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Life cycle analysis has some problems.
About six months ago, a climate scientist from Arizona State University, Stephanie Arcusa, emailed me a provocative new paper she had published that warned against our growing reliance on life cycle analysis. This practice of measuring all of the emissions related to a given product or service throughout every phase of its life — from the time raw materials are extracted to eventual disposal — was going to hinder our ability to achieve net-zero emissions, she wrote. It was a busy time, and I let the message drift to the bottom of my inbox. But I couldn’t stop thinking about it.
Life cycle analysis permeates the climate economy. Businesses rely on it to understand their emissions so they can work toward reducing them. The Securities and Exchange Commission’s climate risk disclosure rule, which requires companies to report their emissions to investors, hinges on it. The clean hydrogen tax credit requires hydrogen producers to do a version of life cycle analysis to prove their eligibility. It is central to carbon markets, and carbon removal companies are now developing standards based on life cycle analysis to “certify” their services as carbon offset developers did before them.
At the same time, many of the fiercest debates in climate change are really debates about life cycle analysis. Should companies be held responsible for the emissions that are indirectly related to their businesses, and if so then which ones? Are carbon offsets a sham? Does using corn ethanol as a gasoline substitute reduce emissions or increase them? Scientists have repeatedly reached opposite conclusions on that one depending on how they accounted for the land required to grow corn and what it might have been used for had ethanol not been an option. Though the debate plays out in calculations, it’s really a philosophical brawl.
Everybody, for the most part, knows that life cycle analysis is difficult and thorny and imprecise. But over and over, experts and critics alike assert that it can be improved. Arcusa disagrees. Life cycle analysis, she says, is fundamentally broken. “It’s a problematic and uncomfortable conclusion to arrive at,” Arcusa wrote in her email. “On the one hand, it has been the only tool we have had to make any progress on climate. On the other, carbon accounting is captured by academia and vested interests and will jeopardize global climate goals.”
When I recently revisited the paper, I learned that Arcusa and her co-authors didn’t just critique life cycle analysis, they proposed a bold alternative. Their idea is not economically or politically easy, but it also doesn’t suffer from the problems of trying to track carbon throughout the supply chain. I recently called her up to talk through it. Our conversation has been edited for clarity.
Can you walk me through what the biggest issues with life cycle analysis are?
So, life cycle analysis is a qualitative tool —
It seems kind of counterintuitive or even controversial to call it a qualitative tool because it’s specifically trying to quantify something.
I think the best analogy for LCA is that it’s a back-of-the-envelope tool. If you really could measure everything, then sure, LCA is this wonderful idea. The problem is in the practicality of being able to collect all of that data. We can’t, and that leads us to use emissions factors and average numbers, and we model this and we model that, and we get so far away from reality that we actually can’t tell if something is positive or negative in the end.
The other problem is that it’s almost entirely subjective, which makes one LCA incomparable to another LCA depending on the context, depending on the technology. And yes, there are some standardization efforts that have been going on for decades. But if you have a ruler, no matter how much you try, it’s not going to become a screwdriver. We’re trying to use this tool to quantify things and make them the same for comparison, and we can’t because of that subjectivity.
In this space where there is a lot of money to be made, it’s very easy to manipulate things one way or another to make it look a little bit better because the method is not robust. That’s really the gist of the problems here.
One of the things you talk about in the paper is the way life cycle analysis is subject to different worldviews. Can you explain that?
It’s mostly seen in what to include or exclude in the LCA — it can have enormous impacts on the results. I think corn ethanol is the perfect example of how tedious this can be because we still don’t have an answer, precisely for that reason. The uncertainty range of the results has shrunk and gotten bigger and shrunk and gotten bigger, and it’s like, well, we still don’t know. And now, this exact same worldview debate is playing into what should be included and not included in certification for things [like carbon removal] that are going to be sold under the guise of climate action, and that just can’t be. We’ll be forever debating whether something is true.
Is this one of those things that scientists have been debating for ever, or is this argument that we should stop using life cycle analysis more of a fringe idea?
