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A counter-proposal for the country’s energy future.
American electricity consumption is growing for the first time in generations. And though low-carbon technologies such as solar and wind have scaled impressively over the past decade, many observers are concerned that all this new demand will provide “a lifeline for more fossil fuel production,” as Senator Martin Heinrich put it.
In response, a few policy entrepreneurs have proposed novel regulations known as “additionality” requirements to handle new sources of electric load. First suggested for electrolytic hydrogen, additionality standards would require that subsidized hydrogen producers source their electricity directly from newly built low-carbon power plants; in a Heatmap piece from September, Brian Deese and Lisa Hansmann proposed similar requirements for new artificial intelligence. And while AI data centers were their focus, the two argued that additionality “is a model that can be extended to address other sectors facing growing energy demand.”
There is some merit to additionality standards, particularly for commercial customers seeking to reduce their emissions profile. But we should be skeptical of writing these requirements into policy. Strict federal additionality regulations will dampen investment in new industries and electrification, reduce the efficiency of the electrical grid through the balkanization of supply and demand, and could become weapons as rotating government officials impose their views on which sources of demand or supply are eligible for the standards. The grid and the nation need a regulatory framework for energy abundance, not burdensome additionality rules.
After decades of end-use efficiency improvements, offshoring of manufacturing, and shifts toward less material-intensive economies, a confluence of emerging factors are pushing electricity demand back up again. For one, the nation is electrifying personal vehicles, home heating, and may do the same for industrial processes like steel production in the not-too-distant future, sparked by a combination of policy and commercial investment. Hydrogen, which has long been a marginal fuel, is attracting substantial interest. And technological innovation is leading to whole new sources of electric load — compute-hungry artificial intelligence being the most immediate example, but also large-scale critical minerals refining, indoor agriculture like alternative protein cultivation and aquaculture, and so on.
In recent years, clean energy has seemed to be on an unstoppable path toward dominating the power sector. Coal-fired generation has been in terminal decline in the United States as natural gas power plants and solar and wind farms have become more competitive. Flexible gas generation, likewise, is increasingly crowded out by renewables when the wind is blowing and the sun shining. These trends persisted in the context of stable electricity load. But even as deployment accelerates, low-carbon electricity supply may not be able to keep up with the surprisingly robust growth in demand. The most obvious — though not the exclusive — way for utilities and large corporates to meet that demand is often with new or existing natural gas capacity. Even a few coal plants have delayed retirement, reportedly in response to rising demand and reliability concerns.
Given the durable competitiveness of coal and especially natural gas, some form of additionality requirement might make sense for hydrogen production in particular, since hydrogen is not just a nascent form of electric load but a novel fuel in its own right. Simply installing an electrolyzer at an existing coal or natural gas plant could produce hydrogen that, from a lifecycle perspective, would result in higher carbon emissions, even if it displaces fossil fuels like gas or oil in final consumption. Even so, many experts caution that overly strict additionality standards for hydrogen at this stage are overkill, and may smother the industry in its crib.
Likewise, large corporate entities and electricity customers adopting additionality requirements for their own operations can bolster investment in so-called “clean firm” generation like nuclear, geothermal, and fossil fuels with carbon capture. In just the past month, Google announced plans to back the construction of new small nuclear reactors, and Microsoft announced plans to purchase electricity for new data centers from the shuttered Three Mile Island power plant, the plant made famous by the 1979 meltdown but which only closed down in 2019. Three Mile Island’s $100-per-megawatt-hour price tag would have been unthinkable just a few years ago but is newly attractive.
Notice the problem Microsoft is trying to solve here: a lack of abundant, reliable electricity generation. Outdated technology licensing, onerous environmental permitting processes, and other regulatory barriers are obstructing the deployment of renewables, advanced nuclear energy, new enhanced geothermal technologies, and low-carbon sources. Additionality fixes none of these issues. Of course, Deese and Hansmann propose “a dedicated fast-track approval process” for verifiably additional low-carbon generation supplying new sources of AI load. Yet this should be the central effort, not the after-the-fact add-on. The back and forth over additionality rules for the clean hydrogen tax credit is a case in point. The rules for the tax credit will (likely) be finalized by January, but lawsuits already loom over them. Expanding this contentious additionality requirement to apply to broad use cases will be even more contentious without solving the actual shortage data center companies care about. Conversations about additionality are a distraction and misplace the energies of policymakers and staff.
