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Here are three big changes the White House is proposing.
The White House proposed a major overhaul to the country’s guidelines for analyzing regulations and government spending on Thursday. The changes to an incredibly dense, wonky set of documents known as “Circular A-4” and “Circular A-94” would affect how government agencies, like the Environmental Protection Agency, measure the costs and benefits of decisions that have big implications for climate change, like power plant regulations, clean car rules, and highway expansion projects.
It’s hard to overstate the magnitude of the makeover. More than anything, the changes represent a shift in philosophy. The proposed guidelines would change the way the government views and takes into account inequity, not just within the United States but also how U.S. actions affect people in other nations and future generations.
The current documents were also sorely outdated. The government hasn’t updated its instructions for regulatory analysis in 20 years, and the guidance for public investment is more than 30 years old. In the years since, academic thinking on how to conduct cost-benefit analysis has changed, financial markets have changed, and the philosophy of the White House has changed, said Noah Kaufman, a senior research scholar at Columbia University who previously served as a senior economist at the Biden administration’s Council of Economic Advisors.
“There's a lot of disagreement about a lot of what's in here, but pretty much everyone kind of agreed that they needed to be redone,” he said.
The proposal will go through a public comment period before being finalized by the federal Office of Information and Regulatory Affairs.
Cost-benefit analysis is but one consideration in government decision making, and often not the most important one, so Kaufman cautions against reading too much into the changes. Perhaps most significant to him is the overall vibe shift between the old guidance and what the White House released on Thursday. He said the old version reads like it’s written by people who are trying to convince you that there’s a very limited role for the government to play. “The people who worked on this document are far more interested in a more proactive role for how government programs and regulations can help address market failures.”
Here are three big changes the White House is proposing.
The proposed guidance makes a big adjustment to an incredibly complicated, confusing, but consequential number called the discount rate. The discount rate determines how much government analysts weigh distant, future benefits of a policy versus its cost today. A higher discount rate downplays future gains, making it much harder to justify the expense of flood protection infrastructure or rules that limit carbon emissions from power plants.
While the old instructions called for a discount rate between 3% and 7%, the new proposal suggests a dramatically lower rate of 1.7%. This means that when regulators look at the cost to society of putting more carbon in the atmosphere — and they take into account all of the potential future lost lives, reduced crop yields, and damages caused by rising seas — it would look a lot more expensive than it does under the current guidelines. To get a sense of how much more, the Obama administration used a discount rate of 3%, and estimated that the cost of every ton of carbon spewed into the atmosphere was about $51 per ton. The nonprofit research group Resources for the Future estimates that with a 2% discount rate, that number would jump to $185.
The new guidelines encourage agencies to take the global impact of decisions — such as potential lives lost to extreme weather outside the U.S. — into account when conducting a cost-benefit analysis. This is a big deal, according to Paul Kelleher, an associate professor at the University of Wisconsin-Madison who studies the ethics of public policy.
“This probably is an acknowledgement that when Americans emit carbon dioxide, it doesn’t only harm Americans,” Kelleher said. It also incentivizes American policymakers to approach international climate negotiations from a more cooperative standpoint, rather than only being interested in what happens within American borders, he said.
It’s an important, if admittedly wonky, way for the Biden administration to acknowledge the United States’ role in global climate change — suddenly, the lives of billions of people around the world are added to the accounting sheets of government agencies. That means a proposal to, for example, limit tailpipe emissions would appear to have larger financial benefits.
Today, the benefits of a proposed policy are weighed against how much the potential beneficiaries would be willing to pay for it. The problem is the government assumes a dollar means the same thing to everyone. But the value of a dollar to a grocery store clerk is a lot higher than the value of a dollar to, say, Elon Musk.
Under the current system, “climate damages in the poorest parts of the world will be registered as not as serious as climate damages that are much less serious in richer parts, where people’s willingness to pay can be quite high because their ability to pay is higher,” Kelleher said.
The new guidelines allows agencies to use an approach known as “equity-weighting,” or to account for the differential impacts of a given regulation or investment. “Now, instead of just counting up the dollars that people are willing to pay to avoid damages, you try to account for the real effect on wellbeing,” said Kelleher.
