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We read the Heritage Foundation’s Project 2025 playbook so you don’t have to.
When former President Donald Trump exited the Oval Office in January 2021, he left behind a record of environmental rollbacks unrivaled in modern U.S. history. Over his 1,461 days as commander-in-chief, Trump replaced, eliminated, or otherwise dismantled more than 100 environmental rules — at least — from repealing the Clean Air Act to allowing coal plants to dump toxic wastewater into lakes and rivers to declaring open season on endangered gray wolves.
President Joe Biden then rolled back most of the rollbacks, largely before their full impacts could be felt, which is why some experts say the most significant climate consequence of Trump’s presidency was actually the loss of four years that could have moved the green transition forward.
Had all Trump’s policies gone into effect, the nonpartisan Rhodium Group estimated at the end of 2020, they would have added an additional 1.8 gigatons of CO2-equivalent to the atmosphere by 2035 — more than the annual energy emissions of Germany, Britain, and Canada combined. But even though we never felt the full brunt of them, the medical journal The Lancet estimated that the policies undertaken during his presidency were responsible for 22,000 deaths in 2019 alone due to sharp increases in things like asthma, heart disease, and lung cancer.
Now Trump is once again the presumed Republican nominee and currently leads Biden in general election polls. Were he to win, he has a ready roadmap for building on his dubious environmental legacy: Project 2025, a 920-page document developed by the right wing think tank The Heritage Foundation.
Project 2025 isn’t just a climate plan, or course — it’s a comprehensive proposal, covering everything from immigration to abortion, education, pornography, and child labor. Though billed as a “presidential transition project,” its wishlist includes numerous actions that would require Republican control of both chambers of Congress (admittedly possible, though currently looking like a longshot) to enact. Undaunted, the document sets its sights on the Inflation Reduction Act, Biden’s landmark climate legislation, which — since the U.S. is the world’s second-largest greenhouse gas emitter — is all but necessary to keep the planet off the path to 1.5 degrees Celcius.
Here is how, precisely, Project 2025 aims to gut the IRA, shrink environmental protections, and slow forward momentum on climate change.
“‘Cheap grace’ aptly describes the Left’s love affair with environmental extremism. Those who suffer most from the policies environmentalism would have us enact are the aged, poor, and vulnerable. It is not a political cause, but a pseudo-religion meant to baptize liberals’ ruthless pursuit of absolute power in the holy water of environmental virtue … They would stand human affairs on their head, regarding human activity itself as fundamentally a threat to be sacrificed to the god of nature.”
Republicans have cannily turned “climate” into another culture war buzzword. As with Critical Race Theory before it, this rhetoric strategy divorces the climate movement from what it actually is — a disparate and diverse constellation of ideas for how to move forward in the face of the reality of human-driven global warming — and flattens it into a boogeyman that voters can easily dismiss. Rather than allow for honest debate over the upsides and drawbacks of LNG or of preserving ecosystems versus quickly building out renewables, the effect is to shut down any and all conversation before it can even start.
Project 2025 both outlines and embodies this strategy. In the foreword, Heritage Foundation president Kevin D. Roberts bafflingly characterizes climate as a “pseudo-religion”; elsewhere in the document, “climate extremism” is often lumped alongside “abortion, gender radicalism … and other woke ideas.”
For good measure, the Project 2025 playbook also uses religious metaphors to code any concern about the environment as being morally wrong or even evil. Republicans have already picked up on this cue: “We should not be bending the knee to this new religion … We are flogging ourselves and losing our modern way of life bowing to this new god of climate,” Florida Governor Ron DeSantis argued during a Republican presidential debate last year.
“The National Labs have been too focused on climate change and renewable technologies. American science dominance is critical to U.S. national security and economic strength.”
As part of the Inflation Reduction Act, the Biden administration channeled $1.5 billion to the Department of Energy’s national laboratories for “innovative research in clean technologies” and “advancing U.S. energy security.” This has been essential for “de-risking” the otherwise prohibitively expensive technological advancements necessary for reaching net zero.