Substituting one regulatory thicket for another is a recipe for stasis. Instead of adding more red tape, we should be working to cut through it, fast-tracking the energy transition and fostering abundance.
With such broad requirements, what’s to stop future administrations from expanding them to cover electric vehicle charging, electric arc furnace steelmaking, alternative protein production, or any politically disfavored source of new demand? Could a second Trump Administration use additionality to punish political enemies in the tech industry? Could a Harris Administration do the same? What if a future administration maintained additionality standards for new sources of load, but required that the electricity come from fossil fuels instead of low-carbon sources?
Zero-sum regulatory contracts between sources of electricity supply and demand are not simply at risk of becoming a tool for handing out favors on a partisan basis — they already are one. Two pieces of model legislation proposed at the July meeting of the American Legislative Exchange Council, an organization of conservative state legislators that collaborate to write off-the-shelf legislative measures, would require public utility commissions to prioritize dispatchable generation and formally discourage intermittent renewable sources like solar and wind. One of the proposals suggests leaning on state attorneys general to extend the lifespans of coal plants threatened with retirement.
These proposals did not move forward this year, but it is unlikely that the motivating force behind them is exhausted. And whatever one thinks of the relative merits of intermittent versus firm generation, ALEC’s proposals demonstrate just how easily gamed regulations like additionality could be and the risks of relying on administrative discretion instead of universal, pragmatic rules.
This is not how the electric grid is supposed to work. The grid is, if not an according-to-Hoyle public good, a shared public resource, providing essential services to customers large and small. Homeowners don’t have to sign additionality contracts with suppliers when they buy an electric car or replace their gas furnace with an electric heat pump. Everyone understands that such requirements would slow the pace of electrification and investment in new industries. The same holds for corporate customers and novel sources of load.
The real problem facing the AI, hydrogen, nuclear, geothermal, and renewables industries is an inability to build. There are more than enough clean generators queueing to enter the system — 2.6 terawatts at last count, according to the Lawrence Berkeley National Laboratory. The unfortunate reality, however, is that just one in five of these projects will make it through — and those represent just 14% of the capacity waiting to connect. Still, this totals about 360 gigawatts of new energy generation over the next few years, much more than the predicted demand from AI data centers. Obstacles to technology licensing, permitting, interconnection, and transmission are the key bottlenecks here.
Would foregoing additionality requirements and loosening regulatory strictures on technology licensing and permitting increase the commercial viability of new or existing fossil fuel capacity, as Deese and Hansmann warn? Perhaps, on some margin. But for the foreseeable future, the energy projects and infrastructure most burdened by regulatory requirements will be low-carbon ones. Batteries, solar, and wind projects make up more than 80% of the queue added in 2023. Meanwhile, oil and gas benefit from categorical exclusions under the National Environmental Policy Act, while low-carbon technologies are subject to stricter standards (although three permitting bills recently passed the House, including one that waives these requirements for new geothermal projects).
Consider that 40% of projects supported by the Inflation Reduction Act are caught up in delays. That is $84 billion of economic activity just waiting for the paperwork to be figured out, according to the Financial Times. Additionality requirements are additional boxes to check that almost necessarily imply additional delays. Permitting reform makes them redundant and unnecessary for a cleaner future.
This underscores perhaps the most essential conflict between strict additionality requirements and clean energy abundance. Ensuring that every new policy and every new source of demand allows for absolutely zero additional fossil fuel consumption or emissions will prove counterproductive to global decarbonization in the long run. Natural gas is still reducing emissions on the margin in the United States. Over the past decade, in years with higher natural gas prices, coal generation has ticked up, indicating that the so-called “natural gas bridge” has not yet reached its terminus. Even aggressive decarbonization scenarios now expect a substantial role for natural gas over the coming decades. And in the long term, natural gas plants may prove wholly compatible with abundant, low-carbon electricity systems if next-generation carbon capture technologies prove scalable.
