the end of this year.
The GOP has proposed an early phase-out of the technology-neutral production and investment tax credits, which subsidize zero-emissions power generation projects including wind, solar, energy storage, advanced nuclear, and geothermal. It also proposed significant changes for the years they remain in effect.
Currently, new clean electricity projects can earn a 2.75 cents for every kilowatt-hour they produce for the first 10 years under section 45Y of the tax code. Alternatively, project developers can get a 30% investment tax credit (48E) on new projects. The Inflation Reduction Act scheduled both of these programs to phase out beginning in 2032, and expire at the end of 2035. It included a major caveat, however: that this phase-out would only happen if greenhouse gas emissions from U.S. power generation fell below 25% of 2022 levels. Otherwise, the tax credits would be maintained at their initial amounts until this target was met.
Under the GOP proposal, both credits would start to phase down in 2029, and new projects would no longer be eligible for either credit beginning in 2032. The proposal also cuts out a key provision that would have grandfathered many more projects into the tax credit. Under current law, a project only has to start construction within a certain year to qualify for that year’s tax credit amount. The draft text changes this, requiring a project to be “placed in service” before 2032 in order to qualify.
A separate tax credit for existing nuclear power generation (45U) would also phase down on the same timeline, despite Trump and other Republicans’ interest in boosting nuclear energy.
“Transferability” supercharged the nation’s clean energy tax credits by allowing project developers with low tax liability to sell their credits to another entity that stood to benefit from them. Previously, developers could only monetize their unusable tax credits through complicated tax equity deals.
Recipients of a wide range of tax credits, including those for clean manufacturing, clean fuels, carbon capture, nuclear power, and hydrogen, can all take advantage of transferability. The provision channeled new capital into the climate economy as corporations looking to reduce their tax liability began scooping up tax credits, indirectly helping to finance clean energy projects. It also helped lower the cost of wind and solar, as developers could earn a premium on tax credits compared to what they got for tax equity transfers, because the whole transaction was cheaper to do.
The proposal would get rid of this option across all of the tax credits beginning in 2028.
The proposal would also impose new sourcing requirements across all of the tax credits, prohibiting developers from using components, subcomponents, or critical minerals sourced from “foreign entities of concern,” a term that applies to companies based in China, Russia, North Korea, or Iran. The consequences would be huge, as China dominates global markets for refined lithium, cobalt, graphite, and rare earths — key materials used in clean energy technologies.
The draft text would also terminate the clean manufacturing credit (45X) in 2032 — one year earlier than under existing law. Wind energy components such as blades, towers, and gearboxes would lose their eligibility sooner, in 2028.
The text proposes repealing three tax credits for residential energy efficiency improvements at the end of 2025. Starting next year, homeowners would no longer be able to claim the Energy Efficiency Home Improvement Credit (25C), which provides up to $3,200 per year for home energy audits, energy-saving windows and doors, air sealing and insulation, heat pumps, and new electrical panels.
It also proposes killing the Residential Clean Energy Credit (25D), which offered homeowners 30% off the cost of solar panels and battery systems to store energy from those solar panels. This credit also subsidizes geothermal home heating systems.
Both of these tax credits have existed in some form since the Energy Policy Act of 2005.
The third credit that would end this year is an up to $5,000 subsidy for contractors who construct new, energy efficient homes (45L).
The proposal would not repeal the energy efficiency tax deduction for improvements made to commercial buildings (179D).
The Inflation Reduction Act created a technology-neutral tax credit for low-carbon transportation fuels, like sustainable aviation fuel and biodiesel (45Z). It operates on a sliding scale, depending on how carbon-intensive the fuel is. The credit is set to expire after 2027, however the GOP proposal would extend it for four years, through the end of 2031.
That said, it would also make a significant change to how the credit is calculated, making it much easier for projects with questionable emissions benefits to qualify. Under the Biden administration, the Treasury Department issued rules that said producers had to account for the emissions tied to indirect land use changes resulting from fuel production. That meant that corn ethanol producers, for example, had to account for the expansion of croplands resulting from the increase of biofuel production and use — which would, in most cases, disqualify corn ethanol from claiming the tax credit. But under the GOP proposal, producers would explicitly not have to account for indirect land use changes.
The GOP proposal would deal a rapid and ruthless death blow to the 45V clean hydrogen production tax credit, requiring developers to begin construction before the end of this year if they want to claim it.