Project 2025, naturally, wants none of that: “The three National Labs run by DOE’s [National Nuclear Security Administration] should continue to focus on national security issues,” Bernard McNamee, the former commissioner of the Federal Energy Regulatory Commission under Trump, writes in the document’s chapter on revamping the department. Additionally, the “ill-advised attempt to expand the National Science Foundation’s mission from supporting university research to supporting an all-encompassing technology transition” (a mischaracterization) should be reconsidered, and “there should be a review to measure, prioritize, and consolidate DOE programs based on a range of beneficial factors, including degree of relationship to national security.” (While addressing the nation’s climate goals is an NSF priority, it is not done at the expense of supporting university research. Also, the current director of the NSF is a Trump appointee).
The Trump administration was memorably hostile toward science, and there are no signs he’ll change his heart during a second term; he’s already vowed to revive “Schedule F,” which reclassifies many government researchers and scientists as at-will employees, making them easier to “clean out” if they “frustrate his policies.”
Still, it does appear that the Heritage Foundation sees some usefulness for scientists: “The next administration should fund the design, development, and deployment of new nuclear warheads, including the production of plutonium pits in quantity,” Project 2025 says.
“The next conservative Administration should rescind all climate policies from its foreign aid programs (specifically USAID’s Climate Strategy 2022–2030 ); shut down the agency’s offices, programs, and directives designed to advance the Paris Climate Agreement; and narrowly limit funding to traditional climate mitigation efforts.”
The United States is the single greatest historical contributor to climate change, but Project 2025 has little sympathy for nations that might be suffering as a result. “The [Biden] administration has incorporated its radical climate policy into every USAID initiative,” Max Primorac, a Heritage Foundation research fellow, complains in the document. “It has joined or funded international partnerships dedicated to advancing the aims of the Paris Climate Agreement and has supported the idea of giving trillions of dollars more in aid transfers for ‘climate reparations.’”
Notably, Biden has not promised climate reparations — despite Trump and other Republicans’ frequent claims to the contrary. And while climate change is “a top driver of humanitarian need and human suffering, particularly for the poorest countries,” according to the United Nations, the former president slashed $200 million from environmental initiatives in his 2019 budget, including investments to help nations move away from heavy carbon-emitting industries.
“Taxpayer dollars should not be used to subsidize preferred businesses and energy resources, thereby distorting the market and undermining energy reliability.”
Among the programs and offices Project 2025 wants to eliminate (or at least substantially reduce) funding for are: the Climate Hub Office; the Clean Energy Corps, the Office of Domestic Climate Policy; the Office of Energy Efficiency and Renewable Energy; the Grid Deployment Office; the Interagency Working Group on the Social Cost of Carbon; the Conservation Reserve Program; the Office of Clean Energy Demonstrations; the Office of Environmental Justice and External Civil Rights; “the activities of EPA advisory bodies”; the Office of State and Community Energy Programs; ARPA-E; the DOE Loan Program Office; the Office of Fossil Energy and Carbon Management; “grant programs for things like energy storage and the testing of grid-enhancing technologies”; “carbon capture utilization and storage programs”; the Greenhouse Gas Reporting Program; the Bureau of Energy Resources; the Office of Emergency Management; the National Flood Insurance Program; and the National Oceanic and Atmospheric Administration (more on that below).
“Support repeal of massive spending bills like the Infrastructure Investment and Jobs Act and Inflation Reduction Act, which established new programs and are providing hundreds of billions of dollars in subsidies to renewable energy developers, their investors, and special interests, and support the rescinding of all funds not already spent by these programs.”
Project 2025 opposes green subsidies across the board. It’s especially twitchy about programs aimed at helping “the private sector deploy and market clean energy and decarbonizing resources” — because, supposedly, the “government should not be picking winners and losers.”
