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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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That’s okay for clean energy firms, terrible for manufacturers, and a big risk for everyone.
Over the past few months, you could put together three different — and somewhat conflicting — pictures of the American economy.
For companies exposed to the AI boom, business has been good — excellent, even. The surge in ongoing capital investment into data centers and electricity has been larger than other recent booms, such as the telecom buildout. Electricity demand is soaring, especially in Texas and the Mid-Atlantic. Technology companies have signed power offtake deals with nuclear and hydroelectricity companies. If anything, companies exposed to artificial intelligence are more afflicted by congested supply chains and shortages than by slack demand — see the yearslong waiting lists to get a new transformer or natural gas turbine.
Outside of the AI economy, though, the economy has been a fair bit colder. You might even say it’s been frozen by indecision. When you talk to business leaders, they confess confusion about where things are heading. President Trump’s constantly changing tariffs — and his administration’s mercurial policy shifts — have made it difficult for non-AI-exposed businesses to plan long-term capital investment.
You could hear this view from clean energy manufacturing and traditional fossil firms alike. When I talked to John Henry Harris, the CEO of the medium-duty truck maker Harbinger Motors, for an episode of Heatmap’s Shift Key podcast in June, he told me that his company was just about to shift a production process to Mexico when a last-minute Trump change made it cheaper to keep it in China. Meanwhile, an oil and gas executive recently told the Dallas Federal Reserve: “The Liberation Day chaos and tariff antics have harmed the domestic energy industry. Drill, baby, drill will not happen with this level of volatility.”
But the data contradicted that tepid view. This was the third picture that we were getting of the economy. Through the summer, federal surveys showed an economy that was performing okay. In May, according to the Bureau of Labor Statistics, the U.S. economy added 139,000 jobs; it gained another 147,000 jobs, apparently, in June. The AI boom was clearly contributing to those robust reports. But how could an economy that business leaders otherwise described as difficult be going so well?
Now we can finally square these disparate pictures.
On Friday, the federal government released its newest tranche of job numbers. The headline number was mediocre — the U.S. added a mere 73,000 jobs in July — but the guts of the report were worse. The government revised down its estimate of the May and June reports by a total of 258,000 jobs. With these new numbers in hand, it’s clear that the labor market has essentially stalled out since Liberation Day in April.
The unemployment rate slightly rose to 4.2%, which was in line with what economists predicted.
These new reports clarify that the broader American economy wasn’t actually thriving. Its summer strength was a mirage the whole time. Outside of AI, things are downright frigid. And as President Trump continues to shuffle tariffs and increase trade uncertainty, we can expect conditions to worsen. Trump seems hellbent even on clouding our ability to understand the underlying economy: on Friday afternoon, he fired the Bureau of Labor Statistics commissioner, a career civil servant.
If you squint, you can see a hazy “AI sector” versus “non-AI sector” distinction in the data, even among the energy and decarbonization companies we cover at Heatmap. But it’s not obvious. Contrary to what you might expect when power demand is surging, utility employment was basically flat last month. Heavy and civil engineering construction jobs were up by 6,000, and “nonresidential specialty trade contractors” — a category that can include electricians — gained nearly 2,000 jobs.
But manufacturing lost 11,000 jobs last month, with the motor vehicles industry driving 2,600 of those losses. Mining, quarrying, and oil and gas jobs were down. The Institute of Supply Management report, a private survey of U.S. manufacturing activity, showed the sector shrank in July for the fifth month in a row.
And even though the Department of Government Efficiency’s deferred buyout program for more than 150,000 people has yet to hit, the federal government bled 12,000 jobs.
In a way, the clean energy industry — or at least solar, battery, nuclear, and geothermal developers — might consider themselves lucky. Despite the best efforts of Trump’s officials, and despite the chaos of President Trump’s policies, they have been able to eke through the past few months because of the AI boom. Nearly 70% of all new power-generating capacity added to the U.S. grid in the first quarter of this year came from solar panels, and the government has thrown its weight behind next-generation nuclear and geothermal technologies. A tepid jobs report might even bring some interest rate relief from the Federal Reserve.
But if that AI boom slows down, we should all watch out below.
A conversation with Heather O’Neill of Advanced Energy United.