The United States is the world’s energy technology R&D and demonstration laboratory. If policies to prune marginal fossil fuel consumption here stall domestic investment and scaling of low-carbon technologies — as current permitting regulations already do, and proposed additionality requirements would do — then we will not only slow U.S. decarbonization, but also inhibit our ability to export affordable and scalable low-carbon technologies abroad.
Environmental progress’s surest path is in speeding up. For that to happen, we need processes that allow for rapid deployment of clean energy solutions. Expediting technology licensing, fast-tracking federal infrastructure permitting, and finding opportunities for quicker and more rational interconnections should be first and foremost.
The real solution lies in building a regulatory environment where energy abundance can flourish. Clearing the path for clean energy development, we can achieve a future where energy is affordable, reliable, and abundant—a future where the United States leads in both decarbonization and economic growth. It’s time to stop adding barriers and start speeding up progress.
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Paradise, California, is snatching up high-risk properties to create a defensive perimeter and prevent the town from burning again.
The 2018 Camp Fire was the deadliest wildfire in California’s history, wiping out 90% of the structures in the mountain town of Paradise and killing at least 85 people in a matter of hours. Investigations afterward found that Paradise’s town planners had ignored warnings of the fire risk to its residents and forgone common-sense preparations that would have saved lives. In the years since, the Camp Fire has consequently become a cautionary tale for similar communities in high-risk wildfire areas — places like Chinese Camp, a small historic landmark in the Sierra Nevada foothills that dramatically burned to the ground last week as part of the nearly 14,000-acre TCU September Lightning Complex.
More recently, Paradise has also become a model for how a town can rebuild wisely after a wildfire. At least some of that is due to the work of Dan Efseaff, the director of the Paradise Recreation and Park District, who has launched a program to identify and acquire some of the highest-risk, hardest-to-access properties in the Camp Fire burn scar. Though he has a limited total operating budget of around $5.5 million and relies heavily on the charity of local property owners (he’s currently in the process of applying for a $15 million grant with a $5 million match for the program) Efseaff has nevertheless managed to build the beginning of a defensible buffer of managed parkland around Paradise that could potentially buy the town time in the case of a future wildfire.
In order to better understand how communities can build back smarter after — or, ideally, before — a catastrophic fire, I spoke with Efseaff about his work in Paradise and how other communities might be able to replicate it. Our conversation has been lightly edited and condensed for clarity.
Do you live in Paradise? Were you there during the Camp Fire?
I actually live in Chico. We’ve lived here since the mid-‘90s, but I have a long connection to Paradise; I’ve worked for the district since 2017. I’m also a sea kayak instructor and during the Camp Fire, I was in South Carolina for a training. I was away from the phone until I got back at the end of the day and saw it blowing up with everything.
I have triplet daughters who were attending Butte College at the time, and they needed to be evacuated. There was a lot of uncertainty that day. But it gave me some perspective, because I couldn’t get back for two days. It gave me a chance to think, “Okay, what’s our response going to be?” Looking two days out, it was like: That would have been payroll, let’s get people together, and then let’s figure out what we’re going to do two weeks and two months from now.
It also got my mind thinking about what we would have done going backwards. If you’d had two weeks to prepare, you would have gotten your go-bag together, you’d have come up with your evacuation route — that type of thing. But when you run the movie backwards on what you would have done differently if you had two years or two decades, it would include prepping the landscape, making some safer community defensible space. That’s what got me started.
Was it your idea to buy up the high-risk properties in the burn scar?
I would say I adapted it. Everyone wants to say it was their idea, but I’ll tell you where it came from: Pre-fire, the thinking was that it would make sense for the town to have a perimeter trail from a recreation standpoint. But I was also trying to pitch it as a good idea from a fuel standpoint, so that if there was a wildfire, you could respond to it. Certainly, the idea took on a whole other dimension after the Camp Fire.
I’m a restoration ecologist, so I’ve done a lot of river floodplain work. There are a lot of analogies there. The trend has been to give nature a little bit more room: You’re not going to stop a flood, but you can minimize damage to human infrastructure. Putting levees too close to the river makes them more prone to failing and puts people at risk — but if you can set the levee back a little bit, it gives the flood waters room to go through. That’s why I thought we need a little bit of a buffer in Paradise and some protection around the community. We need a transition between an area that is going to burn, and that we can let burn, but not in a way that is catastrophic.