Take, for example, a new rule to reduce pollution from power plants, which low-income communities are disproportionately affected by. Under the new system, the financial benefits of such a regulation would appear much higher than they currently do, because more weight would be given to the health rewards and other gains the community would see from that regulation. And because the new guidelines allow analysts to look beyond U.S. borders, the practice of equity-weighting could also account for the disproportionate harms that a poorer country like Bangladesh would face from a warmer planet, significantly raising the cost of emissions.
If this approach is finalized, “it would be a titanic shift in the federal cost-benefit analysis framework,” Kelleher said.
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The rapid increase in demand for artificial intelligence is creating a seemingly vexing national dilemma: How can we meet the vast energy demands of a breakthrough industry without compromising our energy goals?
If that challenge sounds familiar, that’s because it is. The U.S. has a long history of rising to the electricity demands of innovative new industries. Our energy needs grew far more quickly in the four decades following World War II than what we are facing today. More recently, we have squared off against the energy requirements of new clean technologies that require significant energy to produce — most notably hydrogen.
Courtesy of Rhodium Group
The lesson we have learned time and again is that it is possible to scale technological innovation in a way that also scales energy innovation. Rather than accepting a zero-sum trade-off between innovation and our clean energy goals, we should focus on policies that leverage the growth of AI to scale the growth of clean energy.
At the core of this approach is the concept of additionality: Companies operating massive data centers — often referred to as “hyperscalers” — as well as utilities should have incentives to bring online new, additional clean energy to power new computing needs. That way, we leverage demand in one sector to scale up another. We drive innovation in key sectors that are critical to our nation’s competitiveness, we reward market leaders who are already moving in this direction with a stable, long-term regulatory framework for growth, and we stay on track to meet our nation’s climate commitments.
All of this is possible, but only if we take bold action now.
AI technologies have the potential to significantly boost America’s economic productivity and enhance our national security. AI also has the potential to accelerate the energy transition itself, from optimizing the electricity grid, to improving weather forecasting, to accelerating the discovery of chemicals and material breakthroughs that reduce reliance on fossil fuels. Powering AI, however, is itself incredibly energy intensive. Projections suggest that data centers could consume 9% of U.S. electricity generation by 2030, up from 4% today. Without a national policy response, this surge in energy demand risks increasing our long-term reliance on fossil fuels. By some estimates, around 20 gigawatts of additional natural gas generating capacity will come online by 2030, and coal plant retirements are already being delayed.
Avoiding this outcome will require creative focus on additionality. Hydrogen represents a particularly relevant case study here. It, too, is energy-intensive to produce — a single kilogram of hydrogen requires double the average household’s electricity consumption. And while hydrogen holds great promise to decarbonize parts of our economy, hydrogen is not per se good for our clean energy goals. Indeed, today’s fossil fuel-driven methods of hydrogen production generate more emissions than the entire aviation sector. While we can make zero-emissions hydrogen by using clean electricity to split hydrogen from water, the source of that electricity matters a lot. Similar to data centers, if the power for hydrogen production comes from the existing electricity grid, then ramping up electrolytic production of hydrogen could significantly increase emissions by growing overall energy demand without cleaning the energy mix.
This challenge led to the development of an “additionality” framework for hydrogen. The Inflation Reduction Act offers generous subsidies to hydrogen producers, but to qualify, they must match their electricity consumption with additional (read: newly built) clean energy generation close enough to them that they can actually use it.
This approach, which is being refined in proposed guidance from the U.S. Treasury Department, is designed to make sure that hydrogen’s energy demand becomes a catalyst for investment in new clean electricity generation and decarbonization technologies. Industry leaders are already responding, stating their readiness to build over 50 gigawatts of clean electrolyzer projects because of the long term certainty this framework provides.
While the scale and technology requirements are different, meeting AI’s energy needs presents a similar challenge. Powering data centers from the existing electricity grid mix means that more demand will create more emissions; even when data centers are drawing on clean electricity, if that energy is being diverted from existing sources rather than coming from new, additional clean electricity supply, the result is the same. Amazon’s recent $650 million investment in a data center campus next to an existing nuclear power plant in Pennsylvania illustrates the challenge: While diverting those clean electrons from Pennsylvania homes and businesses to the data center reduces Amazon’s reported emissions, by increasing demand on the grid without building additional clean capacity, it creates a need for new capacity in the region that will likely be met by fossil fuels (while also shifting up to $140 million of additional costs per year onto local customers).
