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A little insulation goes a long way toward decarbonizing.
When you think about ways to decarbonize, your mind will likely go straight to shiny new machines — an electric vehicle, solar panels, or an induction stove, perhaps. But let’s not forget the low-tech, low-hanging fruit: your home itself.
Adding insulation, fixing any gaps, cracks or leaks where air can get out, and perhaps installing energy efficient windows and doors are the necessary first steps to decarbonizing at home — though you may also want to consider a light-colored “cool roof,” which reflects sunlight to keep the home comfortable, and electric panel and wiring upgrades to support broader electrification efforts.
Getting started on one or multiple of these retrofits can be daunting — there’s lingo to be learned, audits to be performed, and various incentives to navigate. Luckily, Heatmap is here to help.
Cora Wyent is the Director of Research at Rewiring America, where she conducts research and analysis on how to rapidly electrify the entire economy.
Joseph Lstiburek is the founding principal at the Building Science Corporation, a consulting firm focused on designing and constructing energy efficient, durable, and economic buildings.
Lucy de Barbaro is the founder and director of Energy Efficiency Empowerment, a Pittsburgh-based organization that seeks to transform the home renovation process and help low and middle-income homeowners make energy efficiency improvements.
Definitively, yes! When people hear the word “insulation” they often think of how it can protect them from the cold. And while it certainly does do that, insulation’s overall role is to slow the transfer of heat both out of your home when it’s chilly and into your home when it’s hot. That means you won’t need to use your air conditioning as much during those scorching summer days or your furnace as much when the temperatures drop.
Quite possibly! The most definitive way to know if your home could be improved by weatherization is by getting a home energy audit —- more on that below. While a specific level of insulation is required for all newly constructed homes, these codes and standards are updated frequently. So if you’re feeling uncomfortable in your living space, or if you think your heating and cooling bills are unusually high, it’s definitely worth seeing what an expert thinks. And if you’re interested in getting electric appliances like a heat pump or induction stove, some wiring upgrades will almost certainly be necessary.
Energy efficient appliances like electric heat pumps or induction stoves are fantastic ways to decarbonize your life, but serve a fundamentally different purpose than most of the upgrades that we’re going to talk about here. When you get better air sealing, insulation, windows, or doors, what you’re doing is essentially regulating the temperature of your home, making you less reliant on energy intensive heating and cooling systems. And while this can certainly lead to savings on your energy bill and a positive impact on the environment at large, these upgrades will also allow you to simply live more comfortably.
This is the starting point for making informed decisions about any energy efficiency upgrades that you’re considering. During a home energy audit, a certified auditor (sometimes also referred to as an energy assessor or rater or verifier) will inspect your home to identify both the highest-impact and most cost-effective upgrades you can make, including how much you stand to save on your energy bills by doing so.
Wyent told me checking with your local utility is a good place to start, as many offer low-cost audits. Even if your utility doesn’t do energy assessments, they may be able to point you in the direction of local auditors or state-level resources and directories. The Residential Energy Services Network also provides a directory of certified assessors searchable by location, as does the Department of Energy’s Energy Score program, though neither list is comprehensive.
Audits typically cost between $200 and $700 depending on your home’s location, size, and type, as well as the scope of the audit. Homeowners can claim 30% of the cost of their audit on their federal taxes, up to $150. To be eligible, make sure you find a certified home energy auditor. The DOE provides a list of recognized certification programs.
Important: Make sure the auditor performs both a blower door test and a thermographic inspection. These diagnostic tools are key to determining where air leakage and heat loss/gain is occurring.
Your energy audit isn’t the only thing eligible for a credit. The 25C Energy Efficient Home Improvement Credit allows homeowners to claim up to 30% of the cost of a variety of home upgrades, up to a combined total of $1,200 per year. This covers upgrading your insulation, windows, doors, skylights, electrical wiring, and/or electrical panel. Getting an energy audit is also included in this category.
While $1,200 is the max amount you can claim for all retrofits combined, certain renovations come with their own specific limitations. Let’s break it down:
State and local incentives:
Depending on where you live, there may be additional state and local incentives, and we suggest asking your contractor what you are eligible for. But since incentive programs change frequently, it’s a good idea to do your own research too. Get acquainted with Energy Star, a joint program run by the Environmental Protection Agency and the DOE which provides information on energy efficient products, practices, and standards. On Energy Star’s website, you can search by zip code for utility rebates that can help you save on insulation, windows, and electrical work.