How hard has it been to find willing sellers? Do most people in the area want to rebuild — or need to because of their mortgages?
Ironically, the biggest challenge for us is finding adequate funding. A lot of the property we have so far has been donated to us. It’s probably upwards of — oh, let’s see, at least half a dozen properties have been donated, probably close to 200 acres at this point.
We are applying for some federal grants right now, and we’ll see how that goes. What’s evolved quite a bit on this in recent years, though, is that — because we’ve done some modeling — instead of thinking of the buffer as areas that are managed uniformly around the community, we’re much more strategic. These fire events are wind-driven, and there are only a couple of directions where the wind blows sufficiently long enough and powerful enough for the other conditions to fall into play. That’s not to say other events couldn’t happen, but we’re going after the most likely events that would cause catastrophic fires, and that would be from the Diablo winds, or north winds, that come through our area. That was what happened in the Camp Fire scenario, and another one our models caught what sure looked a lot like the [2024] Park Fire.
One thing that I want to make clear is that some people think, “Oh, this is a fire break. It’s devoid of vegetation.” No, what we’re talking about is a well-managed habitat. These are shaded fuel breaks. You maintain the big trees, you get rid of the ladder fuels, and you get rid of the dead wood that’s on the ground. We have good examples with our partners, like the Butte Fire Safe Council, on how this works, and it looks like it helped protect the community of Cohasset during the Park Fire. They did some work on some strips there, and the fire essentially dropped to the ground before it came to Paradise Lake. You didn’t have an aerial tanker dropping retardant, you didn’t have a $2-million-per-day fire crew out there doing work. It was modest work done early and in the right place that actually changed the behavior of the fire.
Tell me a little more about the modeling you’ve been doing.
We looked at fire pathways with a group called XyloPlan out of the Bay Area. The concept is that you simulate a series of ignitions with certain wind conditions, terrain, and vegetation. The model looked very much like a Camp Fire scenario; it followed the same pathway, going towards the community in a little gulch that channeled high winds. You need to interrupt that pathway — and that doesn’t necessarily mean creating an area devoid of vegetation, but if you have these areas where the fire behavior changes and drops down to the ground, then it slows the travel. I found this hard to believe, but in the modeling results, in a scenario like the Camp Fire, it could buy you up to eight hours. With modern California firefighting, you could empty out the community in a systematic way in that time. You could have a vigorous fire response. You could have aircraft potentially ready. It’s a game-changing situation, rather than the 30 minutes Paradise had when the Camp Fire started.
How does this work when you’re dealing with private property owners, though? How do you convince them to move or donate their land?
We’re a Park and Recreation District so we don’t have regulatory authority. We are just trying to run with a good idea with the properties that we have so far — those from willing donors mostly, but there have been a couple of sales. If we’re unable to get federal funding or state support, though, I ultimately think this idea will still have to be here — whether it’s five, 10, 15, or 50 years from now. We have to manage this area in a comprehensive way.
Private property rights are very important, and we don’t want to impinge on that. And yet, what a person does on their property has a huge impact on the 30,000 people who may be downwind of them. It’s an unusual situation: In a hurricane, if you have a hurricane-rated roof and your neighbor doesn’t, and theirs blows off, you feel sorry for your neighbor but it’s probably not going to harm your property much. In a wildfire, what your neighbor has done with the wood, or how they treat vegetation, has a significant impact on your home and whether your family is going to survive. It’s a fundamentally different kind of event than some of the other disasters we look at.
Do you have any advice for community leaders who might want to consider creating buffer zones or something similar to what you’re doing in Paradise?
Start today. You have to think about these things with some urgency, but they’re not something people think about until it happens. Paradise, for many decades, did not have a single escaped wildfire make it into the community. Then, overnight, the community is essentially wiped out. But in so many places, these events are foreseeable; we’re just not wired to think about them or prepare for them.