Neither hyperscalers nor utilities should be expected to resolve this complex tension on their own. As with hydrogen, it is in our national interest to find a path forward.
What we need, then, is a national solution to make sure that as we expand our AI capabilities, we bring online new clean energy, as well, strengthening our competitive position in both industries and forestalling the economic and ecological consequences of higher electricity prices and higher carbon emissions.
In short, we should adopt a National AI Additionality Framework.
Under this framework, for any significant data center project, companies would need to show how they are securing new, additional clean power from a zero-emissions generation source. They could do this either by building new “behind-the-meter” clean energy to power their operations directly, or by partnering with a utility to pay a specified rate to secure new grid-connected clean energy coming online.
If companies are unwilling or unable to secure dedicated additional clean energy capacity, they would pay a fee into a clean deployment fund at the Department of Energy that would go toward high-value investments to expand clean electricity capacity. These could range from research and deployment incentives for so-called “clean firm electricity generation technologies like nuclear and geothermal, to investments in transmission capacity in highly congested areas, to expanding manufacturing capacity for supply-constrained electrical grid equipment like transformers, to cleaning up rural electric cooperatives that serve areas attractive to data centers. Given the variance in grid and transmission issues, the fund would explicitly approach its investment with a regional lens.
Several states operate similar systems: Under Massachusetts’ Renewable Portfolio Standard, utilities are required to provide a certain percentage of electricity they serve from clean energy facilities or pay an “alternative compliance payment” for every megawatt-hour they are short of their obligation. Dollars collected from these payments go toward the development and expansion of clean energy projects and infrastructure in the state. Facing increasing capacity constraints on the PJM grid, Pennsylvania legislators are now exploring a state Baseload Energy Development Fund to provide low-interest grants and loans for new electricity generation facilities.
A national additionality framework should not only challenge the industry to scale innovation in a way that scales clean technology, it must also clear pathways to build clean energy at scale. We should establish a dedicated fast-track approval process to move these clean energy projects through federal, state, and local permitting and siting on an accelerated basis. This will help companies already investing in additional clean energy to move faster and more effectively – and make it more difficult for anyone to hide behind the excuse that building new clean energy capacity is too hard or too slow. Likewise, under this framework, utilities that stand in the way of progress should be held accountable and incentivized to adopt innovative new technologies and business models that enable them to move at historic speed.
For hyperscalers committed to net-zero goals, this national approach provides both an opportunity and a level playing field — an opportunity to deliver on those commitments in a genuine way, and a reliable long-term framework that will reward their investments to make that happen. This approach would also build public trust in corporate climate accountability and diminish the risk that those building data centers in the U.S. stand accused of greenwashing or shifting the cost of development onto ratepayers and communities. The policy clarity of an additionality requirement can also encourage cutting edge artificial intelligence technology to be built here in the United States. Moreover, it is a model that can be extended to address other sectors facing growing energy demand.
The good news is that many industry players are already moving in this direction. A new agreement between Google and a Nevada utility, for example, would allow Google to pay a higher rate for 24/7 clean electricity from a new geothermal project. In the Carolinas, Duke Energy announced its intent to explore a new clean tariff to support carbon-free energy generation for large customers like Google and Microsoft.
A national framework that builds on this progress is critical, though it will not be easy; it will require quick Congressional action, executive leadership, and new models of state and local partnership. But we have a unique opportunity to build a strange bedfellow coalition to get it done – across big tech, climate tech, environmentalists, permitting reform advocates, and those invested in America’s national security and technology leadership. Together, this framework can turn a vexing trade-off into an opportunity. We can ensure that the hundreds of billions of dollars invested in building an industry of the future actually accelerates the energy transition, all while strengthening the U.S.’s position in innovating cutting- edge AI and clean energy technology.
Almost half of developers believe it is “somewhat or significantly harder to do” projects on farmland, despite the clear advantages that kind of property has for harnessing solar power.
The solar energy industry has a big farm problem cropping up. And if it isn’t careful, it’ll be dealing with it for years to come.
Researchers at SI2, an independent research arm of the Solar Energy Industries Association, released a study of farm workers and solar developers this morning that said almost half of all developers believe it is “somewhat or significantly harder to do” projects on farmland, despite the clear advantages that kind of property has for harnessing solar power.
