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A new report from the Clean Air Task Force casts shade on “levelized cost of energy.”
Forgive me, for I have cited the levelized cost of energy.
That’s what I was thinking as I spoke with Kasparas Spokas, one of the co-authors of a new paper from the Clean Air Task Force that examines this popular and widely cited cost metric — and found it wanting.
Levelized cost of energy, or LCOE, is a simple calculation: You take a generator, like a solar panel (with a discount for future costs), and add up its operating and capital expenditures, and then divide by the expected energy output over the life of the project (also discounted).
LCOE has helped underline the economic and popular case for renewables, especially solar. And it’s cited everywhere. The investment bank Lazard produces an influential annual report comparing the LCOE of different generation sources; the latest iteration puts utility-scale solar as low as $29 per megawatt-hour, while nuclear can be as high as $222. Environmental groups cite LCOE in submissions to utilities regulators. Wall Street analysts use it to project costs. And journalists, including me, will cite it to compare the cost of, say, solar panels to natural gas.
We probably shouldn’t, according to Spokas — or at least we should be more clear about what LCOE actually means.
“We continue to see levelized cost of electricity being used in ways that we think are not ideal or not adequate to what its capabilities are,” Spokas told me.
The report argues that LCOE “is not an appropriate tool to use in the context of long-term planning and policymaking for deep decarbonization” because it doesn’t take into account factors that real-world grids and grid planners also have to consider, such as when the generator is available, whether the generator has inertia, and what supporting infrastructure (including transmission and distribution lines) a generator needs to supply power to customers.
We see these limitations and constraints on real-life grids all the time, for instance in the infamous solar “duck curve.” During the middle of the day, when the sun is highest, non-solar generation can become essentially unnecessary on a solar-heavy grid. But these grids can run into problems as the sun goes down but electricity demand persists. In this type of grid, additional solar may be low cost, but also low value — it gives you electricity when you need it the least.
“If you’re building a lot of solar in the Southwest, at some point you’ll get to the point where you have enough solar during the day that if you build an incremental amount of solar, it’s not going to be valuable,” Spokas said. To make additional panels useful, you’d have to add battery storage, increasing the electricity’s real-world cost.
Looking for new spots for renewables also amps up conflict over land use and provides more opportunities for political opposition, a cost that LCOE can’t capture. And a renewables-heavy grid can require investments in energy transmission capacity that other kinds of generation do not — you can put a gas-fired power plant wherever you can buy land and get permission, whereas utility-scale solar or wind has to be where it’s sunny or windy.
“The trend is, the more renewable penetration you have, the more costly meeting a firm demand with renewables and storage becomes,” Spokas said.
Those real-world pressures are now far more salient to grid planners than they were earlier this century, when LCOE became a popular metric to compare different types of generators.
“The rise of LCOE’s popularity to evaluate technology competitiveness also coincided with a period of stagnant load growth in the United States and Europe,” the report says. When there was sufficient generation capacity that could be ramped up and down as needed, “the need to consider various system needs and costs, such as additional transmission or firm capacity needs was relatively low.”
This is not the world we’re in today.
Demand for electricity is rising again, and the question for grid planners and policymakers now is less how to replace fossil generators going offline, and more how to meet new electricity demand in a way that can also meet society’s varied goals for cost and sustainability.
This doesn’t always have to mean maxing out new generation — it can also mean making large sources of electricity load more flexible — but it does mean making more difficult, more considered choices that take in the grid as a whole into account.
When I asked Spokas whether grid operators and grid planners needed to read this report, he chuckled and said no, they already know what’s in it. Electricity markets, as imperfect as they often are, recognize that not every megawatt is the same.
Electricity suppliers often get paid more for providing power when it’s most needed. In regions with what’s known as capacity markets, generators get paid in advance to guarantee they’ll be available when the grid needs them, a structure that ensures big payouts to coal, gas, and nuclear generators. In markets that don’t have that kind of advance planning, like Texas’ ERCOT, dispatchable generators (often batteries) can get paid for providing so-called “ancillary services,” meeting short term power needs to keep the grid in balance — a service that batteries are often ideally placed to provide.
When grid planners look at the entirety of a system, they often — to the chagrin of many renewables advocates — tend to be less enthusiastic about renewables for decarbonizing the energy system than many environmental groups, advocates, and lawmakers.
The CATF report points to Ontario, Canada where the independent system operator concluded that building a new 300-megawatt small modular nuclear reactor — practically the definition of high LCOE generation, not least because such a thing has never been deployed before in North America — would actually be less risky for electricity costs than building more battery-supported wind and solar, according to the Globe and Mail. Ontario regulators recently granted a construction license to the SMR project, which is part of a larger scheme to install four small reactors, for a total 1.2 gigawatts of capacity. To provide the equivalent supply of renewable energy would require adding between 5.6 and 8.9 gigawatts of wind and solar capacity, plus new transmission infrastructure, the system operator said, which could drive up prices higher than those for advanced nuclear.