Buffers around communities make a lot of sense, even from a road network standpoint. Even from a trash pickup standpoint. You don’t think about this, but if your community is really strung out, making it a little more thoughtfully laid out also makes it more economically viable to provide services to people. Some things we look for now are long roads that don’t have any connections — that were one-way in and no way out. I don’t think [the traffic jams and deaths in] Paradise would have happened with what we know now, but I kind of think [authorities] did know better beforehand. It just wasn’t economically viable at the time; they didn’t think it was a big deal, but they built the roads anyway. We can be doing a lot of things smarter.
A war of attrition is now turning in opponents’ favor.
A solar developer’s defeat in Massachusetts last week reveals just how much stronger project opponents are on the battlefield after the de facto repeal of the Inflation Reduction Act.
Last week, solar developer PureSky pulled five projects under development around the western Massachusetts town of Shutesbury. PureSky’s facilities had been in the works for years and would together represent what the developer has claimed would be one of the state’s largest solar projects thus far. In a statement, the company laid blame on “broader policy and regulatory headwinds,” including the state’s existing renewables incentives not keeping pace with rising costs and “federal policy updates,” which PureSky said were “making it harder to finance projects like those proposed near Shutesbury.”
But tucked in its press release was an admission from the company’s vice president of development Derek Moretz: this was also about the town, which had enacted a bylaw significantly restricting solar development that the company was until recently fighting vigorously in court.
“There are very few areas in the Commonwealth that are feasible to reach its clean energy goals,” Moretz stated. “We respect the Town’s conservation go als, but it is clear that systemic reforms are needed for Massachusetts to source its own energy.”
This stems from a story that probably sounds familiar: after proposing the projects, PureSky began reckoning with a burgeoning opposition campaign centered around nature conservation. Led by a fresh opposition group, Smart Solar Shutesbury, activists successfully pushed the town to drastically curtail development in 2023, pointing to the amount of forest acreage that would potentially be cleared in order to construct the projects. The town had previously not permitted facilities larger than 15 acres, but the fresh change went further, essentially banning battery storage and solar projects in most areas.
When this first happened, the state Attorney General’s office actually had PureSky’s back, challenging the legality of the bylaw that would block construction. And PureSky filed a lawsuit that was, until recently, ongoing with no signs of stopping. But last week, shortly after the Treasury Department unveiled its rules for implementing Trump’s new tax and spending law, which basically repealed the Inflation Reduction Act, PureSky settled with the town and dropped the lawsuit – and the projects went away along with the court fight.
What does this tell us? Well, things out in the country must be getting quite bleak for solar developers in areas with strident and locked-in opposition that could be costly to fight. Where before project developers might have been able to stomach the struggle, money talks – and the dollars are starting to tell executives to lay down their arms.
The picture gets worse on the macro level: On Monday, the Solar Energy Industries Association released a report declaring that federal policy changes brought about by phasing out federal tax incentives would put the U.S. at risk of losing upwards of 55 gigawatts of solar project development by 2030, representing a loss of more than 20 percent of the project pipeline.
But the trade group said most of that total – 44 gigawatts – was linked specifically to the Trump administration’s decision to halt federal permitting for renewable energy facilities, a decision that may impact generation out west but has little-to-know bearing on most large solar projects because those are almost always on private land.
Heatmap Pro can tell us how much is at stake here. To give you a sense of perspective, across the U.S., over 81 gigawatts worth of renewable energy projects are being contested right now, with non-Western states – the Northeast, South and Midwest – making up almost 60% of that potential capacity.
If historical trends hold, you’d expect a staggering 49% of those projects to be canceled. That would be on top of the totals SEIA suggests could be at risk from new Trump permitting policies.
I suspect the rate of cancellations in the face of project opposition will increase. And if this policy landscape is helping activists kill projects in blue states in desperate need of power, like Massachusetts, then the future may be more difficult to swallow than we can imagine at the moment.
And more on the week’s most important conflicts around renewables.
1. Wells County, Indiana – One of the nation’s most at-risk solar projects may now be prompting a full on moratorium.
2. Clark County, Ohio – Another Ohio county has significantly restricted renewable energy development, this time with big political implications.
3. Daviess County, Kentucky – NextEra’s having some problems getting past this county’s setbacks.
4. Columbia County, Georgia – Sometimes the wealthy will just say no to a solar farm.
5. Ottawa County, Michigan – A proposed battery storage facility in the Mitten State looks like it is about to test the state’s new permitting primacy law.