I guess I would call it a fringe idea today. There’s been plenty of criticism throughout the years, even from the very beginning when it was first created. What I have seen is that there is criticism, and then there is, “But here’s how we can solve it and continue using LCA!” I’ve only come across one other publication that specifically said, “This is not working. This is not the right tool,” and that’s from Michael Gillenwater. He’s at the Greenhouse Gas Management Institute. He was like, “What are we doing?” There might be other folks, I just haven’t come across them.
Okay, so what is the alternative to LCA that you’ve proposed in this paper?
LCA targets the middle of the supply chain, and tries to attribute responsibility there. But if you think about where on the supply chain the carbon is the most well-known, it is actually at the source, at the point of origin, before it becomes an emission. At the point where it is created out of the ground is where we know how much carbon there is. If we focus on that source through a policy that requires mandatory sequestration — for every ton of carbon that is now produced, there is a ton of carbon that’s been put away through carbon removal, and the accounting happens there, before it is sold to anybody —anybody who’s now downstream of that supply chain is already carbon neutral. There is no need to track carbon all the way down to the consumer.
We know this is accurate because that is where governments already collect royalties and taxes — they want to know exactly how much is being sold. So we already do this. The big difference is that the policy would be required there instead of taxing everybody downstream.
You’re saying that fossil fuel producers should be required to remove a ton of carbon from the atmosphere for every ton of carbon in the fuels they sell?
Yeah, and maybe I should be more specific. They should pay for an equal amount of carbon to be removed from the atmosphere. In no way are we implying that a fossil carbon producer needs to also be doing the sequestration themselves.
What would be the biggest challenges of implementing something like this?
The ultimate challenge is convincing people that we need to be managing carbon and that this is a waste management type of system. Nobody really wants to pay for waste management, and so it needs to be regulated and demanded by some authority.
What about the fact that we don’t really have the ability to remove carbon or store carbon at scale today, and may not for some time?
Yes, we need to build capacity so that eventually we can match the carbon production to the carbon removal, which is why we also proposed that the liability needs to start today, not in the future. That liability is as good as a credit card debt — you actually have to pay it. It can be paid little by little every year, but the liability is here now, and not in the future.
The risk in the system that I’m describing, or even the system that is currently being deployed, is that you have counterproductive technologies that are being developed. And by counterproductive, I mean [carbon removal] technologies that are producing more emissions than they are storing, and so they’re net-positive. You can create a technology that has no intention of removing more carbon than its sequesters. The intention is just to earn money.
Do you mean, like, the things that are supposed to be removing carbon from the atmosphere and sequestering it, they are using fossil fuels to do that, and end up releasing more carbon in the process?
Yeah, so basically, what we show in the paper is that when we get to full carbon neutrality, the market forces alone will eliminate those kinds of technologies that are counterproductive. The problem is during the transition, these technologies can be economically viable because they are cheaper than they would be if 100% of the fossil fuel they used was carbon neutral through carbon removal. And so in order to prevent those technologies from gaming the system, we need a way to artificially make the price of fossil carbon as expensive as it would be if 100% of that fossil carbon was covered by carbon removal.
That’s where the idea of permits comes in. For every amount that I produce, I now have an instant liability, which is a permit. Each of those permits has to be matched by carbon removal. And since we don’t have enough carbon removal, we have futures and these futures represent the promise of actually doing carbon removal.
What if we burn through the remaining carbon budget and we still don’t have the capacity to sequester enough carbon?
Well, then we’re going into very unchartered territory. Right now we’re just mindlessly going through this thinking that if we just reduce emissions it will be good. It won’t be good.
In the paper, you also argue against mitigating greenhouse gases other than carbon, and that seems pretty controversial to me. Why is that?
We’re not arguing against mitigating, per se. We’re arguing against lumping everything under the same carbon accounting framework because lumping hides the difficulty in actually doing something about it. It’s not that we shouldn’t mitigate other greenhouse gases — we must. It’s just that if we separate the problem of carbon away from the problem of methane, away from the problem of nitrous oxide, or CFCs, we can tackle them more effectively. Because right now, we’re trying to do everything under the same umbrella, and that doesn’t work. We don’t tackle drinking and driving by sponsoring better tires. That’s just silly, right? We wouldn’t do that. We would tackle drinking and driving on its own, and then we would tackle better tires in a different policy.
So the argument is: Most of climate change is caused by carbon; let’s tackle that separately from the others and leave tackling methane and nitrous oxide to purposefully created programs to tackle those things. Let’s not lump the calculations altogether, hiding all the differences and hiding meaningful action.