Still, while it’s uncertain how much damage a Republican president could do to the Inflation Reduction Act without the help of a conservative-controlled Congress, Project 2025 makes clear there are lots of places conservatives can chip away, including going after “subsidies of electric vehicles,” “subsidies for transit expansion,” and subsidies renewables like wind and solar. Additionally, the Office of Energy Efficiency and Renewable Energy “is a conduit for taxpayer dollars to fund progressive policies, including decarbonizing the economy and renewable resources.” That won’t do: “Eliminate EERE,” it says, or otherwise defund it.
“While individual investors may prefer to invest in ‘green’ companies, ‘woke’ companies, or companies with greater board diversity, and may even be willing to sacrifice some financial gains to do so, the question relevant to [the Department of Labor] is whether, and under what conditions, fiduciaries should be permitted to follow this path as well.”
If we’re being honest, though, isn’t the whole “ESG is evil” thing kind of last year?
“The new Administration’s review will permit a fresh look at past monument decrees and new ones by President Biden. Furthermore, the new Administration must vigorously defend the downward adjustments it makes to permit a ruling on a President’s authority to reduce the size of national monuments by the U.S. Supreme Court.”
President Trump was responsible for the most significant reduction in protected land in U.S. history. When he took office, Biden reinstated the protections — mainly in Utah’s Bears Ears and Grand Staircase-Escalante. Project 2025 prioritizes rolling back the rollback of the rollback, but making it stick by taking the case to the conservative-controlled Supreme Court.
The former acting Bureau of Land Management director under Trump, William Perry Pendley, writes in the section on reforming the Department of the Interior that Biden is “abusing National Environmental Policy Act processes, the Antiquities Act, and bureaucratic procedures to advance a radical climate agenda,” and directs an incoming Republican president to “seek repeal of the Antiquities Act.” Republicans and Democrats alike have used the Antiquities Act over the decades to protect scenic and culturally significant places, including the Grand Canyon, Zion, and Olympic National Parks. Any Supreme Court ruling could effectively curb the ability of future presidents to protect scenic and culturally important parts of the country.
“NOAA consists of six main offices ... Together, these form a colossal operation that has become one of the main drivers of the climate change alarm industry and, as such, is harmful to future U.S. prosperity.”
Thomas F. Gilman, writing on reforms for the Department of Commerce, gets right to the point: “Break up NOAA.” The agency’s “emphasis on prediction and management seems designed around the fatal conceit of planning for the unplannable,” he claims, adding, that “its current organization corrupts its useful functions.”
In practice, that would mean the National Weather Service should “fully commercialize its forecasting operations,” since “Americans rely on weather forecasts and warnings provided by … private companies such as AccuWeather,” Gilman writes. It’s a notable shoutout: Barry Lee Myers, the former CEO of AccuWeather, was briefly a Trump nominee to, uh, run NOAA.
Gilman has ideas for the Office of Oceanic and Atmospheric Research, too, writing that it “provides theoretical science” and is “the source of much of NOAA’s climate alarmism,” and should therefore be “disbanded.” Data from the National Hurricane Center is further ordered to be “presented neutrally, without adjustments intended to support any one side in the climate debate.”
Echoing the Trump administration’s hostility toward the sciences, he goes on to allege that “scientific agencies like NOAA are vulnerable to obstructionism … if political appointees are not wholly in sync with administration policy” — never mind that disagreement is one of the most essential parts of scientific research and progress.
But don’t worry: Project 2025 also calls for an elevation of … “the Office of Space Commerce.” Phew.
Republicans are going to make dishwasher cycle times a culture war or die trying.