“Starting by looking at your local utility programs can be a great resource too, because utilities offer rebates or incentives for weatherizing your home or installing a new roof,” said Wyent.
Everyone wants to minimize the number of times they break open or drill into their walls. To that end, it’s useful to plan out all the upgrades you might want to get done over the next five to 10 years to figure out where efficiency might fit in.
Some primary examples: Installing appliances like a heat pump, induction stove, or Level 2 EV charger (all of which you can read more about in our other guides) often require electrical upgrades. Even if you don’t plan to get any of these new appliances now, pre-wiring your home to prepare for their installation (with the exception of a heat pump — see our heat pump guide for more info on that) will save you money later on.
De Barbaro also notes that if you’re planning to repaint your walls anytime soon, this would also be a convenient time to add insulation, as that involves drilling holes which then need to be patched and repainted anyway. Likewise, if you were already planning to replace your home’s siding, this would be a natural time to insulate. Finally, if you’re planning to get a heat pump in the coming years, getting better insulation now will ensure this system is maximally effective.
Conversely, if you’re cash-strapped, spreading out electrical and weatherization upgrades over the course of a few years allows you to claim the full $1,200 tax credit every year. Whether those tax savings are enough to cover the added contractor time and clean-up costs, though, will depend on the particulars of your situation.
“Come in with a plan and talk to the contractor about everything that you want to do in the future, not just immediately,” said Wyent.
Unlike solar installers, which are often associated with large regional and national companies, the world of weatherization and electrical upgrades is often much more localized, meaning you’ll need to do a bit of legwork to verify that the contractors and installers you come across are reliable.
Wyent told me she typically starts by asking friends, family, and neighbors for references, as well as turning to Google and Yelp reviews. Depending on where you live and what type of work you want done, your local utility may also offer incentives for weatherization and electrification upgrades, and can possibly provide a list of prescreened contractors who are licensed and insured for this type of work.
These questions will help you vet contractors and gain a better understanding of their process regardless of the type of renovation you’re pursuing.
Common wisdom says you should always get three quotes. But that doesn’t mean you should automatically choose the cheapest option. Lstiburek says the old adage applies: “If it sounds too good to be true, it's probably too good to be true.” Be sure that your contractors and installers are properly licensed and insured and read the fine print of your contract. Beyond this, how to find qualified professionals and what to ask largely depends on the type of upgrade you are pursuing. So let’s break it down, starting with the biggest bang for your buck.
Air sealing and insulating your home is usually the number one way to increase its energy efficiency. Energy Star says nine out of 10 homes are underinsulated, and many also have significant air leaks. In general, homes lose more heating and cooling energy through walls and attics than through windows and doors, so air sealing and adding insulation in key areas should be your first priority.
“People don't realize how collectively, small holes everywhere add up. So on average here in Pennsylvania, typically those holes would add up to the surface of three sheets of paper, continuously open to the outdoors,” said de Barbaro.
Determining where air is escaping is the purpose of the blower door test and the thermographic inspection, so after your energy audit you should have a good idea of where to begin with these retrofits. This guide from the Department of Energy is a great resource on all the places in a home one might consider insulating.
Choosing an insulation type:
Every home is different, and the type of insulation you choose will depend on a number of factors including where you’re insulating, whether that area is finished or unfinished, what R-Value is right for your climate, and your budget. You can check out this comprehensive list of different insulation types to learn about their respective advantages and use cases. But when it comes to attic rafters and exterior walls, De Barbaro said that one option rises above the rest.
“The magic word here is dense-packed cellulose insulation!” De Barbaro told me.
This type of insulation (which falls under the “loose fill and blown-in” category) is made from recycled paper products, meaning it has very low embodied carbon emissions. It’s also cheap and effective. For exterior walls and attic rafters, be sure to avoid loose-fill cellulose, as that can settle and become less effective over time — although for attic floors, loose-fill works well. Both are installed by drilling holes into the wall or floor space and blowing the insulation in under pressure.
We recommend discussing all of these options with your contractor, but here are the other materials you’re most likely to come across:
In addition to asking friends, family, and your local utility for contractor recommendations, Energy Star specifically recommends these additional resources where you can find licensed and insured contractors for insulation work.
