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A new report from Rhodium Group takes stock of how Trump’s policies will affect America’s emissions future.

In less than a year, the Trump administration has fully transformed U.S. climate and energy policy. The changes have come through the tax code, regulatory repeals, and sweeping but fickle tariffs. Taken together, it means that the worst-case scenario for climate action under Biden has now become the best-case scenario under Trump.
That’s one of the key findings of the Rhodium Group’s latest Taking Stock report, an annual look at how U.S. policies will shape our energy system and emissions trajectory. It’s the first comprehensive assessment of the degree to which Trump’s second term, early as it is, could impede the energy transition. While total U.S. emissions are not expected to go up in the coming decade, the report projects greatly diminished progress compared to the path we were on a year ago.
That point is most clearly illustrated by the following finding: For the past two decades, the U.S. has been reducing emissions by an average of 1% per year. In the coming decade, Rhodium projects that Trump’s policies could reduce this rate by more than half.
Last year’s report, produced at the absolute peak of U.S. climate policy, modeled the effect of clean energy tax credits in the Inflation Reduction Act, new regulations on cars, trucks, power plants, and oil and gas operations, Biden’s freeze on new liquified natural gas export facilities, and a number of state-level policies. While these actions were not expected to be enough to fulfill Biden’s promise to the rest of the world under the Paris Agreement to cut emissions by 50% to 52% by 2030 compared to 2005, they represented America’s first credible show of climate leadership on the global stage. The report estimated that by 2035, we would be able to reduce greenhouse gas emissions 38% to 56%.
Now the low end of that spectrum has become overly optimistic. Rhodium has revised its estimate downwards to reflect revisions to the tax credits in the One Big Beautiful Bill Act — namely, the early end of subsidies for wind, solar, and EVs. The new report also takes into account tariffs, which primarily serve to reduce industrial activity in the U.S. in the near term, Congress’ cancellation of California’s vehicle emissions waivers, and Trump’s efforts to roll back greenhouse gas regulations. The result is that Rhodium expects emissions to decline by 26% to 35% by 2035.
The gap between this projection and last year’s represents about 800 million to 1.3 billion metric tons of carbon. On the high end, that’s roughly equivalent to the emissions from California, Texas, and Michigan combined.
The estimates are expressed as a range because the report looks at what would happen under three different scenarios. The highest emissions scenario models a world where oil and gas prices remain low, clean technology costs remain high, and the economy grows faster than current projections. The low emissions scenario is the opposite — it shows how Trump’s policies will affect our trajectory if oil and gas prices are higher, clean technologies see steeper cost declines and performance improvements, and economic growth is more aligned with current projections. The mid-emissions scenario splits the difference.
The most significant policies for shifting our emissions trajectory, according to Ben King, one of the report’s authors, are the combination of tax credits and regulations affecting the power sector. The regulations, in particular, mean the difference between having almost no coal plants on the grid by 2040 and retaining as many as 77 gigawatts of coal power by that date. “That’s still a massive decline in the amount of coal relative to what we have today,” King said, “but it is a very different-looking grid than if those regulations were to stay in place.”
Whether coal plants are replaced by clean energy or natural gas largely depends on the cost of each. Somewhat counterintuitively, the report projects less coal in the high emissions scenario because low natural gas prices mean that gas plants supplant both coal and renewables.
Even the forms of clean energy that the Trump administration supports, such as nuclear and geothermal, are not expected to play a significant role in reducing emissions over the next 15 years. For example, in the low emissions scenario, where oil and gas prices are high, about 2 gigawatts of new advanced nuclear is added to the grid in the 2030s. But because the tax credit for existing nuclear plants is set to expire in 2032, the models project that 2 gigawatts to 5 gigawatts of nuclear power will shut down in the 2030s, more than canceling out the additions.
The effect of unwinding transportation-related regulations and incentives is more straightforward — fewer EVs, higher emissions. Last year’s report projected that up to 72% of all light duty vehicle sales would be electric by 2032. The new report expects light duty EV sales to make up just 43% of the total, at most, by 2040. This is almost entirely due to the loss of greenhouse gas rules. If those remained in place, EV sales could reach 71% by 2040.
Perhaps the only bright side in the report is a section on household energy costs. The loss of tax credits for renewables and home efficiency upgrades will raise electricity bills compared to the projections in last year’s report. But despite that, Rhodium expects overall household energy costs to decrease in the coming decades — in all scenarios. That’s primarily due to the switch to electric vehicles, which lowers transportation costs for EV drivers and puts downward pressure on the cost of gasoline for everyone else.