Other than ending transferability, the text makes no changes to the 45Q carbon capture and sequestration tax credit.
Most of the tax credits have provisions that allow project developers to qualify for higher amounts if they pay prevailing wages, hire apprentices, build in a qualified “energy community” or a low-income community, or use a certain percentage of domestically-produced materials. This initial draft from the GOP would not change any of those provisions.
The Energy and Commerce Committee dropped its budget proposal Sunday night.
Republicans on the House Committee on Energy and Commerce unveiled their draft budget proposal Sunday night, which features widespread cuts to the Inflation Reduction Act and other clean energy and environment programs.
The legislative language is part of the House’s reconciliation package, an emerging tax and spending bill that will seek to extend much of the 2017 Tax Cuts and Jobs Act, with reduced spending on the IRA and Medicaid helping to balance the budgetary scales.
The Energy and Commerce committee covers energy and environmental programs, while the Ways and Means Committee has jurisdiction over the core tax credits of the IRA that power much of America’s non-carbon power generation. Ways and Means has yet to release its draft budget proposal, which will be another major shoe to drop.
The core way the Energy and Commerce proposal generates budgetary savings is by proposing “rescissions” to existing programs, whereby unspent money would be yanked away.
The language also includes provisions to auction electromagnetic spectrum, as well as changes to Medicaid.Overall, the Congressional Budget Office told the committee, the recommendations would “reduce deficits by more than $880 billion” from 2025 to 2034, which was the target the committee was instructed to hit. The Sierra Club estimated that the cuts specifically to programs designed to help decarbonize heavy industry would add up to $1.6 billion.
The proposed rescissions would affect a number of energy financing and grant programs, including:
And that’s just the “energy” cuts. The language also includes a number of cuts to environmental programs, including:
Lastly, the proposal would also repeal federal tailpipe emission standards starting in the 2027 model year. These rules, which were finalized just last year, would have provided a major boost to the electric vehicle industry, perhaps pushing EV sales to over half of all new car sales by the beginning of the next decade. The language also repeals the latest gas-mileage standards, which were released last year and would have applied to the 2027 through 2031 model years, eventually bumping up miles-per-gallon industry-wide to over 50 by the 2031 model year.
What the Council on Foreign Relations’ new climate program gets drastically wrong.
Let’s start with two basic facts.
First, the climate crisis is here now, killing people, devastating communities, and destroying infrastructure in Los Angeles and Asheville and Spain and Pakistan and China. And it will get worse.
Second, Donald Trump is the President of the United States. He began the process to withdraw the United States from the Paris Agreement on January 20, 2025, his first day in office in his second term. (He, of course, did this in his first term as well.) He illegally froze funding for climate programs that had passed and became law during the Biden administration, and his administration continues to ignore court orders to unfreeze these monies. He has signed numerous executive orders, including onreinvigorating clean [sic] coal,reversing state-level climate policies, “Zero-based regulatory budgeting to unleash American energy,” and “unleashing” American energy, the last of which revoked more than a dozen Biden era executive orders.
How do we address a world that is increasingly shaped by these two facts?
One attempt can be seen in the Council on Foreign Relations’s new “Climate Realism Initiative.” Its statement of purpose attempts to make climate action palatable to MAGA world by securitizing it, framing climate change as a foreign threat to Fortress America. It calls for investing in next-generation technologies and geoengineering in the hopes of leapfrogging the Chinese-led clean energy revolution that is beginning to decarbonize the world today is the best realistic way forward.
This attempt is doomed to failure. Real climate realism for the United States is to stop the destruction of American state capacity, and then to reflect and build on areas of core strength including finance and software.
CRI’s launch document does not call for the U.S. to reduce its own emissions. I’ll say that again: There is no call for the U.S. to reduce its own emissions in the essay establishing the mission and objectives of the Climate Realism Initiative. Written by Varun Sivaram, formerly chief strategy and innovation officer at wind energy developer Orsted and now the leader of the initiative, the essay proposes that four dug-in “fallacies” are getting in the way of effective policy-making: that climate change “poses a manageable risk” to the U.S.; that “the world’s climate targets are achievable;” that the clean energy transition is a “win-in for U.S. interests and climate action;” and that “reducing U.S. domestic greenhouse gas emissions can make a meaningful difference.” For Sivaram, the problem is always other places and their emissions.