While air sealing and insulation should definitely be number one on your weatherization checklist, plenty of heat gets lost through windows, doors, and skylights, as well. Single pane glass is a particularly poor insulator, and while fewer houses these days have it, upgrading to double or triple pane windows or skylights can be a big energy saver. Likewise, steel or fiberglass doors are much better insulators than traditional wooden doors.
But be warned: These can be pricey upgrades. The cost of installing windows alone ranges from hundreds of dollars up to $1,500 per window, and many homes have ten or more. It’s unlikely you’ll fully recoup the outlay through your energy savings, so before going about these retrofits, be sure that you’ve taken care of the easy stuff first.
Once you’ve done your research, it’s time to schedule a consultation with an installer, who can help you refine your project needs, discuss design and installation options, and provide you with a quote.
“So if you pick a Marvin window, make sure that you have a Marvin certified installer in your location, installing the Marvin window according to the Marvin instructions.” said Lstiburek.
Insulating your attic floor or your roof rafters is the best way to ensure that your home is sealed off from the elements. But if you live in a hot climate and need a new roof anyway (most last 25 to 50 years), then you might consider getting a cool roof, which can be made from a variety of materials and installed on almost any slope. However, they won’t lead to energy efficiencies in all geographies, so be sure to do your research beforehand!
Last but certainly not least is a retrofit that’s a little different from the rest. Unlike getting insulation, new windows, or a new roof, upgrading your wiring or electric panel doesn’t lead to greater energy efficiency by regulating the temperature of your home. What it does instead is enable greater energy efficiency by making it possible to operate an increasing number of electrified appliances and devices in your house.
For example, getting an electric or induction stove or dryer, a standard heat pump, a heat pump water heater, or an electric vehicle charger will require that you add new electric circuits to support these devices. And as these new loads add up, you may need to install a larger electric panel to support it all.
After sourcing electrician recommendations from family and friends, a good place to turn is Rewiring America’s contractor directory network. (Rewiring America is also a sponsor of Decarbonize Your Life.)Networks in your area can then provide you with a list of qualified electricians.
“Most people are really only using somewhere around 40% of what their current panels space. So you can actually add a fair amount of new circuits to your existing panel and upgrade your wiring while not having to upgrade your panel at all,” Wyent said.
Once you have three quotes in hand, all that’s left to do is evaluate your options, choose a contractor or installer, and sign a contract. Cost will likely be a major factor in the decision, but you’ll also want to ensure that the cheapest quote doesn’t mean corners will be cut. Here’s what to look out for.
Pay close attention to warranties. This applies both to the warranty for the work being performed and to the warranties for the products themselves. If an installation job or a product is well priced but comes with a short warranty, this should give you pause.
Avoid “same day signing specials.” If you’re being rushed into signing a contract, this is also a bad sign. Be sure to read the fine print — most cost estimates should be good for a few weeks at minimum.
Get specific. Your quotes should specify the type of work being performed, the scope of the work, cost (broken down by materials, labor, permits, and other expenses), payment method, and a tentative timeline for completion. A quote is much less formal than a contract, so if some of this information isn’t provided up front, don’t hesitate to ask for clarification so that you can make apples-to-apples comparisons between different contractors.
When you get a contract in hand, double check that:
Then it’s time to sign, sit back, and enjoy the soothing sounds of hammering, drilling, insulation blowing, and wire tinkering, content in knowing that you’re decarbonizing your home down to its very bones!
Now that you’re living comfortably in a maximally energy efficient home, you’re probably wondering when you’ll start seeing all those incentives you researched pay off. First off, know that you must wait until all renovations are complete and paid for to claim your federal tax credit. That means that even if you purchased new windows this year, if you have them installed in 2025, you’ll file for a tax credit with your 2025 return. Here’s how to go about it.
For state and local incentives, check the website for your local utility as well your local and state government and energy office to see what documentation is required. When in doubt, keep all of your records and receipts!
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Ambient Carbon is doing the methane equivalent of point source carbon capture in dairy barns.
In the world of climate and energy, “emissions” is often shorthand for carbon dioxide, the most abundant anthropogenic greenhouse gas in the world. Similarly, talk of emissions capture and removal usually centers on the growing swath of technologies that either prevent CO2 from entering the atmosphere or pull it back out after the fact.
Discussions and frameworks for reducing methane, which is magnitudes more potent than CO2 in the short-term, have been far less common — but the potential impact could be huge.
