FAS Endorses the State Energy and Oversight Act of 2026
The Federation of American Scientists (FAS) vigorously endorses the State Energy and Oversight Act of 2026. FAS commends the leadership of Rep. Paul Tonko (D-NY) who is introducing this important legislation that supports the essential functions of public utility commissions in providing affordable, resilient, and reliable energy for consumers across the country.
As FAS has argued time and again, we won’t solve the cost-of-living crisis without improving the capacity of state public utility commissions to protect customers, find and implement new solutions to meet rising demand, and realign broken utility incentives. This bill would take an important step to that end.
The State Energy Oversight Act would create a new Department of Energy (DOE) program to provide financial and technical assistance to public utility commissions, which are responsible for regulating utilities that provide the essential energy, telecommunications, and water services in each state.
The State Energy Oversight Act also authorizes DOE to provide information, recommendations
and best practices, and other forms of technical assistance to states to support rate cases, the design of rate structures, and other matters that come before commissions.
“State public utility commissions are the peoples’ best defense against skyrocketing bills and exploding data center energy use. Unfortunately these commissions are outdated, underfunded, and understaffed, and families and businesses are paying the price. This bill would strengthen states’ affordability arsenal through much-needed funding and technical support for commissions,” says Arjun Krishnaswami, FAS Senior Advisor.
For more information, contact Gil Ruiz at GRuiz@FAS.org or Arjun Krishnaswami at AKrishnaswami@FAS.org.
Coloradans Should Require Data Center Measurements They Can Trust
A lack of monitoring, reporting, and transparency of data centers’ impacts have led to a near-complete loss in public support and trust in the development of data centers in Colorado and across the U.S.
And no wonder: Data centers require irrevocable amounts of electricity and water, can increase air and noise pollution, and become permanent heat islands for surrounding communities.
In this memo we recommend steps Colorado should take now to build an essential foundation for responsible data center development. We believe most Coloradans want data center development to be stewards of natural resources and deliver public benefits. To this end, we recommend the reporting of electricity usage and water usage, as well as fenceline monitoring of air quality and temperature. We also advocate for an independent investigation into infrasound noise pollution for data centers near residences and schools. To start, we must improve our fundamental understanding of data centers’ impacts on Colorado communities so that we can enable more evidence-informed decisionmaking for policymakers, utility companies, and people living near existing or proposed data centers. This is an important time for action.
Challenge and Opportunity
Recent advancements in artificial intelligence (AI) have catalyzed the fastest and broadest U.S. infrastructure buildout since World War II. AI advancement is only accelerating, with companies expected to invest up to $7 trillion by 2030 in the development of data centers, the physical infrastructure of AI. As of June 2026, Colorado has 68 operating data centers, with an additional 17 proposed or under development. Table 1 below shows the eight largest proposed, under construction, and operating data centers in the state.
Data centers vary in size, with AI advancement requiring large hyperscale data centers, which consume 100 megawatts (MW) or more. For reference, 100 MW could power over 105,000 Colorado households. Colorado currently has no operational hyperscale data centers, but there are five proposed or under construction. These five hyperscale data centers could consume approximately as much electricity as 84% of all households in Colorado and as much water as all households in Fort Collins and Grand Junction combined, as shown in Table 1.
This growth is outpacing the state’s ability to assess and manage the environmental and health impacts that data centers could have on local Colorado communities, raising concerns among local residents as development expands. Evidence suggests that data centers have the following environmental impacts.
Yet, there is a lack of transparency and public input on data center development and the potential impacts to diminishing water resources, aging electricity infrastructure, and surrounding communities. This has resulted in broad public opposition. Recent polling shows that 7 in 10 Americans oppose data center construction, with opposition spanning across political parties. In Colorado, 9 in 10 residents support commonsense rules to protect ratepayers, communities, and natural resources from unrestricted data center growth. A poll in Larimer County found that 94% of respondents opposed construction of new data centers. Despite strong public support for data center legislation, both Colorado bills on data centers failed in the previous legislative session: SB26-102 proposed investigating the technical and economic feasibility of large data centers and requiring use of renewable energy, and HB26-1030 proposed tax exemptions to data center development that fulfill specific requirements. One explanation for why these bills failed is because of a lack of understanding on environmental and community impacts of data centers. As a result, local opposition across the U.S. has blocked or delayed at least $64 billion worth of data center projects, including projects in the nearby states of Arizona and Texas. In response, governors in Texas and New York have signed executive orders halting data center development throughout their states to audit data centers’ impacts on electricity and water infrastructure, rate payers, and local communities. In Colorado, half of the 12 most populated counties have imposed moratoriums on data center development (Denver, Jefferson, Larimer, Weld, Boulder, Broomfield), impacting the largest proposed data center in the state and two other proposed data centers (see Map 1 for more information on local data center policies in Colorado). These moratoriums reflect an urgency and need to address gaps in our understanding of data centers’ impacts which have eroded public trust and stymied legislation on future data center development.
