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The Biden administration is hoping they’ll be a starting gun for the industry. The industry may or may not be fully satisfied.
In one of the Biden administration’s final acts to advance decarbonization, and after more than two years of deliberation and heated debate, the Treasury Department issued the final requirements governing eligibility for the clean hydrogen tax credit on Friday.
At up to $3 per kilogram of clean hydrogen produced, this was the most generous subsidy in the 2022 Inflation Reduction Act, and it came with significant risks if the Treasury did not get the rules right. Hydrogen could be an important tool to help decarbonize the economy. But without adequate guardrails, the tax credit could turn it into a shovel that digs the U.S. deeper into a warming hole by paying out billions of dollars to projects that increase emissions rather than reducing them.
In the final guidelines, the Biden administration recognized the severity of this risk. It maintained key safeguards from the rules proposed in 2023, while also making a number of changes, exceptions, and other “flexibilities” — in the preferred parlance of the Treasury Department — that sacrifice rigorous emissions accounting in favor of making the program easier to administer and take advantage of.
For example, it kept a set of requirements for hydrogen made from water and electricity known as the “three pillars.” Broadly, they compel producers to match every hour of their operation with simultaneous clean energy generation, buy this energy from newly built sources, and ensure those sources are in the same general region as the hydrogen plant. Hydrogen production is extremely energy-intensive, and the pillars were designed to ensure that it doesn’t end up causing coal and natural gas plants to run more. But the final rules are less strict than the proposal. For example, the hourly matching requirement doesn’t apply until 2030, and existing nuclear plants count as new zero-emissions energy if they are considered to be at risk of retirement.
Finding a balance between limiting emissions and ensuring that the tax credit unlocks development of this entirely new industry was a monumental challenge. The Treasury Department received more than 30,000 comments on the proposed rule, compared to about 2,000 for the clean electricity tax credit, and just 89 for the electric vehicle tax credit. Senior administration officials told me this may have been the most complicated of all of the provisions in the IRA. In October, the department assured me that the rules would be finished by the end of the year.
Energy experts, environmental groups, and industry are still digesting the rule, and I’ll be looking out for future analyses of the department’s attempt at compromise. But initial reactions have been cautiously optimistic.
On the environmental side, Dan Esposito from the research nonprofit Energy Innovation told me his first impression was that the final rule was “a clear win for the climate” and illustrated “overwhelming, irrefutable evidence” in favor of the three pillars approach, though he did have concerns about a few specific elements that I’ll get to in a moment. Likewise, Conrad Schneider, the U.S. senior director at the Clean Air Task Force, told me that with the exception of a few caveats, “we want to give this final rule a thumbs up.”
Princeton University researcher Jesse Jenkins, a co-host of Heatmap’s Shift Key podcast and a vocal advocate for the three pillars approach, told me by email that, “Overall, Treasury’s final rules represent a reasonable compromise between competing priorities and will provide much-needed certainty and a solid foundation for the growth of a domestic clean hydrogen industry.”
On the industry side, the Fuel Cell and Hydrogen Energy Association put out a somewhat cryptic statement. CEO Frank Wolak applauded the administration for making “significant improvements” but warned that the rules were “still extremely complex” and contain several open-ended parts that will be subject to interpretation by the incoming Trump-Vance administration.
“This issuance of Final Rules closes a long chapter, and now the industry can look forward to conversations with the new Congress and new Administration regarding how federal tax and energy policy can most effectively advance the development of hydrogen in the U.S.,” Wolak said.
Constellation Energy, the country’s biggest supplier of nuclear power, was among the most vocal critics of the proposed rule and had threatened to sue the government if it did not create a pathway for hydrogen plants that are powered by existing nuclear plants to claim the credit. In response to the final rule, CEO and President Joe Dominguez said he was “pleased” that the Treasury changed course on this and that the final rule was “an important step in the right direction.”
The California governor’s office, which had criticized the proposed rule, was also swayed. “The final rules create the certainty needed for developers to invest in and build clean, renewable hydrogen production projects in states like California,” Dee Dee Myers, the director of the Governor’s Office of Business and Economic Development, said in a statement. The state has plans to build a $12.6 billion hub for producing and using clean hydrogen.