Project 2025 dictates that “Congress should reform the Natural Gas Act” to “eliminate political and climate-change interference in DOE approvals of liquefied natural gas exports.” Currently, the DOE must decide if it is in the “public interest” to allow LNG exports to non-free trade agreement countries — the only part of the permitting process that could even potentially consider the export terminal’s impacts on frontline communities or their effect on climate change more largely
How? By narrowing the Natural Gas Act to only consider “whether there is a need for the natural gas” and the “impacts of the actual pipeline itself, not indirect upstream and downstream effects.”
The next Republican president should “immediately” reopen the Arctic to drilling, expand the controversial Willow drilling project, max out offshore oil and natural gas lease sales, and restart coal leasing in Wyoming and Montana, the authors write.
Mandy Gunasekara, Trump’s former Environmental Protection Agency chief of staff, details almost gleefully how the agency’s regulatory powers will be dismantled, from preventing downwind states from “over-controlling” their upwind neighbors to loosening car emission standards and beyond.
Since 1968, California has been allowed to set stricter vehicle emission limits than the federal government thanks to a Clean Air Act waiver; other states are welcome but not required to opt in. As president, Trump revoked California’s right to include greenhouse gases in its emissions considerations and barred other states from adopting its criteria. That seems like it’s back on the table — and could be headed to a consequential decision in the Supreme Court.
Project 2025 proposes a fleet-wide average of 35 miles per gallon, far below current benchmarks of 49 miles per gallon by 2026 and 58 miles per gallon by 2032.
There is no question that the management of wild horses and burros is a big problem for the Western United States. But Project 2025 waves off strategies like “expanded adoptions” and “more effective use of fertility controls” as “not enough,” writing that “Congress must enact laws permitting the BLM to dispose humanely of these animals.”
Project 2025 aims not only to gut the Endangered Species Act, but also to “direct the Fish and Wildlife Service to end its abuse of Section 10( j) of the ESA,” which is being used to reintroduce grizzly bears in Washington state and wolves in Colorado.
Project 2025 says that “the Department of Energy should end the Biden Administration’s unprovoked war on fossil fuels, restore America’s energy independence, oppose eyesore windmills built at taxpayer expense, and respect the right of Americans to buy and drive cars of their own choosing, rather than trying to force them into electric vehicles and eventually out of the driver’s seat altogether in favor of self-driving robots.” But as far as roadmaps go, that doesn’t look much like a way forward — it looks like holding back the inevitable. If that’s the case, then self-driving robots start to look good.
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On a late-night House vote, Tesla’s slump, and carbon credits
Current conditions: Tropical storm Chantal has a 40% chance of developing this weekend and may threaten Florida, Georgia, and the Carolinas • French far-right leader Marine Le Pen is campaigning on a “grand plan for air conditioning” amid the ongoing record-breaking heatwave in Europe • Great fireworks-watching weather is in store tomorrow for much of the East and West Coasts.
The House moved closer to a final vote on President Trump’s “big, beautiful bill” after passing a key procedural vote around 3 a.m. ET on Thursday morning. “We have the votes,” House Speaker Mike Johnson told reporters after the rule vote, adding, “We’re still going to meet” Trump’s self-imposed July 4 deadline to pass the megabill. A floor vote on the legislation is expected as soon as Thursday morning.
GOP leadership had worked through the evening to convince holdouts, with my colleagues Katie Brigham and Jael Holzman reporting last night that House Freedom Caucus member Ralph Norman of North Carolina said he planned to advance the legislation after receiving assurances that Trump would “deal” with the Inflation Reduction Act’s clean energy tax credits, particularly for wind and solar energy projects, which the Senate version phases out more slowly than House Republicans wanted. “It’s not entirely clear what the president could do to unilaterally ‘deal with’ tax credits already codified into law,” Brigham and Holzman write, although another Republican holdout, Representative Chip Roy of Texas, made similar allusions to reporters on Wednesday.
Tesla delivered just 384,122 cars in the second quarter of 2025, a 13.5% slump from the 444,000 delivered in the same quarter of 2024, marking the worst quarterly decline in the company’s history, Barron’s reports. The slump follows a similarly disappointing Q1, down 13% year-over-year, after the company’s sales had “flatlined for the first time in over a decade” in 2024, InsideEVs adds.