He then goes on to propose three “pillars” of climate realism: the need for America to prepare for a world “blowing through climate targets;” to “invest in globally competitive clean technology industries;” and to “lead international efforts to avert truly catastrophic climate change.” How an America that does not commit to reduce its own emissions will have any credibility or standing to lead international efforts is left unstated.
Sivaram attempts to trick the reader into overlooking America’s emissions by ignoring the facts of the past and focusing instead on guesses about the future. It’s true that in 2023, China produced more than a quarter of new global carbon pollution — more than the United States, Europe, and India combined. But no country has contributed more to the blanket of pollution that traps additional heat in our atmosphere than the United States, which has emitted over 430 billion tons of CO2, or 23% of the world’s total historical emissions. Even in 2023, the U.S. remained the world’s number two carbon polluter.
Sivaram goes further than merely minimizing the U.S. role in creating our current climate problems. Indeed, he sets up climate change as a problem that foreign countries are imposing on Americans. “Foreign emissions,” he writes, “are endangering the American homeland,” and the effects of climate disasters “resemble those if China or Indonesia were to launch missiles at the United States.” There is something to this rhetoric that is powerful — we should think about climate-induced disasters as serious threats and respond to them with the kind of resources that we lavish on the military industrial complex. But the idea that it is foreign emissions that are the primary source of this danger is almost Trumpian.
The initiatives proposed in the Climate Realism launch are the initiatives of giving up. Investing in resilience and adaptation is needed in any scenario, but tying this spending on adaptation to Trumpian notions of protecting our borders reeks of discredited lifeboat ethics, which only cares to save ourselves and leaves others to suffer for our sins. And while supporting next-generation technologies is an appropriate piece of the policy puzzle, they should be like the broccoli at a steakhouse: off to the side and mostly superfluous compared with the meat and potatoes of deployment and mitigation to decarbonize today.
Sivaram may argue that there’s no point in trying to compete against China in the technologies of today when Chinese firms are so dominant and apparently willing to make these products while earning minimal profits. And from a parochial profit-maximizing perspective, there is a business case that firms should not be building lots of new solar cell manufacturing facilities given global manufacturing capacity.
But if American automotive firms simply ignore the coming EV wave and hope against hope that some breakthrough in solid state batteries will allow them to leapfrog over the firms vying today, they are fooling themselves. Electric vehicle giant BYD and world-leading battery manufacturer CATL have both announced batteries that can charge a car in five minutes. Both are also moving in the solid state space, and CATL is pushing into sodium ion batteries.
The notion that U.S. firms ought to sit out this fight for strategic reasons also ignores how China has come to dominate these sectors — by investing in today’s state of the art and pushing it forward through incremental process improvements at scale. The Thielian notion that “competition is for losers” leads to an immense amount of waste as wannabe founders search for unbreakable technological advantages. If venture capitalists want to fund such bets, I’m not going to stop them. But as a policy prescription for climate realism, it fails.
The final gambit of the essay is to advocate for America-controlled geoengineering. This, too, is an area where research may be needed. But regardless, it is the kind of emergency backup plan that you hope that you never need to use, rather than something that should be central to anyone’s policy strategy. Trump is currently decimating American capacity to research hard problems, whether they be cancer or vaccines or social science or anything else, so it is difficult to imagine that this administration is likely to spend real resources to investigate geoengineering.
The Climate Realism Initiative pitches itself as “bipartisan.” But where is the MAGA coalition that supports this? Even simple spending on adaptation and resilience seems unlikely to find much of a political home given the Trump administration’s drastic cuts in weather and disaster forecasting. Sivaram even mentions the need to balance the budget as part of climate realism, which must be a sick joke. For all of the fanfare over cuts to the federal government under Trump, the budget deficit is the last thing that they care about. Tax cuts remain the coin of the realm, with the House budgetary guidelines expanding the deficit by $2.8 trillion. Elon Musk’s Department of Government Efficiency, similarly, has a distorted notion of government efficiency, ignoring the returns to government investments and gutting the tax collection capacity of the IRS.
The Biden administration had plans — “all of the above” energy among them — that were coherent, if not necessarily the most appealing to the world. They were based on the idea that a resilient climate coalition in the U.S. required more than just deploying Chinese-made products.
CRI seems to want to engage instead in a fantasy conversation where anti-Chinese nationalism can unite Americans to fight climate change — an all-form, no-content negative sum realpolitik that does little to address the real, compelling, and deeply political questions that the climate crisis poses.