“If you can accelerate the decrease of methane in the atmosphere, you actually could have a much more significant climate impact, much faster than with CO2,” Gabrielle Dreyfus, chief scientist at the Institute for Governance & Sustainable Development, told me. “People often talk about gigatons of CO2 removal. But because of the potency of methane, for a similar level of temperature impact, you’re talking about megatons.”
Over the past year or so, this conversation has finally started to gain traction. Last October, the National Academies of Sciences, Engineering, and Medicine released a report on atmospheric methane removal, recommending that the U.S. develop a research agenda for methane removal technologies and establish methodologies to assess their impacts. Dreyfus chaired the committee that authored the report.
And one startup, at least — Denmark-based Ambient Carbon — is trying to commercialize its methane-zapping tech. Last week, the company announced that it had successfully trialed its “methane eradication photochemical system” at a dairy barn in Denmark, eliminating the majority of methane from the barn’s air. It’s also aiming to deploy a prototype in the U.S., at a farm in Indiana, by year’s end.
The way the company’s process works is more akin to point source carbon capture, in which emissions are pulled from a smokestack, than it is to something like direct air capture, in which carbon dioxide is removed from ambient air. Inside a dairy barn, cows are continually belching methane, producing high concentrations of the gas that are typically vented into the atmosphere. Instead, Ambient Carbon captures this noxious air from the barn’s ventilation ducts and brings it into an enclosed reactor.
Inside the reactor, which uses electricity from the grid, UV light activates chlorine molecules, splitting their chemical bonds to form unstable radicals. These radicals then react with methane, breaking down the potent gas and converting it into CO2, water, and other byproducts. The whole process mimics the natural destruction of atmospheric methane, which would normally take a decade or more, while Ambient Carbon’s system does it in a matter of seconds. Much of the chlorine gets recycled back into the process, and the CO2 is released into the air.
That might sound less than ideal. Famously, carbon dioxide is bad. This molecule alone is responsible for two-thirds of all human-caused global warming. But because methane is over 80 times as potent as CO2 over a 20-year timeframe, and since it would eventually break down into carbon dioxide in the atmosphere anyway, accelerating that inevitable process turns out to be a net good for the climate.
“The amount of CO2 produced by methane when it oxidizes has about 50 times smaller climate effect than the methane that produced it,” Zeke Hausfather, a climate scientist and climate research lead at Stripe, told me. “So you get a 98% reduction in the warming effects by converting methane to CO2, which I think is a pretty good deal.”
As he sees it, preventing methane emissions in the first place or destroying the molecules before they’re released, as Ambient Carbon is doing, is far more impactful than pursuing after-the-fact atmospheric methane removal. Because while CO2 can linger in the air for centuries — making removal a necessity for near-term planetary cooling — when it comes to methane, “if you cut emissions, you cool the planet pretty quickly, because all that previous warming from methane goes away over the course of a decade or two.”
Agriculture represents 40% of global methane emissions, the largest single source, making the industry a ripe target for de-methane-ization. Ambient Carbon’s tech is only really effective when methane concentrations are relatively high, the company’s CEO, Matthew Johnson, told me — which still leaves a large addressable market given that in many parts of the world, cows are mostly kept in dairy barns, where methane accumulates.
In its trial, Ambient Carbon’s system eliminated up to 90% of dairy barn methane at concentrations ranging from 4.3 parts per million to 44 parts per million. But while the system can theoretically operate at the lower end of that range, Johnson told me it’s only truly energy efficient at 20 parts per million and above. “It’s a question of cost benefit, because we could remove 99% [of the methane from dairy barns] but if you do that, that marginal cost is more energy,” Johnson explained, telling me that the company’s system will likely aim to remove between 80% to 90% of barn methane.
One reason methane destruction and removal technology hasn’t gained much traction is that capturing methane — whether from the atmosphere, a smokestack, or a ventilation duct — is far more challenging than capturing CO2, given that it’s so much less prevalent in the atmosphere. Atmospheric methane is relatively diffuse, with an average concentration of just about 2 parts per million, compared with roughly 420 parts per million for CO2. “I heard the analogy used that if pulling carbon dioxide out of the atmosphere is finding a needle in a haystack, pulling methane out of the atmosphere is pulling dust off the needle in that haystack,” Dreyfus told me.
Because of methane’s relative chemical stability, removing it from the air also requires a strong oxidant, such as chlorine radicals, to break it down. CO2 on the other hand, can be separated from the air with sorbents or membranes, which is a technically simpler process.