This week’s conversation is with Heather O’Neill, CEO of renewables advocacy group Advanced Energy United. I wanted to chat with O’Neill in light of the recent effective repeal of the Inflation Reduction Act’s clean electricity tax credits and the action at the Interior Department clamping down on development. I’m quite glad she was game to talk hot topics, including the future of wind energy and whether we’ll see blue states step into the vacuum left by the federal government.
The following conversation has been lightly edited for clarity.
During Trump 1.0 we saw blue states really step into the climate role in light of the federal government. Do you see anything similar taking place now?
I think this moment we’re in – it is a different moment.
How are we handling load growth? How are we making sure consumers are not paying for expensive stranded assets? Thinking about energy affordability? All of those challenges absolutely present a different moment and will result in a different response from state leaders.
But that’s where some of the changes our industry has gone through mean we’re able to meet that moment and provide solutions to those challenges. I think we need aggressive action from state leaders and I think we’ll see that from them, because of the challenges in front of them.
What does that look like?
Every state is different. Take Virginia for example. Five years after we passed the Virginia Clean Economy Act – a big, bold promise of action – we’re not on track. So what are the things we need to do to keep the foot on the accelerator there? This last legislative session we passed the virtual power plant legislation that’ll help tremendously in terms of grid flexibility. We made a big push around siting and permitting reform, and we didn’t quite get it over the finish line but that’s the kind of thing where we made a good foundation.
Or Texas. There’s so much advanced energy powering Texas right now. You had catastrophic grid failure in Hurricane Uri and look at what they’ve been able to build out in response to that: wind, solar, and in the last few years, battery storage, and they just passed the energy waste reduction [bill].
We need to build things and make it easier to build – siting and permitting reform – but it’s also states depending on their environment looking at and engaging with their regional transmission organization.
You saw that last week, a robust set of governors across the PJM region called on them to improve their interconnection queue. It’s about pushing and finding reforms at the market level, to get these assets online and get on the grid deployed.
I think the point about forward momentum, I definitely see what you’re saying there about the need for action. Do you see state primacy laws or pre-emption laws? Like what Michigan, New York, and California have done…
I’m not a siting expert, but the reform packages that work the best include engagement from communities in meaningful ways. But they also make sure you’re not having a vocal minority drowning out the benefits and dragging out the process forever. There are timelines and certainty attached to it while still having meaningful local engagement.
Our industry absolutely has to continue to lean into more local engagement and community engagement around the benefits of a project and what they can deliver for a community. I also think there’s a fair amount of making sure the state is creating that pathway, providing that certainty, so we can actually move forward to build out these projects.
From the federal government’s perspective, they’re cracking down on wind and solar projects while changing the tax credits. Do you see states presenting their own incentives for renewables in lieu of federal incentives? I’ve wondered if that’ll happen given inflation and affordability concerns.
No, I think we have to be really creative as an industry, and state leaders have to be creative too. If I’m a governor, affordability concerns were already front and center for me, and now given what just happened, they’re grappling with incredibly tight state budgets that are about to get tighter, including health care. They’re going to see state budgets hit really hard. And there’s energy impacts – we’re cutting off supply, so we’re going to see prices go up.
This is where governors and state leaders can act but I think in this context of tight state budgets I don’t think we can expect to see states replacing incentive packages.
It’ll be: how do we take advantage of all the flexible tools that we have to help shape and reduce demand in meaningful ways that’ll save consumers money, as well as push on building out projects and getting existing juice out of the transmission system we have today.
Is there a future for wind in the United States?
It is an incredibly challenging environment – no question – for all of our technologies, wind included. I don’t want to sugar-coat that at all.
But I look at the whole picture, and I include wind in this: the technologies have improved dramatically in the past couple of decades and the costs have come down. When you look around at what resources are around to deploy, it’s advanced energy. We’re seeing it continue to grow. There’ll be headwinds, and it’ll be more expensive for all of us. But I look at what our industry and our technologies are able to offer and deliver, and I am confident we’ll continue to see growth.
The Grain Belt Express was just the beginning.
The anti-renewables movement is now coming for transmission lines as the Trump administration signals a willingness to cut off support for wires that connect to renewable energy sources.