None of this is to say that we should abandon LCOE entirely. The best use case, the report argues, is for comparing costs for the same technology over time, not comparing different technologies in the present or future. And here the familiar case for solar — that its cost has fallen dramatically over time — is borne out.
Broadly speaking, CATF calls for “decarbonization policy, industry strategy, and public debate” to take a more “holistic approach” to estimating cost for new sources of electricity generation. Policymakers “should rely on jurisdiction-specific system-level analysis where possible. Such analysis would consider all the system costs required to ensure a reliable and resilient power system and would capture infrastructure cost tradeoffs over long and uncertain-time horizons,” the report says.
As Spokas told me, none of this is new. So why the focus now?
CATF is catching a wave. Many policymakers, grid planners, and electricity buyers have already learned to appreciate all kinds of megawatts, not just the marginally cheapest one. Large technology companies are signing expensive power purchase agreements to keep nuclear power plants open or even revive them, diving into the development of new nuclear power and buying next-generation geothermal in the hope of spurring further commercialization.
Google and Microsoft have embraced a form of emissions accounting that practically begs for clean firm resources, as they try to match every hour of electricity they use with a non-emitting resource.
And it’s possible that clean firm resources could get better treatment than they currently get in the reconciliation bill working its way through Congress. Secretary of Energy Chris Wright recently called for tax credits for “baseload” power sources like geothermal and nuclear to persist through 2031, according to Foundation for American Innovation infrastructure director Thomas Hochman.
“It’s not our intention to try to somehow remove incentives for renewables specifically, but to the extent that we can preserve what we can, we’re happy if it would be used in that way,” Spokas said.
When I asked Spokas who most needed to read this report, he replied frankly, “I think climate advocates would be in that bucket. I think policymakers that have a less technical background would also be in that bucket, and media that have a less technical background would also be in there.”
I’ll keep that in mind.
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All of the administration’s anti-wind actions in one place.
The Trump administration’s war on the nascent U.S. offshore wind industry has kicked into high gear over the past week, with a stop work order issued on a nearly fully-built project, grant terminations, and court filings indicating that permits for several additional projects will soon be revoked.
These actions are just the latest moves in what has been a steady stream of attacks beginning on the first day Trump stepped into the White House. He appears to be following a policy wishlist that anti-offshore wind activists submitted to his transition team almost to a T. As my colleague Jael Holzman reported back in January, those recommendations included stop work orders, reviews related to national security, tax credit changes, and a series of agency studies, such as asking the Health and Human Services to review wind turbines’ effects on electromagnetic fields — all of which we’ve seen done.
It’s still somewhat baffling as to why Trump would go so far as to try and shut down a nearly complete, 704-megawatt energy project, especially when his administration claims to be advancing “energy addition, NOT subtraction.” But it’s helpful to see the trajectory all in one place to understand what the administration has accomplished — and how much is still up in the air.
January 20: Trump issues a presidential memorandum temporarily halting all new onshore and offshore wind permitting and leasing activities “in light of various alleged legal deficiencies underlying the Federal Government’s leasing and permitting of onshore and offshore wind projects,” while his administration conducts an assessment of federal review practices. The memo also temporarily withdraws all areas on the U.S. Outer Continental Shelf from offshore wind leasing.
March 14: The Environmental Protection Agency pulls a Clean Air Act permit for Atlantic Shores, which was set to deliver power into New Jersey.
April 16: The Department of the Interior issues a stop work order to Empire Wind, a New York offshore wind farm that began construction in 2024. Interior Secretary Doug Burgum accuses the Biden administration of giving the project a “rushed approval” that was “built on bad and flawed science,” citing feedback from the National Oceanic and Atmospheric Administration.
May 1: The Interior Department withdraws a Biden-era legal opinion for how to conduct permitting in line with the Outer Continental Shelf Lands Act that advised the Secretary to “strike a rational balance” between wind energy and fishing. The Department reinstated the opinion issued under Trump’s first term, which was more favorable to the fishing industry.
May 2: Anti-offshore wind group Green Oceans sends a 68-page report titled “Cancelling Offshore Wind Leases” to Secretary Burgum and acting Assistant Secretary for Lands and Minerals Management Adam Suess, according to emails uncovered by E&E News. The report “evaluates potential violations of Outer Continental Shelf Lands Act (OCSLA) and related Federal laws in addition to those generally associated with environmental protection.”
May 5: Seventeen states plus the District of Columbia file a lawsuit challenging Trump’s January 20 memo halting federal approvals of wind projects.