Part of the reason the Treasury needed to find a Goldilocks compromise that pleased as many stakeholders as possible was to protect the rule from future lawsuits and lobbying. But not everyone got what they wanted. For example, the energy developer NextEra, pushed the administration to get rid of the hourly matching provision, which though delayed remained essentially untouched. NextEra did not respond to a request for comment.
Companies that fall on the wrong side of the final rules may still decide to challenge them in court. The next Congress could also make revisions to the underlying tax code, or the incoming Trump administration could change the rules to perhaps make them more favorable to hydrogen made from fossil fuels. But all of this would take time — a rule change, for example, would trigger a whole new notice and comment process. Though the one thing I’ve heard over and over is that the industry wants certainty, which the final rule provides, it’s not yet clear whether that will outweigh any remaining gripes.
In the meantime, it's off to the races for the nascent clean hydrogen industry. Between having clarity on the tax credit, the Department of Energy’s $7 billion hydrogen hubs grant program, and additional federal grants to drive down the cost of clean hydrogen, companies now have numerous incentives to start building the hydrogen economy that has received much hype but has yet to prove its viability. The biggest question now is whether producers will find any buyers for their clean hydrogen.
Below is a more extensive accounting of where the Treasury landed in the final rules.
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On “deliverability,” or the requirement to procure clean energy from the same region, the rules are largely unchanged, although they do allow for some flexibility on regional boundaries.
As I explained above, the Treasury Department also kept the hourly matching requirement, but delayed it by two years until 2030 to give the market more time to set up systems to achieve it — a change Schneider said was “really disappointing” due to the potential emissions consequences. Until then, companies only have to match their operations with clean energy on an annual basis, which is a common practice today. The new deadline is strict, and those that start operations before 2030 will not be grandfathered in — that is, they’ll have to switch to hourly matching once that extended clock runs out. In spite of that, the final rules also ensure that producers won’t be penalized if they are not able to procure clean energy for every single hour their plant operates, an update several groups applauded.
On the requirement to procure clean power from newly built sources, also known as “incrementality,” the department made much bigger changes. It kept an overarching definition that “incremental” generators are those built within three years of the hydrogen plant coming into service, but added three major exceptions:
1. If the hydrogen facility buys power from an existing nuclear plant that’s at risk of retirement.
2. If the hydrogen facility is in a state that has both a robust clean electricity standard and a broad, binding, greenhouse gas cap, such as a cap and trade system. Currently, only California and Washington pass this test.
3. If the hydrogen facility buys power from an existing natural gas or coal plant that has added new carbon capture and storage capacity within three years of the hydrogen project coming into service.
The hydrogen tax credit is so lucrative that environmental groups and energy analysts were concerned it would drive companies like Constellation to start selling all their nuclear power to hydrogen plants instead of to regular energy consumers, which could drive up prices and induce more fossil fuel emissions.
The final rules try to limit this possibility by only allowing existing reactors that are at risk of retirement to qualify. But the definition of “at risk of retirement” is loose. It includes “merchant” nuclear power plants — those that sell at least half their power on the wholesale electricity market rather than to regulated utilities — as well as plants that have just a single reactor, which the rules note have lower or more uncertain revenue and higher operational costs. Looking at the Nuclear Energy Institute’s list of plants, merchant plants make up roughly 40% of the total. All of Constellation Energy’s plants are merchant plants.
There are additional tests — the plant has to have had average annual gross receipts of less than 4.375 cents per kilowatt hour for at least two calendar years between 2017 and 2021. It also has to obtain a minimum 10-year power purchase agreement with the hydrogen company. Beyond that, the reactors that meet this definition are limited to selling no more than 200 megawatts to hydrogen companies, which is roughly 20% for the average reactor.
Esposito, who has closely analyzed the potential emissions consequences of using existing nuclear plants to power hydrogen production, was not convinced by the safeguards. “I don't love the power price look back,” he told me, “because that's not especially indicative of the future — particularly this high load growth future that we're quickly approaching with data centers and everything. It’s very possible power prices could go up from that, and then all of a sudden, the nuclear plants would have been fine without hydrogen.”
As for the 200 megawatt cap, Esposito said it was better than nothing, but he feels “it's kind of an implicit admission that it's not really, truly clean” to produce hydrogen with the energy from these nuclear plants.
Schneider, on the other hand, said the safeguards for nuclear-powered hydrogen projects were adequate. While a lot of plants are theoretically eligible, not all of their electricity will be eligible, he said.