Other nascent approaches to methane destruction and removal include introducing chlorine radicals into the open atmosphere and adding soil amendments to boost the effectiveness of natural methane sinks. Among these options, Ambient Carbon’s approach is the furthest along, most well-understood, and likely also lowest-risk. After its successful field trial, “there is not much uncertainty remaining about whether or not this does the claimed thing,” Sam Abernethy, a methane removal scientist at the nonprofit Spark Climate Solutions, told me. “The main questions remaining are whether they can be cost-effective at progressively lower concentrations, whether they can get more methane destroyed per energy input. And that’s something they’ve been improving every year since they started.”
Venture firms have yet to jump onboard though. Thus far, Ambient Carbon’s funding has come from agricultural partners such as Danone North America and Benton Group Dairies, which are working with the company to conduct its field trials. Additional collaboration and financial support comes from organizations such as the Hofmansgave Foundation, a Danish philanthropic group, and Innovation Fund Denmark. Johnson told me the startup also has a number of unnamed angel investors.
Whether or not this tech could ever become efficient enough to tackle more dilute methane emissions — and thus make true atmospheric methane removal feasible — remains highly uncertain. Questions also remain about how these technologies, if proven to be workable, would ultimately be able to scale. For instance, would methane destruction and removal depend more on government policies and regulations, or on market-based incentives?
In the short term, voluntary corporate commitments appear to be the main drivers of interest when it comes to methane destruction specifically. “A lot of food companies have made public pledges that they’re going to reduce their greenhouse gas emissions,” Johnson told me. As he noted, ubiquitous brands such as Kraft Heinz, General Mills, Danone, and Starbucks have all joined the Dairy Methane Action Alliance, which aims to “accelerate action and ambition to drive down methane emissions across dairy supply chains,” according to its website.
The way Ambient Carbon envisions this market working, its food industry partners would be the ones to encourage farms to buy the startup’s methane-destroying units, and would pay farmers a premium for producing low-emissions products. This would enable farmers to cover the system’s cost within five years, and eventually generate additional revenue. Whether the food companies would pass the green premium onto consumers, however, remains to be seen.
But as with the carbon dioxide removal sector, voluntary corporate commitments and carbon crediting schemes will likely only go so far. “Most of what’s going to drive methane elimination is going to be policy,” Hausfather told me. Denmark, where Ambient Carbon conducted its first trial, is set to become the first country in the world to implement a tax on agricultural emissions, starting in 2030. Europe also has a comprehensive greenhouse gas reduction framework, as do states such as California, Washington, and New York.
“It’s such a low-hanging fruit of climate impacts that it’s hard to imagine it’s not going to be regulated pretty substantially in the future,” Hausfather told me. But stringent regulatory requirements are often shaped by the technologies that have been established as effective. And in that sense, what Ambient Carbon is doing today could help pave the way for the ambitious methane targets of tomorrow.
“Moving from a lot of the voluntary pledges that we have towards more mandatory requirements I think is going to have a really important role to play,” Dreyfus told me. “But I think it’s going to be easier if we have more proven technologies to get there.”
On tax credit deadlines, America’s nuclear export hopes, and data center flexibility
Current conditions: Hurricane Erin’s riptides continue lashing the Atlantic Coast, bringing 15-foot waves to the eastern end of New York’s Long Island • In Colorado, the Derby fire tripled in size to more than 2,600 acres, prompting evacuations in the county north of the ski enclave of Aspen • Heavy rain in Sydney set a new 18-year record.
Trump is preparing to onshore turbines, likely shrinking their numbers. Scott Olson/Getty Images
The Trump administration launched an investigation into imported wind turbines and parts, teeing up what Bloomberg called a “potential precursor to adding more tariffs on the clean-energy components.” The Department of Commerce started a national security probe on August 13 to query whether the imports undermine domestic production and put the country at risk from foreign opponents, according to a notice posted Thursday on the agency’s website. The agency already said this week that it would include wind turbines and related parts on the list of products facing 50% steel and aluminum tariffs. As of 2023, at least 41% of wind-related equipment to the U.S. came from Mexico, Canada, and China, according to figures Bloomberg cited from the consultancy Wood Mackenzie.
Also on Thursday, the Treasury Department published an FAQ document outlining the phaseout dates for eight key energy efficiency tax credits repealed under the One Big Beautiful Bill Act. The rules all deal with zero-carbon vehicles or energy efficiency rebates for home improvements.