Despite the drop, Tesla stock rose 5% on Wednesday, with Wedbush analyst Dan Ives calling the Q2 results better than some had expected. “Fireworks came early for Tesla,” he wrote, although Barron’s notes that “estimates for the second quarter of 2025 started at about 500,000 vehicles. They started to drop precipitously after first-quarter deliveries fell 13% year over year, missing Wall Street estimates by some 40,000 vehicles.”
The European Commission proposed its 2040 climate target on Wednesday, which, for the first time, would allow some countries to use carbon credits to meet their emissions goals. EU Commissioner for Climate, Net Zero, and Clean Growth Wopke Hoekstra defended the decision during an appearance on Euronews on Wednesday, saying the plan — which allows developing nations to meet a limited portion of their emissions goals with the credits — was a chance to “build bridges” with countries in Africa and Latin America. “The planet doesn’t care about where we take emissions out of the air,” he separately told The Guardian. “You need to take action everywhere.” Green groups, which are critical of the use of carbon credits, slammed the proposal, which “if agreed [to] by member states and passed by the EU parliament … is then supposed to be translated into an international target,” The Guardian writes.
Around half of oil executives say they expect to drill fewer wells in 2025 than they’d planned for at the start of the year, according to a Federal Reserve Bank of Dallas survey. Of the respondents at firms producing more than 10,000 barrels a day, 42% said they expected a “significant decrease in the number of wells drilled,” Bloomberg adds. The survey further indicates that Republican policy has been at odds with President Trump’s “drill, baby, drill” rhetoric, as tariffs have increased the cost of completing a new well by more than 4%. “It’s hard to imagine how much worse policies and D.C. rhetoric could have been for U.S. E&P companies,” one anonymous executive said in the report. “We were promised by the administration a better environment for producers, but were delivered a world that has benefited OPEC to the detriment of our domestic industry.”
Fine-particulate air pollution is strongly associated with lung cancer-causing DNA mutations that are more traditionally linked to smoking tobacco, a new study by researchers at the University of California, San Diego, and the National Cancer Institute has found. The researchers looked at the genetic code of 871 non-smokers’ lung tumors in 28 regions across Europe, Africa, and Asia and found that higher levels of local air pollution correlated with more cancer-driving mutations in the respective tumors.
Surprisingly, the researchers did not find a similar genetic correlation among non-smokers exposed to secondhand smoke. George Thurston, a professor of medicine and population health at New York University, told Inside Climate News that a potential reason for this result is that fine-particulate air pollution — which is emitted by cars, industrial activities, and wildfires — is more widespread than exposure to secondhand smoke. “We are engulfed in fossil-fuel-burning pollution every single day of our lives, all day long, night and day,” he said, adding, “I feel like I’m in the Matrix, and I’m the only one that took the red pill. I know what’s going on, and everybody else is walking around thinking, ‘This stuff isn’t bad for your health.’” Today, non-smokers account for up to 25% of lung cancer cases globally, with the worst air quality pollution in the United States primarily concentrated in the Southwest.
EPA
National TV news networks aired a combined 4 hours and 20 minutes of coverage about the record-breaking late-June temperatures in the Midwest and East Coast — but only 4% of those segments mentioned the heat dome’s connection to climate change, a new report by Media Matters found.
“We had enough assurance that the president was going to deal with them.”
A member of the House Freedom Caucus said Wednesday that he voted to advance President Trump’s “big, beautiful bill” after receiving assurances that Trump would “deal” with the Inflation Reduction Act’s clean energy tax credits – raising the specter that Trump could try to go further than the megabill to stop usage of the credits.