No modeling exercise is perfect, and this one contains a number of caveats. One of the biggest points of uncertainty right now is how much energy demand from data centers will grow. The authors modeled just one pathway for data centers, with power demand nearly doubling by 2030 and more than tripling by 2040. But they note that analyst estimates fall as much as 80% higher or 80% lower. If demand turns out to be higher, “it would effectively turn up the dial on the trends that we’re seeing already,” King said.
Another area of uncertainty is that the Trump administration is working overtime to find creative new ways to stymie wind and solar development, as my colleague Jael Holzman has documented. It could turn out that these moves are even more effective than what Rhodium has captured in this report, King told me. With tariffs changing on a weekly, sometimes even daily basis, it was also difficult to capture how much of an impact they will have on technology prices, he said. Lastly, there’s a human behavior element that’s difficult for models to project.
“In the absence of government support, this is all going to happen on the basis of what private investors see as wise moves moving forward,” King said. “I don’t know the extent to which they might look at the uncertainty that the Trump administration is introducing for some of these technologies, and say, ‘Gosh, I’m going to avoid that for the foreseeable future, and maybe even beyond.’”
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Things in Sulphur Springs are getting weird.
Texas Attorney General Ken Paxton is trying to pressure a company into breaking a legal agreement for land conservation so a giant data center can be built on the property.
The Lone Star town of Sulphur Springs really wants to welcome data center developer MSB Global, striking a deal this year to bring several data centers with on-site power to the community. The influx of money to the community would be massive: the town would get at least $100 million in annual tax revenue, nearly three times its annual budget. Except there’s a big problem: The project site is on land gifted by a former coal mining company to Sulphur Springs expressly on the condition that it not be used for future energy generation. Part of the reason for this was that the lands were contaminated as a former mine site, and it was expected this property would turn into something like a housing development or public works project.
The mining company, Luminant, went bankrupt, resurfaced as a diversified energy company, and was acquired by power giant Vistra, which is refusing to budge on the terms of the land agreement. After sitting on Luminant’s land for years expecting it to be used for its intended purposes, the data center project’s sudden arrival appears to have really bothered Vistra, and with construction already underway, the company has gone as far as to send the town and the company a cease and desist.
This led Sulphur Springs to sue Vistra. According to a bevy of legal documents posted online by Jamie Mitchell, an activist fighting the data center, Sulphur Springs alleges that the terms of the agreement are void “for public policy,” claiming that land restrictions interfering with a municipality’s ability to provide “essential services” are invalid under prior court precedent in Texas. The lawsuit also claims that by holding the land for its own use, Vistra is violating state antitrust law by creating an “energy monopoly.” The energy company filed its own counterclaims, explicitly saying in a filing that Sulphur Springs was part of crafting this agreement and that “a deal is a deal.”
That’s where things get weird, because now Texas is investigating Luminant over the “energy monopoly” claim raised by the town. It’s hard not to see this as a pressure tactic to get the data center constructed.
In an amicus brief filed to the state court and posted online, Paxton’s office backs up the town’s claim that the land agreement against energy development violates the state’s antitrust law, the Texas Free Enterprise and Antitrust Act, contesting that the “at-issue restriction appears to be perpetual” and therefore illegally anti-competitive. The brief also urges the court not to dismiss the case before the state completes its investigation, which will undoubtedly lead to the release of numerous internal corporate documents.
“Sulphur Springs has alleged a pattern of restricting land with the potential for energy generation, with the effect of harming competition for energy generation generally, which would necessarily have the impact of increasing costs for both Sulphur Springs and Texas consumers generally,” the filing states. “Evaluating the competitive effects of Luminant’s deed restrictions as well as the harm to Texans generally is a fact-intensive matter that will require extensive discovery.”
The Texas attorney general’s office did not respond to multiple requests for comment on the matter. It’s worth noting that Paxton has officially entered the Republican Senate primary, challenging sitting U.S. Senator John Cornyn. Contrary to his position in this case, Paxton has positioned himself as a Big Tech antagonist and fought the state public utilities commission in pursuit of releasing data on the crypto mining industry’s energy use.
A solar developer gets into a forest fight in California, and more of the week’s top conflicts around renewables.
1. Sacramento County, California – A solar project has become a national symbol of the conflicts over large-scale renewables development in forested areas.
2. Sedgwick County, Kansas – I am eyeing this county to see whether a fight over a solar farm turns into a full-blown ban on future projects.