As Heatmap’s Emily Pontecorvo and Robinson Meyer wrote when the first tranche of data on the programs came out around this time last year, millions of Americans had already taken advantage of at least one of the credits. But the uptake was largely concentrated among households earning $100,000 per year or more.
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For years, Westinghouse has been locked in an intellectual property dispute with South Korea’s two state-owned nuclear companies, as the American atomic energy giant accused the Korea Electric Power Corporation and its subsidiary, Korea Hydro & Nuclear Power, of ripping off its reactor technology. This week, the companies brokered a settlement that would keep the Korean giants from bidding on projects in North America, Europe, Japan, the United Kingdom, and Ukraine, effectively eliminating what is arguably the United States’ most capable rival outside of Russia and China from the key markets Washington wants to dominate. That could spur a lot more bids for Westinghouse’s flagship gigawatt-sized AP1000 reactor, projects for which are already underway in Poland, Slovakia, and Ukraine. But KoreaPro reported on Thursday that South Korea is pushing back on a deal Seoul fears infringes on its sovereignty.
In Sweden, meanwhile, the U.S.-Japanese joint venture GE Vernova-Hitachi Nuclear Energy secured a new deal to build its 300-megawatt small modular reactor that the government in Stockholm explicitly pitched as a bid to strengthen its trans-Atlantic security ties. “This is the beginning of something bigger, in many ways,” Ebba Busch, Sweden’s deputy prime minister, wrote in a post on LinkedIn. “As in the NATO process, Sweden is part of a larger movement.”
The Department of Energy extended its emergency order directing the J.H. Campbell Generating Plant in Michigan to remain open past its planned retirement. Secretary of Energy Chris Wright initially ordered the 1,420-megawatt coal station to stay online three months past its May 31 shutdown date, citing risks of electricity shortages in the Midcontinent Independent System Operator, the electrical grid that runs from the Upper Midwest down to Louisiana. Starting Thursday, the latest order directs the plant’s owners to keep the station running November 19. The consultancy Grid Strategies estimated last week that if the Trump administration expands the effort to cover all 54 aging fossil fuel plants slated for closure between now and 2028, the program will cost upward of $6 billion. Last week, the Federal Energy Regulatory Commission approved a framework for the utilities that own the affected plants to recoup the costs of operating the power stations past the closure dates from ratepayers, despite surging electricity prices.
The Data Center Coalition, a leading trade association representing the burgeoning server farm industry, has endorsed adopting programs to curb electricity demand when the grid is under stress. In a filing Thursday with the North Carolina Utility Commission, the industry group said it “supports exploring well-structured, voluntary demand-response and load flexibility programs for large load customers that allocates risk appropriately, provides clear incentives and compensation, and allows customers to meet their sustainability commitments.”
Researchers at Duke University put out an influential paper in February that found the U.S. could add gigawatts of additional demand from new data centers without building out an equivalent amount of generating plants if those facilities could curtail power usage when demand was particularly high. Heatmap’s Matthew Zeitlin described the strategy as “one weird trick for getting more data centers on the grid,” boiling down the approach simply as: “Just turn them off sometimes.” When I interviewed Tyler Norris, the study’s lead author, he pitched the idea as a way “to buy us some time” to figure out exactly how much electricity the artificial intelligence boom requires before we build out a bunch of gas plants that are even more expensive than usual due to the years-long backorder of turbines.
Researchers at the University of Houston claim to have made two major breakthroughs in carbon capture technology. The first breakthrough, published in the journal Nature Communications, introduces a new electrochemical process for filtering out carbon dioxide that avoids using a membrane like traditional carbon capture technology. The second, featured on the cover of the journal ES&T Engineering, demonstrates a new vanadium-based flow battery that could be used both to capture carbon and to store renewable energy. “We need solutions, and we wanted to be part of the solution. The biggest suspect out there is CO2 emissions, so the low-hanging fruit would be to eliminate those emissions,” Mim Rahimi, a professor at the University of Houston’s Cullen College of Engineering, said in a statement. “From membraneless systems to scalable flow systems, we’re charting pathways to decarbonize hard-to-abate sectors and support the transition to a low-carbon economy.”
A conversation with Scott Cockerham of Latham and Watkins.
This week’s conversation is with Scott Cockerham, a partner with the law firm Latham and Watkins whose expertise I sought to help me best understand the Treasury Department’s recent guidance on the federal solar and wind tax credits. We focused on something you’ve probably been thinking about a lot: how to qualify for the “start construction” part of the new tax regime, which is the primary hurdle for anyone still in the thicket of a fight with local opposition.