May 19: The Interior Department lifts the stop work order on Empire Wind after closed-door meetings between New York governor Kathy Hochul and President Trump, during which the White House later says that Hochul “caved” to allowing “two natural gas pipelines to advance” through New York. Hochul denies reaching any deal on pipelines during the meetings.
June 4: Atlantic Shores files a request with New Jersey regulators to cancel its contract to sell energy into the state.
July 4: Trump signs the One Big Beautiful Bill Act, which imposes new expiration dates on tax credits for wind and solar projects, including offshore wind, as well as on the manufacture of wind turbine components.
July 7: The Environmental Protection Agency notifies the Maryland Department of the Environment that the state office erred when issuing an air permit to the Maryland Offshore Wind Project, also known as MarWin, because the state specified that petitions to review the permit would go to state court rather than the federal agency. The state later disagrees.
July 17: New York regulators cancel plans to develop additional transmission capacity for future offshore wind development, citing “significant federal uncertainty.”
July 29: The Interior Department issues an order requesting reports that describe and provide recommendations for “trends in environmental impacts from onshore and offshore wind projects on wildlife” and the impacts that approved offshore wind projects might have on “military readiness.” The order also asserts that the Biden administration misapplied federal law when it approved the construction and operation plans of offshore wind projects.
July 30: The Interior Department rescinds all designated “wind energy areas” on the U.S. Outer Continental Shelf, which had been deemed suitable for offshore wind development.
August 5: The Interior Department eliminates a requirement to publish a five-year schedule of offshore wind energy lease sales and to update the lease sale schedule every two years.
August 7: The Interior Department initiates a review of offshore wind energy regulations “to ensure alignment with the Outer Continental Shelf Lands Act and America’s energy priorities under President Donald J. Trump.”
August 13: The Department of Commerce initiates an investigation into whether imports of onshore and offshore wind turbine components threaten national security, a precursor to imposing tariffs.
New Jersey regulators also decide to delay offshore wind transmission upgrades by two years. They officially cancel their contract with Atlantic Shores.
August 22: The Interior Department issues a stop work order on Revolution Wind, an offshore wind project set to deliver power to Rhode Island and Connecticut, citing national security concerns. The 65-turbine project is already 80% complete.
Interior also says in a court filing that it intends to “vacate its approval” of the Construction and Operations Plan for the Maryland Offshore Wind Project.
August 29: The Interior Department says in a court filing that it “intends to reconsider” its approval of the construction and operations plan for the SouthCoast wind project, which was set to deliver power to Massachusetts.
The Department of Transportation also withdraws or terminates $679 million for 12 offshore wind port infrastructure projects to “ensure federal dollars are prioritized towards restoring America’s maritime dominance” by “rebuilding America’s shipbuilding capacity, unleashing more reliable, traditional forms of energy, and utilizing the nation’s bountiful natural resources to unleash American energy.” The grants include:
September 3: The Interior Department says in a court filing that it intends to vacate its approval of the construction and operations plan for Avangrid’s New England Wind 1 and 2, which were set to deliver power to Massachusetts.
The New York Times also reports that the White House has instructed “a half-dozen agencies to draft plans to thwart the country’s offshore wind industry,” including asking the Department of Health and Human Services to study “whether wind turbines are emitting electromagnetic fields that could harm human health,” and asking the Defense Department to probe “whether the projects could pose risks to national security.”
September 4: The states of Rhode Island and Connecticut, as well as Orsted, file lawsuits challenging the stop work order on Revolution Wind.
At the start of all this, the U.S. had three offshore wind projects that were fully operational and five that were under construction. As of today, the Trump administration has halted just one of those five, but it has threatened to rescind approvals for each and every remaining fully permitted project that hasn’t yet broken ground.
The tumult has rippled out into the states, where regulators in Massachusetts and Rhode Island are delaying plans to sign contracts to procure additional energy from offshore wind projects.
Looking ahead, we can expect a few things to happen over the next few weeks. We’ll see the Interior Department formally begin to rescind permits, as it indicated it would do in numerous court filings. We’ll also likely get an opinion from a federal court in Massachusetts in the case that states filed fighting Trump’s Day One memo. Orsted also said it intends to ask for a temporary injunction, so it’s possible that Revolution Wind could resume construction soon.
It’s been barely a month since Jael dubbed the Trump administration’s tactics a “total war on wind.” While the result hasn’t been a complete shutdown of the industry, it seems he might still be in the early stages of his plan.
The Nimbus wind project in the Ozark Mountains is moving forward even without species permits, while locals pray Trump will shut it down.
The state of Arkansas is quickly becoming an important bellwether for the future of renewable energy deployment in the U.S., and a single project in the state’s famed Ozark Mountains might be the big fight that decides which way the state’s winds blow.