Last week, Trump’s Energy Department with a brief letter rescinded a nearly $5 billion loan guarantee to Invenergy for the Grain Belt Express line that would, if completed, connect wind projects in Kansas to areas of Illinois and Indiana. This decision followed a groundswell of public opposition over concerns about land use and agricultural impacts – factors that ring familiar to readers of The Fight – which culminated in Republican Senator Josh Hawley reportedly asking Donald Trump in a meeting to order the loan’s cancellation. It’s unclear whether questions around the legality of this loan cancellation will be resolved in the courts, meaning Invenergy may just try to trudge ahead and not pick a fight with the Trump administration.
But the Grain Belt Express is not an anomaly. Across the country, transmission lines tied to both renewable sources and more conventional fuels – both fossil and nuclear – are facing a growing chorus of angst and anguish from the same crowds that are fighting renewable energy. In some ways, it’s a tale as old as widespread transmission itself. But I am also talking about farmers, ranchers, and rural towns who all now mention transmission lines in the same exasperated breaths they use to bemoan solar, wind, and battery storage. Many of the same communities fighting zero-carbon energy sources see those conflicts as part of a broader stand against a new age of tech industrial build-out – meaning that after a solar or wind farm is defeated, that activism energy is likely to go elsewhere, including expanding the grid.
I’ve been trying to figure out if there are other situations like Grain Belt, where a project facing local headwinds could potentially be considered no longer investable from a renewables-skeptic federal perspective. And that’s why since Invenergy lost its cash for that project, I have been digging into the Cimarron Link transmission line, another Invenergy facility proposed to carry wind energy from eastern Oklahoma to the western part of the state, according to a map on the developer’s website.
Do you remember the campaign to ban wind energy in Oklahoma that I profiled at the start of this year? Well, one of the most prominent scalps that this activism movement has claimed was bagged in late 2024, when they successfully pressured Governor Kevin Stitt into opposing a priority transmission corridor proposed by the Biden administration. Then another one of the activists’ biggest accomplishments came through an anti-wind law enacted this year that would, among other things, require transmission projects to go through a new certification program before the state’s Corporation Commission. Many of the figures fighting Cimarron and another transmission line project – NextEra’s Heartland Spirit Connector – are also involved in fighting wind and solar across the state, and see the struggles as part and parcel with each other.
Invenergy appears to want to soldier on through this increasingly difficult process, or at least that’s according to a letter some landowners received that was posted to Facebook. But these hurdles will seriously impact the plausibility that Cimarron Link can be completed any time soon.
Now, on top of these hurdles, critics want Cimarron Link to get the Grain Belt treatment. Cimarron Link was told last fall it was awarded north of $300 million from the Energy Department as a part of DOE’s Transmission Facilitation Program.
Enter Darren Blanchard, a farmer who says his property is in the path of Cimarron Link and has been one of the main public faces of opposition against the project. Blanchard has recently been pleading with the DOE to nix the disposition of that money if it hasn’t been given already. Blanchard wrote the agency a lengthy request that Cimarron get similar treatment to Grain Belt which was made public in the appendix of the agency’s decision documents related to the loan cancellation (see page 23 of this document).
To Blanchard’s surprise, he got a reply from the Transmission Facilitation Program office “responding on behalf of” Energy Secretary Chris Wright. The note, to him, read like they wanted him to know they saw his comment: “We appreciate you taking the time to share your views on the project,” it read.
Now, this might’ve been innocuous. I haven’t heard back from the Energy Department about Cimarron Link and I am personally skeptical of the chances a grant is canceled easily. There is no high-level politician calling for the cancellation of this money right now, like there was in Sen. Josh Hawley and the Grain Belt Express.
But I do believe that if there is a will, there is a way with the Trump administration. And as anti-renewables sentiments abound further, there’ll be more ways to create woe for transmission projects like Cimarron that connect to renewable resources. Should voices like Blanchard aim their sights at replicating what happened with Grain Belt, well… bets may be off.
Over the next few weeks, I will be chronicling more fights over individual transmission projects connected to zero-carbon sources. Unique but with implications for a host of proposed wires across the country, they’re trend-setters, so to speak. Next week I’ll be tackling some power lines out West, so stay tuned.