Alternative visions are possible. The American economy is services based. Americans and American firms will inevitably make some of the hardware components of the energy transition, but the opportunities that play to our strengths are mostly on the software side.
It is critical to remember that the clean technologies that power the energy transition are categorically different from the fossil fuels that the world burned (and still burns) for energy. We do not require a constant stream of these technologies to operate our economy. The solar panels on your roof or in the field outside of town still generate electricity even if you can’t buy new ones because of a trade war. Same with wind turbines. In fact, renewables are a source of energy security because the generation happens from domestic natural resources — the sun and wind. Yet smart thinkers like Jake Sullivan fall into the trap of treating “dependence” on Chinese renewable technologies as analogous to European dependence on Russian natural gas.
Even China’s ban on U.S.-bound rare earth exports won’t make much of a dent. Despite the name, rare earths aren’t that rare, and while China does dominate their processing, it’s a tiny industry; in making fun of the “critical” nature of rare earths, Bloomberg opinion writer Javier Blas noted that the total imports of rare earths from China to the U.S. in 2024 was $170 million, or about 0.03% of U.S.-China trade. That being said, the major concern is if supplies fall to zero then major processes that require tiny amounts of rare earths (like Yttria and turbine construction) could be completely halted with serious fallout.
The American government should carefully choose what industries it would like to support. Commodity factories that have little-to-no profits, like solar cells, seem unattractive. There are many more jobs in installing solar than there are in manufacturing it, after all.
On the other hand, sectors with a much larger existing domestic industry, such as wind turbines and especially automobiles, should not be left to wither. But rather than a tariff wall to protect them, the U.S. auto firms should be encouraged to partner with the leading firms — even if those firms are Chinese — to build joint ventures in the American heartland, so that they and the American people can participate in the EV shift.
But the core of real climate realism for the United States is not about new factories. It’s about playing to our strengths. The United States has the best finance and technology sectors in the world, and these should be used to help decarbonize at home and around the world. This climate realism agenda can come in left- and right-wing flavors. A leftist vision is likely state-led with designs, guides, and plans, while the right-wing vision relies on markets.
Take Texas. On May 7, 2020, the Texas grid set a record with 21.4 gigawatts of renewable electricity generation. Just five years later, that figure hit 41.9 gigawatts. Solar and batteries have exploded on the grid, with capacity hitting 30 gigawatts and 10 gigawatts respectively. They have grown so rapidly because of the state’s market-based system, with its low barriers to interconnection and competitive dynamics.
Of course, not every location is blessed with as much wind, sun, and open space as Texas. But there’s no reason why its market systems can’t be a template for other states and countries. This, too, is industrial policy — not just the factory workers building the technologies or even the installers deploying them. There is lots of work for the lawyers and power systems engineers and advertisers and policy analysts and bankers and consultants, as well.
Yet instead of seizing these real chances to push climate action forward at home and abroad, the Trump administration is eviscerating American state capacity, the rule of law, and global trust in the government. The whipsawing of Trump’s tariffs generates uncertainty that undercuts investment. The destruction of government support for scientific exploration hits at the next-generation moonshots that Sivaram is so enamored of, as well as the institutions that educate our citizens and train our workforce. Trump’s blatant disregard for court orders and his regime’s cronyism undercut belief in the rule of law, and that investments will rise and fall based on their economics rather than how close they are to the President.
But it’s not just Trump. Texas legislators are on the verge of destroying the golden goose of cheap electricity through rapid renewables deployment out of a desire to own the libs. Despite the huge economic returns to rural communities that have seen so much utility-scale expansion in the state, some Republican legislators are pushing bills that would stick their fingers into the electricity market pie, undercutting the renewable expansion and mandating expensive gas expansion.
The Trump business coalition, which was mostly vibes in the first place, is fracturing. There are conflicting interests between those who want to fight inflation and those who see low oil prices as a problem. Pushing down oil prices by pressuring OPEC+ to pump more crude and depressing global economic outlooks with the trade war (Degrowth Donald!) has hurt the frackers in Texas. Ironically, one way to lower their costs is to electrify operations, so they don’t have to rely on expensive diesel.
Climate change is here, but so is Donald Trump. Ignoring either one is a recipe for disaster as they both create destructive whirlwinds and traffic in uncertainty. The real solution to both is mitigation — doing everything possible today to stop as much of the damage as possible before it happens.