Representative Ralph Norman, a Republican of North Carolina, said that while IRA tax credits were once a sticking point for him, after meeting with Trump “we had enough assurance that the president was going to deal with them in his own way,” he told Eric Garcia, the Washington bureau chief of The Independent. Norman specifically cited tax credits for wind and solar energy projects, which the Senate version would phase out more slowly than House Republicans had wanted.
It’s not entirely clear what the president could do to unilaterally “deal with” tax credits already codified into law. Norman declined to answer direct questions from reporters about whether GOP holdouts like himself were seeking an executive order on the matter. But another Republican holdout on the bill, Representative Chip Roy of Texas, told reporters Wednesday that his vote was also conditional on blocking IRA “subsidies.”
“If the subsidies will flow, we’re not gonna be able to get there. If the subsidies are not gonna flow, then there might be a path," he said, according to Jake Sherman of Punchbowl News.
As of publication, Roy has still not voted on the rule that would allow the bill to proceed to the floor — one of only eight Republicans yet to formally weigh in. House Speaker Mike Johnson says he’ll, “keep the vote open for as long as it takes,” as President Trump aims to sign the giant tax package by the July 4th holiday. Norman voted to let the bill proceed to debate, and will reportedly now vote yes on it too.
Earlier Wednesday, Norman said he was “getting a handle on” whether his various misgivings could be handled by Trump via executive orders or through promises of future legislation. According to CNN, the congressman later said, “We got clarification on what’s going to be enforced. We got clarification on how the IRAs were going to be dealt with. We got clarification on the tax cuts — and still we’ll be meeting tomorrow on the specifics of it.”
Neither Norman nor Roy’s press offices responded to a request for comment.
The foreign entities of concern rules in the One Big Beautiful Bill would place gigantic new burdens on developers.
Trump campaigned on cutting red tape for energy development. At the start of his second term, he signed an executive order titled, “Unleashing Prosperity Through Deregulation,” promising to kill 10 regulations for each new one he enacted.
The order deems federal regulations an “ever-expanding morass” that “imposes massive costs on the lives of millions of Americans, creates a substantial restraint on our economic growth and ability to build and innovate, and hampers our global competitiveness.” It goes on to say that these regulations “are often difficult for the average person or business to understand,” that they are so complicated that they ultimately increase the cost of compliance, as well as the risks of non-compliance.
Reading this now, the passage echoes the comments I’ve heard from industry groups and tax law experts describing the incredibly complex foreign entities of concern rules that Congress — with the full-throated backing of the Trump administration — is about to impose on clean energy projects and manufacturers. Under the One Big Beautiful Bill Act, wind and solar, as well as utility-scale energy storage, geothermal, nuclear, and all kinds of manufacturing projects will have to abide by restrictions on their Chinese material inputs and contractual or financial ties with Chinese entities in order to qualify for tax credits.
“Foreign entity of concern” is a U.S. government term referring to entities that are “owned by, controlled by, or subject to the jurisdiction or direction of” any of four countries — Russia, Iran, North Korea, and most importantly for clean energy technology, China.
Trump’s tax bill requires companies to meet increasingly strict limits on the amount of material from China they use in their projects and products. A battery factory starting production next year, for example, would have to ensure that 60% of the value of the materials that make up its products have no connection to China. By 2030, the threshold would rise to 85%. The bill lays out similar benchmarks and timelines for clean electricity projects, as well as other kinds of manufacturing.
But how companies should calculate these percentages is not self-evident. The bill also forbids companies from collecting the tax credits if they have business relationships with “specified foreign entities” or “foreign-influenced entities,” terms with complicated definitions that will likely require guidance from the Treasury for companies to be sure they pass the test.
Regulatory uncertainty could stifle development until further guidance is released, but how long that takes will depend on if and when the Trump administration prioritizes getting it done. The One Big Beautiful Bill Act contains a lot of other new tax-related provisions that were central to the Trump campaign, including a tax exemption for tips, which are likely much higher on the department’s to-do list.
