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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 attractingsubstantial interest. And technological innovation is leading to whole new sources of electric load — compute-hungry artificial intelligence beingthe 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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A conversation with VDE Americas CEO Brian Grenko.
This week’s Q&A is about hail. Last week, we explained how and why hail storm damage in Texas may have helped galvanize opposition to renewable energy there. So I decided to reach out to Brian Grenko, CEO of renewables engineering advisory firm VDE Americas, to talk about how developers can make sure their projects are not only resistant to hail but also prevent that sort of pushback.
The following conversation has been lightly edited for clarity.
Hiya Brian. So why’d you get into the hail issue?
Obviously solar panels are made with glass that can allow the sunlight to come through. People have to remember that when you install a project, you’re financing it for 35 to 40 years. While the odds of you getting significant hail in California or Arizona are low, it happens a lot throughout the country. And if you think about some of these large projects, they may be in the middle of nowhere, but they are taking hundreds if not thousands of acres of land in some cases. So the chances of them encountering large hail over that lifespan is pretty significant.
We partnered with one of the country’s foremost experts on hail and developed a really interesting technology that can digest radar data and tell folks if they’re developing a project what the [likelihood] will be if there’s significant hail.
Solar panels can withstand one-inch hail – a golfball size – but once you get over two inches, that’s when hail starts breaking solar panels. So it’s important to understand, first and foremost, if you’re developing a project, you need to know the frequency of those events. Once you know that, you need to start thinking about how to design a system to mitigate that risk.
The government agencies that look over land use, how do they handle this particular issue? Are there regulations in place to deal with hail risk?
The regulatory aspects still to consider are about land use. There are authorities with jurisdiction at the federal, state, and local level. Usually, it starts with the local level and with a use permit – a conditional use permit. The developer goes in front of the township or the city or the county, whoever has jurisdiction of wherever the property is going to go. That’s where it gets political.
To answer your question about hail, I don’t know if any of the [authority having jurisdictions] really care about hail. There are folks out there that don’t like solar because it’s an eyesore. I respect that – I don’t agree with that, per se, but I understand and appreciate it. There’s folks with an agenda that just don’t want solar.
So okay, how can developers approach hail risk in a way that makes communities more comfortable?
The bad news is that solar panels use a lot of glass. They take up a lot of land. If you have hail dropping from the sky, that’s a risk.
The good news is that you can design a system to be resilient to that. Even in places like Texas, where you get large hail, preparing can mean the difference between a project that is destroyed and a project that isn’t. We did a case study about a project in the East Texas area called Fighting Jays that had catastrophic damage. We’re very familiar with the area, we work with a lot of clients, and we found three other projects within a five-mile radius that all had minimal damage. That simple decision [to be ready for when storms hit] can make the complete difference.
And more of the week’s big fights around renewable energy.
1. Long Island, New York – We saw the face of the resistance to the war on renewable energy in the Big Apple this week, as protestors rallied in support of offshore wind for a change.
2. Elsewhere on Long Island – The city of Glen Cove is on the verge of being the next New York City-area community with a battery storage ban, discussing this week whether to ban BESS for at least one year amid fire fears.
3. Garrett County, Maryland – Fight readers tell me they’d like to hear a piece of good news for once, so here’s this: A 300-megawatt solar project proposed by REV Solar in rural Maryland appears to be moving forward without a hitch.
4. Stark County, Ohio – The Ohio Public Siting Board rejected Samsung C&T’s Stark Solar project, citing “consistent opposition to the project from each of the local government entities and their impacted constituents.”
5. Ingham County, Michigan – GOP lawmakers in the Michigan State Capitol are advancing legislation to undo the state’s permitting primacy law, which allows developers to evade municipalities that deny projects on unreasonable grounds. It’s unlikely the legislation will become law.
6. Churchill County, Nevada – Commissioners have upheld the special use permit for the Redwood Materials battery storage project we told you about last week.
Long Islanders, meanwhile, are showing up in support of offshore wind, and more in this week’s edition of The Fight.
Local renewables restrictions are on the rise in the Hawkeye State – and it might have something to do with carbon pipelines.
Iowa’s known as a renewables growth area, producing more wind energy than any other state and offering ample acreage for utility-scale solar development. This has happened despite the fact that Iowa, like Ohio, is home to many large agricultural facilities – a trait that has often fomented conflict over specific projects. Iowa has defied this logic in part because the state was very early to renewables, enacting a state portfolio standard in 1983, signed into law by a Republican governor.
But something else is now on the rise: Counties are passing anti-renewables moratoria and ordinances restricting solar and wind energy development. We analyzed Heatmap Pro data on local laws and found a rise in local restrictions starting in 2021, leading to nearly 20 of the state’s 99 counties – about one fifth – having some form of restrictive ordinance on solar, wind or battery storage.
What is sparking this hostility? Some of it might be counties following the partisan trend, as renewable energy has struggled in hyper-conservative spots in the U.S. But it may also have to do with an outsized focus on land use rights and energy development that emerged from the conflict over carbon pipelines, which has intensified opposition to any usage of eminent domain for energy development.
The central node of this tension is the Summit Carbon Solutions CO2 pipeline. As we explained in a previous edition of The Fight, the carbon transportation network would cross five states, and has galvanized rural opposition against it. Last November, I predicted the Summit pipeline would have an easier time under Trump because of his circle’s support for oil and gas, as well as the placement of former North Dakota Governor Doug Burgum as interior secretary, as Burgum was a major Summit supporter.
Admittedly, this prediction has turned out to be incorrect – but it had nothing to do with Trump. Instead, Summit is now stalled because grassroots opposition to the pipeline quickly mobilized to pressure regulators in states the pipeline is proposed to traverse. They’re aiming to deny the company permits and lobbying state legislatures to pass bills banning the use of eminent domain for carbon pipelines. One of those states is South Dakota, where the governor last month signed an eminent domain ban for CO2 pipelines. On Thursday, South Dakota regulators denied key permits for the pipeline for the third time in a row.
Another place where the Summit opposition is working furiously: Iowa, where opposition to the CO2 pipeline network is so intense that it became an issue in the 2020 presidential primary. Regulators in the state have been more willing to greenlight permits for the project, but grassroots activists have pressured many counties into some form of opposition.
The same counties with CO2 pipeline moratoria have enacted bans or land use restrictions on developing various forms of renewables, too. Like Kossuth County, which passed a resolution decrying the use of eminent domain to construct the Summit pipeline – and then three months later enacted a moratorium on utility-scale solar.
I asked Jessica Manzour, a conservation program associate with Sierra Club fighting the Summit pipeline, about this phenomenon earlier this week. She told me that some counties are opposing CO2 pipelines and then suddenly tacking on or pivoting to renewables next. In other cases, counties with a burgeoning opposition to renewables take up the pipeline cause, too. In either case, this general frustration with energy companies developing large plots of land is kicking up dust in places that previously may have had a much lower opposition risk.
“We painted a roadmap with this Summit fight,” said Jess Manzour, a campaigner with Sierra Club involved in organizing opposition to the pipeline at the grassroots level, who said zealous anti-renewables activists and officials are in some cases lumping these items together under a broad umbrella. ”I don’t know if it’s the people pushing for these ordinances, rather than people taking advantage of the situation.”