Arkansas has not historically been a renewables-heavy state, and very little power there is generated from solar or wind today. But after passage of the Inflation Reduction Act, the state saw a surge in project development, with more than 1.5 gigawatts of mostly utility-scale solar proposed in 2024, according to industry data. The state also welcomed its first large wind farm that year.
As in other states – Oklahoma and Arizona, for example – this spike in development led to a fresh wave of opposition and grassroots organizing against development. At least six Arkansas counties currently have active moratoria on solar or wind development, according to Heatmap Pro data. Unlike other states, Arkansas has actually gone there this year by passing a law restricting wind development and requiring all projects to have minimum setbacks on wind turbines from neighboring property owners of at least 3.5-times the height of the wind turbine itself, which can be as far as a quarter of a mile.
But activists on the ground still want more. Specifically, they want to stop Scout Clean Energy’s Nimbus wind project, which appears to have evaded significant barriers from either the new state law or a local ordinance blocking future wind development in Carroll County, the project’s future home. This facility is genuinely disliked by many on the ground in Carroll County; for weeks now, I have been monitoring residents posting to Facebook with updates on the movements of wind turbine components and their impacts to traffic. I’ve also seen the grumbling about it travel from the mouths of residents living near the project site to conservative social media influencers and influential figures in conservative energy policy circles.
The Nimbus project is also at considerable risk of federal intervention in some fashion. As I wrote about a few weeks ago, Nimbus applied to the Fish and Wildlife Service for incidental take approval covering golden eagles and endangered bats throughout the course of its operation. This turned into a multi-year effort to craft a conservation plan in tandem with permitting applications that are all pending approval from federal officials.
Scout Clean Energy still had not received permission by the time FWS changed hands to Trump 2.0, though – putting not only its permit but the project itself in potential legal risk. In addition, activists have recently seized upon risks floated by the Defense Department during development around the potential for the turbines to negatively impact radar capabilities, which previously resulted in the developer planning towers of varying heights for the blades.
These risks aren’t unique to Nimbus. Some of this is a reflection of how wind projects are generally so large and impactful that they wind up eventually landing in a federal nexus. But in this particular case, the fact that it seemed nothing could halt this project made me wonder if Trump was on the minds of people in Carroll County, too.
That’s how I wound up on the phone with Caroline Rogers, a woman living on Bradshaw Mountain near the Nimbus project site, who told me she has been fighting it since she first learned about it in 2023. Rogers and I chatted for almost an hour and, candidly, I found her to be an incredibly nice individual. When I asked her why she’s against the wind farm, she brought up a bunch of reasons I couldn’t necessarily fault her for, like concerns about property values and a lack of local civil services to support the community if there were a turbine failure or fire at the site.
“I still pray every day,” she told me when I asked her about whether she wants an outside force – à la Trump – to come in and do something to stop the facility. “There have been projects that have been stopped for various reasons, and there have been turbines that have been taken down.”
One of the things Rogers hopes happens is that the Fish and Wildlife Service’s bird crackdown comes for the Nimbus project, which is under construction even as it’s unclear whether it’ll ever get the take permits under the Trump administration. “Maybe it can be more of an enforcement [action],” she told me. “I hope it happens.”
This is where Trump’s unprecedented approach to energy development – and the curtailment of it – would have to cross a new rubicon. The Fish and Wildlife Service has rarely exercised its bird protection enforcement abilities against wind projects because of a significant and recent backlog in the permitting process related to applications from the sector. Bill Eubanks, an environmental attorney who works on renewables conflicts, told me earlier this week that if a developer is told by the agency it needs a permit, then “they’re on notice if they kill an eagle.” But while enforcement powers have been used before, it is “not that common.”
Even Rogers knows intervention from federal species regulators would be a potentially unprecedented step. “It can never stop a project that I’ve seen,” she told me.
Yet if Trump were to empower FWS to go after wind projects for violating species statutes, it is precisely this backlog that would make projects like Nimbus a potential target.
“They got so many applications from developers, and each one takes so much staff time to finalize,” Eubanks told me. “Even before January 20, there was already a significant backlog.”
Scout Clean Energy did not respond to requests for comment. If I hear from them or the Fish and Wildlife Service, I will let you know.
And more on the week’s most important conflicts around renewable energy projects.
1. Newport County, Rhode Island – The Trump administration escalated its onslaught against the offshore wind sector in the past week … coincidentally (or not) right after a New England-based anti-wind organization requested that it do so.
2. Madison County, New York – Officials in this county are using a novel method to target a wind project: They’re claiming it’ll disrupt 911 calls.
3. Wells County, Indiana – A pro-solar organization is apparently sending mass texts to people in this county asking them to sign a petition opposing a county-wide moratorium on new projects.
4. Henderson County, Kentucky – Planning officials in this county have recommended a two-year moratorium on wind power, sending the matter to a final vote before the county fiscal court.
5. Monterey County, California – Uh oh, another battery fire in central California.