Tax credit implementation was a top priority for the Biden administration, and even with much higher staffing levels than the department currently has, it took the Treasury 18 months to publish initial guidance on foreign entities of concern rules for the Inflation Reduction Act’s electric vehicle tax credit. “These things are so unbelievably complicated,” Rachel McCleery, a former senior advisor at the Treasury under Biden, told me.
McCleery questioned whether larger, publicly-owned companies would be able to proceed with major investments in things like battery manufacturing plants until that guidance is out. She gave the example of a company planning to pump out 100,000 batteries per year and claim the per-kilowatt-hour advanced manufacturing tax credit. “That’s going to look like a pretty big number in claims, so you have to be able to confidently and assuredly tell your shareholder, Yep, we’re good, we qualify, and that requires a certification” by a tax counsel, she said. To McCleery, there’s an open question as to whether any tax counsel “would even provide a tax opinion for publicly-traded companies to claim credits of this size without guidance.”
John Cornwell, the director of policy at the Good Energy Collective, which conducts research and advocacy for nuclear power, echoed McCleery’s concerns. “Without very clear guidelines from the Treasury and IRS, until those guidelines are in place, that is going to restrict financing and investment,” Cornwell told me.
Understanding what the law requires will be the first challenge. But following it will involve tracking down supply chain data that may not exist, finding alternative suppliers that may not be able to fill the demand, and establishing extensive documentation of the origins of components sourced through webs of suppliers, sub-suppliers, and materials processors.
The Good Energy Collective put out an issue brief this week describing the myriad hurdles nuclear developers will face in trying to adhere to the tax credit rules. Nuclear plants contain thousands of components, and documenting the origin of everything from “steam generators to smaller items like specialized fasteners, gaskets, and electronic components will introduce substantial and costly administrative burdens,” it says. Additionally the critical minerals used in nuclear projects “often pass through multiple processing stages across different countries before final assembly,” and there are no established industry standards for supply chain documentation.
Beyond the documentation headache, even just finding the materials could be an issue. China dominates the market for specialized nuclear-grade materials manufacturing and precision component fabrication, the report says, and alternative suppliers are likely to charge premiums. Establishing new supply chains will take years, but Trump’s bill will begin enforcing the sourcing rules in 2026. The rules will prove even more difficult for companies trying to build first-of-a-kind advanced nuclear projects, as those rely on more highly specialized supply chains dominated by China.
These challenges may be surmountable, but that will depend, again, on what the Treasury decides, and when. The Department’s guidance could limit the types of components companies have to account for and simplify the documentation process, or it could not. But while companies wait for certainty, they may also be racking up interest. “The longer there are delays, that can have a substantial risk of project success,” Cornwell said.
And companies don’t have forever. Each of the credits comes with a phase-out schedule. Wind manufacturers can only claim the credits until 2028. Other manufacturers have until 2030. Credits for clean power projects will start to phase down in 2034. “Given the fact that a lot of these credits start lapsing in the next few years, there’s a very good chance that, because guidance has not yet come out, you’re actually looking at a much smaller time frame than than what is listed in the bill,” Skip Estes, the government affairs director for Securing America’s Energy Future, or SAFE, told me.
Another issue SAFE has raised is that the way these rules are set up, the foreign sourcing requirements will get more expensive and difficult to comply with as the value of the tax credits goes down. “Our concern is that that’s going to encourage companies to forego the credit altogether and just continue buying from the lowest common denominator, which is typically a Chinese state-owned or -influenced monopoly,” Estes said.
McCleery had another prediction — the regulations will be so burdensome that companies will simply set up shop elsewhere. “I think every industry will certainly be rethinking their future U.S. investments, right? They’ll go overseas, they’ll go to Canada, which dumped a ton of carrots and sticks into industry after we passed the IRA,” she said.
“The irony is that Republicans have historically been the party of deregulation, creating business friendly environments. This is completely opposite, right?”