Is there still a role for life cycle analysis?
You don’t want to be regulating carbon using life cycle analysis. So you can use the life cycle analysis for qualitative purposes, but we’re pretending that it is a tool that can deliver accurate results, and it just doesn’t.
What has the response been like to this paper? What kind of feedback have you gotten?
Stunned silence!
Nobody has said anything?
In private, they have. Not in public. In private, it’s been a little bit like, “I’ve always thought this, but it seemed like there was no other way.” But then in public, think about it. Everything is built on LCA. It’s now in every single climate bill out there. Every single standard. Every single consulting company is doing LCA and doing carbon footprinting for companies. It’s a huge industry, so I guess I shouldn’t have been surprised to hear nothing publicly.
Yeah, I was gonna ask — I’ve been writing about the SEC rules and this idea that companies should start reporting their emissions to their investors, and that would all be based on LCA. There’s a lot of buy-in for that idea across the climate movement.
Yeah, but there’s definitely a fine line with make-believe. I think in many instances, we kid ourselves thinking that we’re going to have numbers that we can hang our hats on. In many instances we will not, and they will be challenged. And so at that point, what’s the point?
One thing I hear when I talk to people about this is, well, having an estimate is better than not having anything, or, don’t let the perfect be the enemy of the good, or, we can just keep working to make them better and better. Why not?
I mean, I wouldn’t say don’t try. But when it comes to actually enforcing anything, it’s going to be extremely hard to prove a number. You could just be stuck in litigation for a long time and still not have an answer.
I don’t know, to me it just seems like an endless debate while time is ticking and we will just feel good because we’ll have thought we measured everything. But we’re still not doing anything.
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Ecolectro, a maker of electrolyzers, has a new manufacturing deal with Re:Build.
By all outward appearances, the green hydrogen industry is in a state of arrested development. The hype cycle of project announcements stemming from Biden-era policies crashed after those policies took too long to implement. A number of high profile clean hydrogen projects have fallen apart since the start of the year, and deep uncertainty remains about whether the Trump administration will go to bat for the industry or further cripple it.
The picture may not be as bleak as it seems, however. On Wednesday, the green hydrogen startup Ecolectro, which has been quietly developing its technology for more than a decade, came out with a new plan to bring the tech to market. The company announced a partnership with Re:Build Manufacturing, a sort of manufacturing incubator that helps startups optimize their products for U.S. fabrication, to build their first units, design their assembly lines, and eventually begin producing at a commercial scale in a Re:Build-owned factory.
“It is a lot for a startup to create a massive manufacturing facility that’s going to cost hundreds of millions of dollars when they’re pre-revenue,” Jon Gordon, Ecolectro’s chief commercial officer, told me. This contract manufacturing partnership with Re:Build is “massive,” he said, because it means Ecolectro doesn’t have to take on lots of debt to scale. (The companies did not disclose the size of the contract.)
The company expects to begin producing its first electrolyzer units — devices that split water into hydrogen and oxygen using electricity — at Re:Build’s industrial design and fabrication site in Rochester, New York, later this year. If all goes well, it will move production to Re:Build’s high-volume manufacturing facility in New Kensington, Pennsylvania next year.
The number one obstacle to scaling up the production and use of cleaner hydrogen, which could help cut emissions from fertilizer, aviation, steelmaking, and other heavy industries, is the high cost of producing it. Under the Biden administration, Congress passed a suite of policies designed to kick-start the industry, including an $8 billion grant program and a lucrative new tax credit. But Biden only got a small fraction of the grant money out the door, and did not finalize the rules for claiming the tax credit until January. Now, the Trump administration is considering terminating its agreements with some of the grant recipients, and Republicans in Congress might change or kill the tax credit.
Since the start of the year, a $500 million fuel plant in upstate New York, a $400 million manufacturing facility in Michigan, and a $500 million green steel factory in Mississippi, have been cancelled or indefinitely delayed.