The rules assert that in states that meet the two criteria of a clean electricity standard and a binding cap on emissions, “any increased electricity load is highly unlikely to cause induced grid emissions.”
But in a paper published in February, Energy Innovation explored the potential consequences of this exemption in California. It found that hydrogen projects could have ripple effects on the cap and trade market, pushing up the state’s carbon price and triggering the release of extra carbon emission allowances. “In other words, the California program is more of a ‘soft’ cap than a binding one — the emissions budget ‘expands or contracts in response to price bounds set by the legislature and [California Air Resources Board],’” the report says.
Esposito thinks the exemption is a risk, but that it requires further analysis and he’s not sounding the alarm just yet. He said it could come down to other factors, including how economical hydrogen production in California ends up being.
Producers are also eligible for the tax credit if they make hydrogen the conventional way, by “reforming” natural gas, but capture the emissions released in the process. For this pathway, the Treasury had to clarify several accounting questions.
First, there’s the question of how producers should account for methane leaked into the atmosphere upstream of the hydrogen plant, such as from wells and pipelines. The proposal had suggested using a national average of 0.9%. But researchers found this would wildly underestimate the true warming impact of hydrogen produced from natural gas. It could also underestimate emissions from natural gas producers that have taken steps to reduce methane leakage. “We branded that as one size fits none,” Schneider told me.
The final rules create a path for producers to use more accurate, project-specific methane emissions rates in the future once the Department of Energy updates a lifecycle emissions tool that companies have to use called the “GREET” model. The Environmental Protection Agency recently passed new methane emissions laws that will enable it to collect better data on leakage, which will help the DOE update the model.
Schneider said that’s a step in the right direction, though it will depend on how quickly the GREET model is updated. His bigger concern is if the Trump administration weakens or eliminates the EPA’s methane emissions regulations.
The Treasury also opened up the potential for companies to produce hydrogen from alternative, cleaner sources of methane, like gas captured from wastewater, animal manure, and coal mines. (The original rule included a pathway for using gas captured from landfills.) In reality, hydrogen plants taking this approach are unlikely to use gas directly from these sources, but rather procure certificates that say they have “booked” this cleaner gas and can “claim” the environmental benefits.
Leading up to the final rule, some climate advocates were concerned that this system would give a boost to methane-based hydrogen production over electricity-based production, as it's cheaper to buy renewable natural gas certificates than it is to split water molecules. Existing markets for these credits also often overestimate their benefits — for example, California’s low carbon fuel system gives biogas captured from dairy farms a negative carbon intensity score, even though these projects don’t literally remove carbon from the atmosphere.
The Treasury tried to improve its emissions estimates for each of these alternative methane sources to make them more accurate, but negative carbon intensity scores are still possible.
The department did make one significant change here, however. It specified that companies can’t just buy a little bit of cleaner methane and then average it with regular fossil-based methane — each must be considered separately for determining tax credit eligibility. Jenkins, of Princeton, told me that without this rule, huge amounts of hydrogen made from regular natural gas could qualify.
Producers also won’t be able to take this “book and claim” approach until markets adapt to the Treasury’s reporting requirements, which isn’t expected until at least 2027.
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The political marriage of President Donald Trump and Elon Musk, the EV mogul and world’s richest man, has significantly changed the outlook for what the Trump administration might mean for energy policy, decarbonization, and the rule of law.
Musk has taken over numerous offices responsible for crucial functions within the federal government, including the Office of Personnel Management at the White House. Musk has snatched control of the federal government’s payments system, and he and his team have illegally tried to use it to block payments to federal programs, according to CNN and The New York Times. Conservative budget experts say that such a move violates the Constitution, which grants sole control over the power of the purse to Congress.
What’s the issue? The problem here is not primarily that Musk is unelected — there are lots of powerful people in every administration who are not elected (though few have ever had as many conflicts of interest as Musk, the CEO of the world’s most valuable automaker in Tesla and the holder of many government contracts via the rocket company SpaceX and satellite internet provider Starlink). Nor would it be a problem if Musk were merely trying to modernize the government’s IT systems.
The problem is that Musk has used his control of a technical system — the software that the government uses to send more than a billion payments a year — to assert effective control over federal programs and policies. This is why Musk trying to shut off payments that have been appropriated by Congress matters: He is in essence saying that because he can do something with the software, he may do it.