Unveiled in conjunction with RE+, the largest renewable energy conference in the U.S., the federally-funded research includes a warning sign that permitting is far and away the single largest impediment for solar developers trying to build projects on farmland. If this trend continues or metastasizes into a national movement, it could indefinitely lock developers out from some of the nation’s best land for generating carbon-free electricity.
“If a significant minority opposes and perhaps leads to additional moratoria, [developers] will lose a foot in the door for any future projects,” Shawn Rumery, SI2’s senior program director and the survey lead, told me. “They may not have access to that community any more because that moratoria is in place.”
SI2’s research comes on the heels of similar findings from Heatmap Pro. A poll conducted for the platform last month found 70% of respondents who had more than 50 acres of property — i.e. the kinds of large landowners sought after by energy developers — are concerned that renewable energy “takes up farmland,” by far the greatest objection among that cohort.
Good farmland is theoretically perfect for building solar farms. What could be better for powering homes than the same strong sunlight that helps grow fields of yummy corn, beans and vegetables? And there’s a clear financial incentive for farmers to get in on the solar industry, not just because of the potential cash in letting developers use their acres but also the longer-term risks climate change and extreme weather can pose to agriculture writ large.
But not all farmers are warming up to solar power, leading towns and counties across the country to enact moratoria restricting or banning solar and wind development on and near “prime farmland.” Meanwhile at the federal level, Republicans and Democrats alike are voicing concern about taking farmland for crop production to generate renewable energy.
Seeking to best understand this phenomena, SI2 put out a call out for ag industry representatives and solar developers to tell them how they feel about these two industries co-mingling. They received 355 responses of varying detail over roughly three months earlier this year, including 163 responses from agriculture workers, 170 from solar developers as well as almost two dozen individuals in the utility sector.
A key hurdle to development, per the survey, is local opposition in farm communities. SI2’s publicity announcement for the research focuses on a hopeful statistic: up to 70% of farmers surveyed said they were “open to large-scale solar.” But for many, that was only under certain conditions that allow for dual usage of the land or agrivoltaics. In other words, they’d want to be able to keep raising livestock, a practice known as solar grazing, or planting crops unimpeded by the solar panels.
The remaining percentage of farmers surveyed “consistently opposed large-scale solar under any condition,” the survey found.
“Some of the messages we got were over my dead body,” Rumery said.
Meanwhile a “non-trivial” number of solar developers reported being unwilling or disinterested in adopting the solar-ag overlap that farmers want due to the increased cost, Rumery said. While some companies expect large portions of their business to be on farmland in the future, and many who responded to the survey expect to use agrivoltaic designs, Rumery voiced concern at the percentage of companies unwilling to integrate simultaneous agrarian activities into their planning.
In fact, Rumery said some developers’ reticence is part of what drove him and his colleagues to release the survey while at RE+.
As we discussed last week, failing to address the concerns of local communities can lead to unintended consequences with industry-wide ramifications. Rumery said developers trying to build on farmland should consider adopting dual-use strategies and focus on community engagement and education to avoid triggering future moratoria.
“One of the open-ended responses that best encapsulated the problem was a developer who said until the cost of permitting is so high that it forces us to do this, we’re going to continue to develop projects as they are,” he said. “That’s a cold way to look at it.”
Meanwhile, who is driving opposition to solar and other projects on farmland? Are many small farm owners in rural communities really against renewables? Is the fossil fuel lobby colluding with Big Ag? Could building these projects on fertile soil really impede future prospects at crop yields?
These are big questions we’ll be tackling in far more depth in next week’s edition of The Fight. Trust me, the answers will surprise you.
Here are the most notable renewable energy conflicts over the past week.
1. Worcester County, Maryland –Ocean City is preparing to go to court “if necessary” to undo the Bureau of Ocean Energy Management’s approval last week of U.S. Wind’s Maryland Offshore Wind Project, town mayor Rick Meehan told me in a statement this week.
2. Magic Valley, Idaho – The Lava Ridge Wind Project would be Idaho’s biggest wind farm. But it’s facing public outcry over the impacts it could have on a historic site for remembering the impact of World War II on Japanese residents in the United States.
3. Kossuth County, Iowa – Iowa’s largest county – Kossuth – is in the process of approving a nine-month moratorium on large-scale solar development.
Here’s a few more hotspots I’m watching…