The outlook is particularly bad for hydrogen made from water and electricity, often called “green” hydrogen, according to a recent BloombergNEF analysis. Trump’s tariffs could increase the cost of green hydrogen by 14%, or $1 per kilogram, based on tariff announcements as of April 8. More than 70% of the clean hydrogen volumes coming online between now and 2030 are what’s known as “blue” hydrogen, made using natural gas, with carbon capture to eliminate climate pollution. “Blue hydrogen has more demand than green hydrogen, not just because it’s cheaper to produce, but also because there’s a lot less uncertainty around it,” BloombergNEF analyst Payal Kaur said during a presentation at the research firm’s recent summit in New York City. Blue hydrogen companies can take advantage of a tax credit for carbon capture, which Congress is much less likely to scrap than the hydrogen tax credit.
Gordon is intimately familiar with hydrogen’s cost impediments. He came to Ecolectro after four years as co-founder of Universal Hydrogen, a startup building hydrogen-powered planes that shut down last summer after burning through its cash and failing to raise more. By the end, Gordon had become a hydrogen skeptic, he told me. The company had customers interested in its planes, but clean hydrogen fuel was too expensive at $15 to $20 per kilogram. It needed to come in under $2.50 to compete with jet fuel. “Regional aviation customers weren’t going to spend 10 times the ticket price just to fly zero emissions,” he said. “It wasn’t clear to me, and I don’t think it was clear to our prospective investors, how the cost of hydrogen was going to be reduced.” Now, he’s convinced that Ecolectro’s new chemistry is the answer.
Ecolectro started in a lab at Cornell University, where its cofounder and chief science officer Kristina Hugar was doing her PhD research. Hugar developed a new material, a polymer “anion exchange membrane,” that had potential to significantly lower the cost of electrolyzers. Many of the companies making electrolyzers use designs that require expensive and supply-constrained metals like iridium and titanium. Hugar’s membrane makes it possible to use low-cost nickel and steel instead.
The company’s “stack,” the sandwich of an anode, membrane, and cathode that makes up the core of the electrolyzer, costs at least 50% less than the “proton exchange membrane” versions on the market today, according to Gordon. In lab tests, it has achieved more than 70% efficiency, meaning that more than 70% of the electrical energy going into the system is converted into usable chemical energy stored in hydrogen. The industry average is around 61%, according to the Department of Energy.
In addition to using cheaper materials, the company is focused on building electrolyzers that customers can install on-site to eliminate the cost of transporting the fuel. Its first customer was Liberty New York Gas, a natural gas company in Massena, New York, which installed a small, 10-kilowatt electrolyzer in a shipping container directly outside its office as part of a pilot project. Like many natural gas companies, Liberty is testing blending small amounts of hydrogen into its system — in this case, directly into the heating systems it uses in the office building — to evaluate it as an option for lowering emissions across its customer base. The equipment draws electricity from the local electric grid, which, in that region, mostly comes from low-cost hydroelectric power plants.
Taking into account the expected manufacturing cost for a commercial-scale electrolyzer, Ecolectro says that a project paying the same low price for water and power as Liberty would be able to produce hydrogen for less than $2.50 per kilogram — even without subsidies. Through its partnership with Re:Build, the company will produce electrolyzers in the 250- to 500-kilowatt range, as well as in the 1- to 5-megawatt range. It will be announcing a larger 250-kilowatt pilot project later this year, Gordon said.
All of this sounded promising, but what I really wanted to know is who Ecolectro thought its customers were going to be. Demand for clean hydrogen, or the lack thereof, is perhaps the biggest challenge the industry faces to scaling, after cost. Of the roughly 13 million to 15 million tons of clean hydrogen production announced to come online between now and 2030, companies only have offtake agreements for about 2.5 million tons, according to Kaur of BNEF. Most of those agreements are also non-binding, meaning they may not even happen.
Gordon tied companies’ struggle with offtake to their business models of building big, expensive, facilities in remote areas, meaning the hydrogen has to be transported long distances to customers. He said that when he was with Universal Hydrogen, he tried negotiating offtake agreements with some of these big projects, but they were asking customers to commit to 20-year contracts — and to figure out the delivery on their own.
“Right now, where we see the industry is that people want less hydrogen than that,” he said. “So we make it much easier for the customer to adopt by leasing them this unit. They don’t have to pay some enormous capex, and then it’s on site and it’s producing a fair amount of hydrogen for them to engage in pilot studies of blending, or refining, or whatever they’re going to use it for.”