The issue is that the government can do many things that it broadly does not do because they are illegal.
But Trump and Musk together are now testing the limits of the law.
The Trump administration is operating on a legal theory that the president can simply decide not to spend money that has been appropriated by Congress. Key officials in the Trump administration argue that Congress sets a ceiling, but not a floor, when it appropriates federal funding. It also believes that the Impoundment Control Act of 1974, which Congress passed during the Nixon administration, is unconstitutional.
I find it hard to believe that the Supreme Court — which last year severely limited the executive branch’s ability to interpret congressional laws which create and govern agencies — agrees with Trump that the president can ignore those same laws when they govern federal spending. But the Court has reached shocking decisions on Trump’s behalf before.
Trump’s team seems to be trying to make this legal theory central to how his entire administration works. Impoundment underpinned the White House’s attempt last month to block all outgoing federal grants and loans, which briefly threw the government into chaos before it was blocked by a judge and ultimately rescinded.
Musk’s ploy, seemingly, is to move so fast that these legal and constitutional questions become moot. If he can close a federal agency’s offices, put its workers on leave, and cut off funding to its programs, then perhaps it won’t matter what a judge says about impoundment itself. And if Musk can control the tap of public money, turning it on and off at will, then he can usurp the operation of the United States government.
In the world of climate and energy, Musk’s prominence — and the lack of precedent for his situation — raises important questions for businesses and policy makers. Here is what we do not know about Musk today:
In 2010, the federal government issued a $465 million loan to Tesla so that it could build a factory in California for its Model S sedan.
In recent years, the government has made similar deals, lending tens of billions of dollars to other companies that make electric vehicles or that mine and refine critical minerals.
Last month, the Biden administration closed a $6.57 billion loan to Rivian, the electric truck maker, so that it could build a new factory in Georgia.
Some of these new borrowers, including Rivian and legacy automakers like Ford, compete with Tesla. It is still unclear whether Musk will be able to use his control of the federal government’s checkbook to cut off some loans and allow others to proceed. Doing so would ultimately stifle competition in the EV sector, benefitting Tesla, where Musk remains CEO.
The White House said this week that Trump is allowing Musk to police his own conflicts of interest.
In December, Musk called for Congress to “get rid” of the clean energy tax credits created by the Inflation Reduction Act.
Most tax credits are claimed by companies against what they owe on their taxes, meaning that they result in negative revenue to the government. But the IRA created a new kind of credit — a so-called “direct payment” — that allowed states, schools, churches, tribes, and other entities without federal tax liability to claim money for installing clean energy or buying electric vehicles.
Those payments — and any other tax refunds — ultimately run through the Treasury Department’s computer systems. It remains unclear whether Musk can use control of the federal government’s checkbook to block the payout of these payments.
One of Musk’s initiatives, the U.S. DOGE Service, is housed at the General Services Administration, or GSA.
The GSA is the government’s internal landlord and facilities manager — it owns, builds, and manages federal office space. It also operates parts of the federal vehicle fleet.
Under the Biden administration, it undertook a number of energy sustainability and efficiency initiatives. Some of these programs were canceled by President Trump’s initial set of executive orders, but it remains unclear whetheb
Last year, the U.S. military was investigating whether Elon Musk complied with the rules of his security clearance, according to The New York Times.
At the time, Musk’s rocket company, SpaceX, had already declined to pursue the highest level security clearance for Musk, in part because of reports around his open drug use and contact with foreign leaders, according to The Wall Street Journal. Musk is reported to hold a “Top Secret” clearance.
The Journal has also previously reported that Musk conducted secret conversations with Vladimir Putin and that Musk’s drug use worries Tesla and SpaceX executives.
Tesla has deep ties in China. It achieved record sales in China last year, although its market share has fallen as Chinese EV companies have out-competed its aging vehicle line-up. Tesla is reportedly opening a new factory in Shanghai this month. Musk has also staked out public positions that favor the Chinese Community Party’s views. In 2022, he suggested that Taiwan could become a “special administrative zone” of the People’s Republic of China.
It’s unclear how these commitments might affect his work for the U.S. government.
Three tactics from Erin Burns, executive director of Carbon180, on how the industry can use this time wisely.