The following is our chat lightly edited for clarity. Enjoy.
So can you explain what we’re looking at here with the guidance and its approach to what it considers the beginning of construction?
One of the reasons for the guidance was a distinction in the final version of the bill that treated wind and solar differently for purposes of tax credit phase-outs. They landed on those types of assets being placed in service by the end of 2027, or construction having to begin within 12 months of enactment – by July 4th, 2026. But as part of the final package, the Trump administration promised the House Freedom Caucus members they would tighten up what it means to ‘start construction’ for solar and wind assets in particular.
In terms of changes, probably the biggest difference is that for projects over 1.5 megawatts of output, you can no longer use a “5% safe harbor” to qualify projects. The 5% safe harbor was a construct in prior start of construction guidance saying you could begin construction by incurring 5% of your project cost. That will no longer be available for larger projects. Residential projects and other smaller solar projects will still have that available to them. But that is probably the biggest change.
The other avenue to start construction is called the “physical work test,” which requires the commencement of physical work of a significant nature. The work can either be performed on-site or it can be performed off-site by a vendor. The new guidance largely parrotted those rules from prior guidance and in many cases transferred the concepts word-for-word. So on the physical work side, not much changed.
Significantly, there’s another aspect of these rules that say you have to continue work once you start. It’s like asking if you really ran a race if you didn’t keep going to the finish line. Helpfully, the new guidance retains an old rule saying that you’re assumed to have worked continuously if you place in service within four calendar years after the year work began. So if you begin in 2025 you have until the end of 2029 to place in service without having to prove continuous work. There had been rumors about that four-year window being shortened, so the fact that it was retained is very helpful to project pipelines.
The other major point I’d highlight is that the effective date of the new guidance is September 2. There’s still a limited window between now and then to continue to access the old rules. This also provides greater certainty for developers who attempted to start construction under the old rules after July 4, 2025. They can be confident that what they did still works assuming it was consistent with the prior guidance.
On the construction start – what kinds of projects would’ve maybe opted to use the 5% cost metric before?
Generally speaking it has mostly been distributed generation and residential solar projects. On the utility scale side it had recently tended to be projects buying domestic modules where there might have been an angle to access the domestic content tax credit bonus as well.
For larger projects, the 5% test can be quite expensive. If you’re a 200-megawatt project, 5% of your project is not nothing – that actually can be quite high. I would say probably the majority of utility scale projects in recent years had relied on the manufacturing of transformers as the primary strategy.
So now that option is not available to utility scale projects anymore?
The domestic content bonus is still available, but prior to September 2 you can procure modules for a large project and potentially both begin construction and qualify for the domestic content bonus at the same time. Beginning September 2 the module procurement wouldn’t help that same project begin construction.
Okay, so help me understand what kinds of work will developers need to do in order to pass the physical work test here?
A lot of it is market-driven by preferences from tax equity investors and tax credit buyers and their tax counsel. Over the last 8 years or so transformer manufacturing has become quite popular. I expect that to continue to be an avenue people will pursue. Another avenue we see quite often is on-site physical work, so for a wind project for example that can involve digging foundations for your wind turbines, covering them with concrete slabs, and doing work for something called string roads – roads that go between your turbines primarily for operations and maintenance. On the solar side, it would be similar kinds of on-site work: foundation work, road work, driving piles, putting things up at the site.
One of the things that is more difficult about the physical work test as opposed to the 5% test is that it is subjective. I always tell people that more work is always better. In the first instance it’s likely up to whatever your financing party thinks is enough and that’s going to be a project-specific determination, typically.
Okay, and how much will permitting be a factor in passing the physical work test?
It depends. It can certainly affect on-site work if you don’t have access to the site yet. That is obviously problematic.
But it wouldn’t prevent you from doing an off-site physical work strategy. That would involve procuring a non-inventory item like a transformer for the project. So there are still different things you can do depending on the facts.
What’s your ultimate takeaway on the Treasury guidance overall?
It certainly makes beginning construction on wind and solar more difficult, but I think the overall reaction that I and others in the market have mostly had is that the guidance came out much better than people feared. There were a lot of rumors going around about things that could have been really problematic, but for the most part, other than the 5% test option going away, the sense is that not a whole lot changed. This is a positive result on the development side.