He expects most of the demand to come from industrial customers that already use hydrogen, like fertilizer companies and refineries, that want to switch to a cleaner version of the fuel, or hydrogen-curious companies that want to experiment with blending it into their natural gas burners to reduce their emissions. Demand will also be geographically-limited to places like New York, Washington State, and Texas, that have low-cost electricity available, he said. “I think the opportunity is big, and it’s here, but only if you’re using a product like ours.”
On coal mines, Energy Star, and the EV tax credit
Current conditions: Storms continue to roll through North Texas today, where a home caught fire from a lightning strike earlier this week • Warm, dry days ahead may hinder hotshot crews’ attempts to contain the 1,500-acre Sawlog fire, burning about 40 miles west of Butte, Montana• Severe thunderstorms could move through Rome today on the first day of the papal conclave.
The International Energy Agency published its annual Global Methane Tracker report on Wednesday morning, finding that over 120 million tons of the potent greenhouse gas were emitted by oil, gas, and coal in 2024, close to the record high in 2019. In particular, the research found that coal mines were the second-largest energy sector methane emitter after oil, at 40 million tons — about equivalent to India’s annual carbon dioxide emissions. Abandoned coal mines alone emitted nearly 5 million tons of methane, more than abandoned oil and gas wells at 3 million tons.
“Coal, one of the biggest methane culprits, is still being ignored,” Sabina Assan, the methane analyst at the energy think tank Ember, said in a statement. “There are cost-effective technologies available today, so this is a low-hanging fruit of tackling methane.” Per the IEA report, about 70% of all annual methane emissions from the energy sector “could be avoided with existing technologies,” and “a significant share of abatement measures could pay for themselves within a year.” Around 35 million tons of total methane emissions from fossil fuels “could be avoided at no net cost, based on average energy prices in 2024,” the report goes on. Read the full findings here.
Opportunities to reduce methane emissions in the energy sector, 2024
IEA
The Environmental Protection Agency told staff this week that the division that oversees the Energy Star efficiency certification program for home appliances will be eliminated as part of the Trump administration’s ongoing cuts and reorganization, The Washington Post reports. The Energy Star program, which was created under President George H.W. Bush, has, in the past three decades, helped Americans save more than $500 billion in energy costs by directing them to more efficient appliances, as well as prevented an estimated 4 billion metric tons of greenhouse gas from entering the atmosphere since 1992, according to the government’s numbers. Almost 90% of Americans recognize its blue logo on sight, per The New York Times.
President Trump, however, has taken a personal interest in what he believes are poorly performing shower heads, dishwashers, and other appliances (although, as we’ve fact-checked here at Heatmap, many of his opinions on the issue are outdated or misplaced). In a letter on Tuesday, a large coalition of industry groups including the Air-Conditioning, Heating, and Refrigeration Institute, the Association of Home Appliance Manufacturers, and the U.S. Chamber of Commerce wrote to EPA Administrator Lee Zeldin in defense of Energy Star, arguing it is “an example of an effective non-regulatory program and partnership between the government and the private sector. Eliminating it will not serve the American people.”
House Speaker Mike Johnson suggested that the electric vehicle tax credit may be on its last legs, according to an interview he gave Bloomberg on Tuesday. “I think there is a better chance we kill it than save it,” Johnson said. “But we’ll see how it comes out.” He estimated that House Republicans would reveal their plan for the tax credits later this week. Still, as Bloomberg notes, a potential hangup may be that “many EV factories have been built or are under construction in GOP districts.”
As we’ve covered at Heatmap, President Trump flirted with ending the $7,500 tax credit for EVs throughout his campaign, a move that would mark “a significant setback to the American auto industry’s attempts to make the transition to electric vehicles,” my colleague Robinson Meyer writes. That holds true for all EV makers, including Tesla, the world’s most valuable auto company. However, its CEO, Elon Musk — who holds an influential position within the government — has said he supports the end of the tax credit “because Tesla has more experience building EVs than any other company, [and] it would suffer least from the subsidy’s disappearance.”