To rebuild public trust, promote public health, and improve data center development outcomes for the state’s economy, there needs to be more transparency with the public through clear, accessible data on data centers. Bills and legislation in other states (e.g., Nebraska LB1111, New York Senate Bill S9144A, Florida House Bill 1007, Oklahoma SB1488, Vermont S.205, Wisconsin LRB-6377/LRB-6391 as described in Appendix 1) offer models for Colorado. These examples highlight the need to monitor, report, and investigate key environmental and public health factors: electricity usage, electricity generation, water usage, fenceline temperature, air pollution, and noise pollution. This memo focuses in particular on data centers that consume an average of 10 MW or more to avoid undue burden on smaller enterprise data centers which are not used for AI purposes. This threshold is consistent with those used by the city of Broomfield and the state of South Dakota. The Colorado Department of Public Health & Environment (CDPHE) is well-positioned to facilitate these efforts given their existing work and expertise in industrial and environmental monitoring, reporting, and investigations. Ultimately, this solution can support Colorado in meeting the growing demand for data infrastructure, while still promoting responsible land stewardship and public health.
Plan of Action
Recommendation 1. Existing and new data centers must regularly report electricity usage, electricity generation, and water usage.
To inform government agencies, utilities, and the public, we recommend having all operating, under construction, planned, and future data center sites consuming 10 MW or more to report: (1) monthly electricity usage (average and peak), (2) amount of on-site electricity generation and from what sources, and (3) the amount of water used and discharged. Such reporting requirements are included in Nebraska LB1010, which was unanimously passed in the legislature and signed into law in April 2026. This usage data should be reported to the Colorado Department of Public Health and the Environment (CDPHE). The CDPHE should share relevant information with the Public Utilities Commission (PUC), Xcel Energy, Blackhills Energy, and investor-owned utilities, as well as the Colorado Energy Office (CEO) which develops programs and promotes energy policies to address climate change. The CDPHE should also conduct annual evaluations of reported metrics and revise their reporting requirements as needed to improve their assessment of data centers’ environmental impacts.
Penalties for non-compliance should be a fine of up to $10,000 per violation (consistent with Illinois SB2181), with collected fees going towards CDPHE activities to monitor and investigate data centers. Failure to report across three consecutive months, or four or more months a year, will lead to a notification from CDPHE and the PUC, and developers who fail to respond to these inquiries within 90 days are ineligible for future connection requests from the electric grid as determined by the CDPHE and PUC. This penalty is intended to deter data center operators from choosing not to disclose data during demanding seasons or weather events (e.g. during the summer, drought, or wildfires) when this information is most important. Funding for this monitoring and reporting should come from a fee associated with proposals for future data center development. For example, Nebraska LB1010 has a study fee of $50,000 or $1,000 per megawatt, whichever amount is greater, for data center developers.
Monitoring and reporting of electricity use, water use, and on-site electricity generation will enable PUC and utilities to understand demands on infrastructure and better prepare for future improvements and environmental risks, such as drought preparations. Furthermore, local and state governments can use these data to understand potential community health impacts and inform proposed development of future data centers.
Recommendation 2. Existing and new data centers within three miles of residential, educational, or agricultural areas must have continuous monitoring of air quality and temperature.
Data centers are often placed near residential areas, resulting in potential harm to nearby residents. For example, the under construction CoreSite DE3 Data Center is in the disproportionately impacted community of Elyria-Swansea and across the street from an elder care facility, affordable housing complex, park, and community health center. The CDPHE should conduct additional fenceline monitoring of any existing and future data center sites that meet two criteria: (1) provide a capacity of 10+ MW and (2) are located within three miles of residential, educational, or agricultural areas, which is the regulatory boundary set by Oklahoma SB1488.
Data centers’ operations, specifically the regular testing and/or usage of their on-site generators produce exhaust emissions, which will worsen nearby air quality. The CDPHE is required to conduct fenceline monitoring to control airborne emissions from oil and gas operations. Given this, the CDPHE should establish at least one reference or near-reference air quality monitor and maintain this fenceline monitoring consistent with existing CDPHE regulations and policies on fenceline monitoring (e.g. Regulation 7).
Data centers also generate exhaust heat, becoming a permanent heat island that heats up the surrounding area day and night. The CDPHE should monitor temperature with at least two reference or near-reference thermometers recording fenceline temperature upwind and downwind of the data center site and/or between the site and any concentration of people.