3. Montezuma County, Colorado – One southwest Colorado county is loosening restrictions on solar farms.
4. Putnam County, Indiana – An uproar over solar projects is now leading this county to say no to everything, indefinitely.
5. Kalamazoo County, Michigan – I’m eyeing yet another potential legal challenge against Michigan’s permitting reform efforts.
A conversation with Renee Grabe of Nature Forward
This week’s conversation is with Renee Grabe, a conservation advocate for the environmental group Nature Forward who is focused intently on data center development in Northern Virginia. I reached out to her for a fresh perspective on where data centers and renewable energy development fits in the Commonwealth amidst heightened frustration over land use and agricultural impacts, especially after this past election cycle. I thought her views on policy-making here were refreshingly nuanced.
This transcript was lightly edited for clarity.
Tell me more about how you started focusing on data centers.
So, in Fairfax County, in 2020 or 2021, people were pursuing the construction of an indoor ski facility on a landfill. From a climate perspective, to build something that would need to be cooled 24/7 for indoor skiing seemed like a very bad proposal in terms of energy usage. And for what kind of gain?
Then our friends at the Sierra Club were saying, indoor ski slopes? Bad, yes. But data centers? Way, way worse. Those aren’t cooling to support snow but are cooling much larger areas on a much larger scale, dwarfing the area of that one ski slope. This was around the time the Prince William Digital Gateway was showing up – they were saying all these acres of agricultural lands and single-family housing zones were about to be rezoned. This was a big deal, and Sierra Club led the way in opening our eyes to this. The rezoning ultimately passed. The data centers were sued and the people who filed the lawsuit won, but pre-planning for the centers is still allowed to take place.
The way we think about the impacts of data centers, besides the loss of natural lands and the amount of energy that’s going to be needed to power these things, has been diesel generators. These are the things that are backup generation and the camel’s nose under the tent is trying to get them to be primary power.
Now I want to ask you a provocative question: is there any middle ground between letting these projects be built unfettered and outright bans on their development?
We have no regulation today. From our standpoint, these things are coming, they’re here. We know a lot more now than we did in 2022. As we make decisions about how and where to build these facilities we all need – I mean we’re using one right now. I use a data center all day at work. Teams conferencing. ChatGPT to answer a question. We need these. So if we’re going to build them, let’s not give a pass to some of the world’s largest and richest companies. Let’s ask them to put the guardrails on to protect our residences and our infrastructure to make sure they’re as sustainable as possible.
Okay, so what are the guardrails then?
The costs of what was going to go into a data center need to be more transparent. We need to bring accountability to the forefront right away as they’re being built.
In Ohio, they passed a law requiring data center companies to pay for a high percentage of the power they’re using. That cut a significant number of the projects in Ohio. This industry is so speculative and a land grab and a rush to be first to get the most.
You have this dichotomy of land values for residences being inundated, while land values for developers are skyrocketing. We have an affordability crisis going on and we are all on the hook for paying for the infrastructure to power these things.
So when you think about what regulation might make data center development more reasonable, it’s asking for the costs happening to be borne by the industry making them. Let’s get rid of some of the incentives for power users. We don’t need to be encouraging the loss of state revenue, either – we’re leaving money on the table to bring these facilities here.
Lastly, our readers love to get hyperlocal. I know you’re intently focused on Fairfax County right now which has been a big part of the data center boom in Virginia – what’s happening there?
There are a couple things that have happened over the course of this past year. Fairfax County passed a data center zoning ordinance amendment – minimum requirements a data center will have to adhere to. The big thing with that one is, you have to have a special exception if you build within a mile of a Metro station. When you think about good land use and building a data center within a walkable distance of a Metro, that’s eye-openingly poor land use policy and a missed opportunity for transit-oriented development. It doesn’t mean they can’t be built near one but you have to get a special exception.
Some things can’t be regulated at the local level. Like generators. That’s in the hands of the state.
Last night, we had a public hearing at the Fairfax County board level for our policy plan – our comprehensive plan providing guidance for developers who want to get a special exception or rezoning. It is not law. It is not required. It is a visionary document that helps us get to better. They’ve added a section for data centers in that. In May, staff put forward something pretty good, making sure data centers met a minimum level of efficiency. But our chairman of the county board said it went above and beyond our zoning ordinance and said he didn’t think it was appropriate, so staff rewrote that section and stripped out a lot of the specificity and higher standards that were in that document.
At the hearing, they deferred a decision, listening to the public but not having a discussion at the board level. They’ve left the record open through December 9th.