Erin Burns has been here before. The executive director of Carbon180, a carbon removal research and policy nonprofit, joined the organization as its first policy director in 2018, partway through Donald Trump’s first term as president. It was under that administration that she helped win the first ever dedicated federal research and development funding for carbon removal, a modest $60 million in 2019.
It’s a very different world today than it was then, so she wasn’t exactly here. There’s now billions of dollars in federal funding appropriated to pull carbon from the atmosphere — not just for research and development, but also for building commercial-scale projects and purchasing carbon removal services. At the same time, this new Trump administration is moving more quickly and aggressively than the last one to undo anything resembling climate policy, and future attempts to re-allocate some of that money are not out of the question.
I recently spoke to Burns about how she’s looking to make progress on carbon removal under these circumstances. Here are my big takeaways from the conversation.
It’s not yet clear how the Trump administration or new Congress is going to act on existing carbon removal programs. Although the industry has a history of receiving bipartisan support and federally-funded carbon removal projects are happening in Republican states and districts, that doesn’t mean these programs are safe. “The rollback of certain policies are not ultimately going to be about how people feel about direct air capture or carbon removal,” Burns told me. “It’s going to be a broader ideology around the role of a place like the Department of Energy, and what kinds of supports the federal government should provide.”
With that in mind, Burns’ motto is “the best defense is a good offense.” That means working with the congresspeople who supported the direct air capture hubs to highlight why the government should continue investing in them. It also involves working with labor unions with members in heavy industry who see the jobs potential. It’s time to double down on a more expansive argument for the benefits of these projects, she said. “There are additional benefits to every carbon removal pathway. We should always be talking about them. Climate’s not going to be the argument that gets you those really durable political coalitions.”
Playing offense also means planning for the next opening. The reason the Biden administration made so much progress on carbon removal, Burns said, is that advocates like her spent two years under the Trump administration meeting weekly, developing policy and “socializing” it, so that it was “ready to go.” As policy enactment in Washington slows down, advocates will have more capacity to sit down and develop the next wave of ideas. To Burns, that means thinking about a more tailored, ground-up approach.
“To be honest, we don’t really have carbon removal policy in the United States,” Burns told me. “We have direct air capture policy, and even that is, like, point-source carbon capture policy that’s been tweaked to fit direct air capture.” An example is the 45Q tax credit, which was originally created to support projects that capture carbon from the smokestacks of coal plants, but was expanded to support direct air capture projects as well.
But carbon removal is not just direct air capture — it’s also planting trees and grinding rocks, activities that likely require different policies and supports than big air-sucking machines to scale up. Leveraging all that to its fullest extent will require a more expansive policy regime.
“Let’s start from scratch,” Burns said. “Start to grapple with the fundamental nature of carbon removal as a unique thing that isn’t going to be deployed only with the policies that we’ve used to deploy technologies like solar. Because carbon removal is not going to create electricity, for example. It’s not just about making it cheap enough that there’s going to be this market force. Making it cheaper is great, but you also have to think about the other barriers.”
Before coming to Carbon180, Burns worked at the center-left think tank Third Way on carbon capture and nuclear energy policy. While she was there, Trump proposed dramatically slashing the Department of Energy’s budget for energy efficiency and renewable energy research and eliminating the Advanced Research Projects Agency-Energy, which supports the early development of technologies that are too risky for private investment.
“You can get some unusual bedfellows together when you have an administration that’s trying to cut, say, all of the Department of Energy,” Burns said. Instead of renewable developers and nuclear power companies and carbon removal startups all fighting for a piece of the pie, there’s incentive to come together and “make sure the pie still exists.”
It’s not just about preserving funding. The carbon removal industry also needs to be making inroads with adjacent industries because they have common interests. Direct air capture facilities need renewable energy to operate. and right now the future of renewable energy is under major threat. Similarly, direct air capture projects need the Environmental Protection Agency to be well-staffed enough to continue permitting carbon sequestration wells — a process that was slow to start but starting to pick up at the end of Biden’s term. “I think there’s value in us thinking about what it means to not just defend carbon removal, but defend all of this climate infrastructure that is going to be necessary for us to be successful.”
In her past work on carbon capture, Burns grew familiar with a divide between players who were genuinely trying to fight climate change and those for whom carbon capture was just a line in their advertising budget. In her view, the carbon removal industry has been different, with most companies genuinely trying to do the right thing for the climate. It’s an open question as to whether that might change in this new political environment, she said.