Constellation Energy Corp. held its quarterly earnings call on Tuesday, announcing that its operating revenue rose more than 10% in the first three months of the year compared to 2024, beating expectations. Shares climbed 12% after the call, with Chief Executive Officer Joe Dominguez confirming that Constellation’s pending purchase of natural gas and geothermal energy firm Calpine is on track to be completed by the end of the year, and that the nuclear power utility is “working hard to meet the power needs of customers nationwide, including powering the new AI products that Americans increasingly are using in their daily lives and that businesses and government are using to provide better products and services.”
But as my colleague Matthew Zeitlin reported, Dominguez also threw some “lukewarm water on the most aggressive load growth projections,” telling investors that “it’s not hard to conclude that the headlines are inflated.” As Matthew points out, Dominguez also has some reason to downplay expectations, including that “there needs to be massive investment in new power plants,” which could affect the value of Constellation’s existing generation fleet.
The Rockefeller Foundation aims to phase out 60 coal-fired power plants by 2030 by using revenue from carbon credits to cover the costs of closures, the Financial Times reports. The team working on the initiative has identified 1,000 plants in developing countries that would be eligible for the program under its methodology.
Rob and Jesse go deep on the electricity machine.
Last week, more than 50 million people across mainland Spain and Portugal suffered a blackout that lasted more than 10 hours and shuttered stores, halted trains, and dealt more than $1 billion in economic damage. At least eight deaths have been attributed to the power outage.
Almost immediately, some commentators blamed the blackout on the large share of renewables on the Iberian peninsula’s power grid. Are they right? How does the number of big, heavy, spinning objects on the grid affect grid operators’ ability to keep the lights on?
On this week’s episode of Shift Key, Jesse and Rob dive into what may have caused the Iberian blackout — as well as how grid operators manage supply and demand, voltage and frequency, and renewables and thermal resources, and operate the continent-spanning machine that is the power grid. Shift Key is hosted by Robinson Meyer, the founding executive editor of Heatmap, and Jesse Jenkins, a professor of energy systems engineering at Princeton University.
Subscribe to “Shift Key” and find this episode on Apple Podcasts, Spotify, Amazon, or wherever you get your podcasts.
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Here is an excerpt from our conversation:
Robinson Meyer: So a number of people started saying, oh, this was actually caused because there wasn’t enough inertia on the grid — that Spain kind of flew too close to the sun, let’s say, and had too many instantaneous resources that are metered by inverters and not by these large mechanical generators attached to its grid. Some issue happened and it wasn’t able to maintain the frequency of its grid as needed. How likely do you think that is?
Jesse Jenkins: So I don’t think it’s plausible as the precipitating event, the initial thing that started to drive the grid towards collapse. I would say it did contribute once the Iberian grid disconnected from France.
So let me break that down: When Spain and Portugal are connected to the rest of the continental European grid, there’s an enormous amount of inertia in that system because it doesn’t actually matter what’s going on just in Spain. They’re connected to this continen- scale grid, and so as the frequency drops there, it drops a little bit in France, and it drops a little bit in Latvia and all the generators across Europe are contributing to that balance. So there was a surplus of inertia across Europe at the time.
Once the system in Iberia disconnected from France, though, now it’s operating on its own as an actual island, and there it has very little inertia because the system operator only scheduled a couple thousand megawatts of conventional thermal units of gas power plants and nuclear. And so it had a very high penetration on the peninsula of non-inertia-based resources like solar and wind. And so whatever is happening up to that point, once the grid disconnected, it certainly lacked enough inertia to recover at that point from the kind of cascading events. But it doesn’t seem like a lack of inertia contributed to the initial precipitating event.
Something — we don’t know what yet — caused two generators to simultaneously disconnect. And we know that we’ve observed oscillation in the frequency, meaning something happened to disturb the frequency in Spain before all this happened. And we don’t know exactly what that disturbance was.
There could have been a lot of different things. It could have been a sudden surge of wind or solar generation. That’s possible. It could have been something going wrong with the control system that manages the automatic response to changes in frequency — they were measuring the wrong thing, and they started to speed up or slow down, or something went wrong. That happened in the past, in the case of a generator in Florida that turned on and tried to synchronize with the grid and got its controls wrong, and that causes caused oscillations of the frequency that propagated all through the Eastern Interconnection — as far away as North Dakota, which is like 2,000 miles away, you know? So these things happen. Sometimes thermal generators screw up.
Music for Shift Key is by Adam Kromelow.