Under the Biden administration, the Department of Energy was staffed with some of the leading carbon removal experts in the country. Now there may be less pressure on companies to have high standards for measuring, reporting, and verifying carbon removal outcomes — meaning more of an opening to fudge the truth of how much benefit their projects are providing.
The Trump administration is also scaling back the size of agencies’ staff and removing requirements for companies that receive financial assistance to do things like ensure that the communities hosting their projects also benefit from them. Burns said the onus is on organizations like Carbon180 and on corporate carbon removal buyers to maintain high standards not just for measurement, but also for community engagement. “If you care about deploying CDR, you need to care about local support for those projects,” she said.
For one, community opposition can shut down a project. But also, bringing benefits to host communities helps build political support for carbon removal that can lead to more federal aid down the line. “Those are keys for long-term success.”
A conversation with Peter Bonner, senior fellow for the Federation of American Scientists
This week’s Q&A is with Peter Bonner, senior fellow for the Federation of American Scientists. I reached out to Peter because this week, as I was breaking stories about chaos in renewables permitting, his organization released a report he helped author that details how technology and hiring challenges are real bottlenecks in the federal environmental review process. We talked about this report, which was the culmination of 18 months of research and involved detailed interviews with federal permitting staff.
The following interview was lightly edited for clarity.
Okay so walk me through why you did this report.
The reason for doing the report was to look at, why is permitting a bottleneck? What are some things that can improve the effectiveness and the efficiency of permitting to get permits done better and faster?
Depending on the type of permitting project and where the infrastructure is getting built, permitting could be very, very difficult, or it could go more easily. It depends on the number of stakeholders involved. It depends on the type of permitting project it is. But it also depends on each agency doing permitting somewhat differently, and leaning on different types of technology to enable them to do permitting better.
One agency may have one configuration of a permitting team and in another agency, that configuration of a permitting team may be quite different, sometimes independent of the type of permitting project they’re talking about. So there’s a need for greater consistency in how those teams are built, and also the skill and talent that goes into those teams and how they work with contractors to get the permits done.
In addition, each agency is leaning on their own types of technologies on case management and how to run the permitting project instead of there being consistency around the technologies they use as well.
What went into this report?
There were a couple pieces to it. One is a set of pretty extensive interviews with permitting program managers, hiring managers, and HR specialists who were bringing people into agencies to help with permitting functions and programs. We also did significant extensive research into the permitting process and what technologies permitting teams were using to document and guide their work in adherence to regulations. So a lot of it was primary research working directly with the agencies and the people who were on the ground doing the permitting.
How much of the backlog in permitting is Congress? Or is it just the executive branch?
Clarity in the laws and regulations that guide permitting – there’s still work there to be done. But our focus was less on laws and regulations and more around, how are permitting teams actually getting the work done? What talent do they need on those teams? What technologies can they use to support their work?
So you’re telling me a big issue might really be the government’s load bearing infrastructure, so to speak. Is it really just the back-end? The pipes?
A decent amount of it is the pipes and getting the right people in place.
The permitting workforce has been wanting for people and skillsets even before the increase in infrastructure spending over the past few years. You’re looking at a workforce that did not have enough people to do the job before this influx of projects came in.
It therefore depended on bringing in people and contracting people to do that work as well. And in the hiring process, we found significant delays in recruiting for permitting talent..
What we found was a lot of delays due to the bureaucracy around hiring that I think is well-documented in other places [in government]. Doing more, clear skills-based assessments up-front when you’re evaluating people for jobs so that highly qualified people then make it to the list that you can hire from. Making sure people get through the background check process properly. There’s lots of things that delay getting people on board faster and also reaching out and recruiting the right sorts of folks.
To what extent do you think your recommendations here on the pipes, so to speak, will have an audience with this administration? I’m particularly curious given all the headlines we’re seeing about staff reductions in the federal government.
It’s hard to project that and there’s a lot of clarity that needs still to come in terms of how this administration is viewing supporting permitting teams and the agencies to make sure that they can do their jobs better. The real answers to that are still to come.
I think there’s a lot of change going on in the permitting regulatory environment, the regulations. There’s also executive orders, legal decisions that have come down lately. We’re in a dynamic, changing situation.
My hope is that the administration would recognize that, take a look at the report we have and take a look at investing in the right people and the right technologies.