To fund fenceline monitoring, the CDPHE should establish a schedule of fees payable by the owners or operators of data centers (as consistent with Virginia SB 1448). This fee should scale according to the size of the data center sites (as measured by MW).
Recommendation 3. Investigate the impacts of data centers’ noise on people and agriculture.
Existing Colorado laws do not effectively regulate data center noise because of their low frequencies. Colorado’s maximum permissible noise levels (§ 25-12-103) are measured according to db(A). This measure biases towards audible, higher frequencies, as shown by the curved red line in the figure below. This method of measurement under-reports lower frequency noises associated with data centers by over 10 db. Therefore, existing laws do not effectively regulate low hums which come from data centers. In response to this, Weld County added a db(C) noise limit of 65 dB(C) at the property line, although it is unclear if this threshold is appropriate.
When compared to db(Z) and db(C) weightings, db(A) underreports low frequency hums which data centers emit (INVC)
To better understand how data center noise may impact local residences, schools, and livestock, the CDPHE should conduct an investigation of select data centers of varying sizes which are within three miles of any residential, school, or agricultural zones. This investigation may include use of infrasound microphones which meet industry standards (e.g. IEC) and include narrow band frequency analysis and target area analysis, as well as surveys and interviews with local residents and domain experts.
We expect this study to require one full time employee across two years. In the first year, this can be funded through a new one-time fee for all data centers owners and operators of a site of at least 10 MW of capacity. In the second year, this can be funded through fees associated with permits for generators, which CDPHE already requires, and for fines from non-compliance from data centers and industrial sites (as consistent with New York A09086). This application of fines is similar to Colorado’s Impact Cash Fund (§ 25-7-129). Future funding can also come from CDPHE annual emission fees.
Recommendation 4. Disclose data reporting and monitoring findings publicly
Rebuilding public trust requires transparent and independent disclosure. Therefore, we recommend the CDPHE collaborate with the Colorado Energy Office (CEO) to disseminate energy and water reports (Recommendation 1) and the CDPHE integrate fenceline monitoring data into existing platforms (Recommendation 2).
For monthly reporting of data centers’ energy generation, energy usage, and water usage, the CDPHE and CEO should conduct anonymization or aggregation (e.g. by county) required to protect industry secrets and make this data publicly available within 60 days through Colorado’s existing Open Data Portal. This data should be in a format which supports searching, filtering, data analysis, and downloading (e.g. a spreadsheet). Data should be publicly available for at least 10 years from reporting.
Fenceline air quality and temperature data should be made publicly available in approximately real-time through websites such as Colorado’s EnviroScreen and Love My Air. Historical data of at least 36 months should be available for download through public request to the CDPHE.
Regarding the noise pollution investigation (Recommendation 3), the CDPHE should produce publicly available updates every 4-6 months, and a final report within 24 months of receiving funding. This report can inform future standards for data center development and monitoring to mitigate negative impacts of noise pollution on residents, schools, wildlife and livestock. Specifically, local and municipal planning and zoning departments should use this data to inform decisions on data center sites (e.g. minimum distance from communities, farms, open spaces), resource allocation (e.g., grid power allocation, water allocation), and environmental impact mitigation requirements for new data center development.
Recommendation 5. Share data for Economic Development, Planning, and Research
The CDPHE should transmit this reporting and monitoring data to the Colorado Office of Economic Development & International Trade (OEDIT). Doing so will inform state research and development priorities for reducing the environmental impacts of data center operations while advancing economic opportunities. This data should be transmitted at regular intervals, jointly determined by CDPHE and OEDIT.
Conclusion
Data centers are crucial to advance AI innovation in the United States and an incredible opportunity for Colorado. Colorado could see an estimated $144 million in tax revenue and 28,000+ construction jobs and hundreds of permanent jobs across the next decade from 17 currently proposed data center projects.
However, these projects could also exhaust our water resources, compromise aging electricity infrastructure, increase utility rates, harm communities, wildlife and livestock, and violate the will of Coloradans. Monitoring and reporting managed by the CDPHE will ensure more transparency and build public trust, as opposed to asking data centers to voluntarily report or self-regulate. Through independent monitoring, reporting, and investigation on data centers’ environmental impacts, we can promote public trust, inform the allocation of natural resources, and enable responsible governance on future data center development.
Appendix 1. Relevant Legislation, Bills, and Memos on Monitoring and Reporting for Data Centers from other states
New York Senate Bill S9144A: Requires environmental impact reports for new data centers. This includes reporting current and maximum GW capacities and how energy is generated; total and daily water usage and how much water is lost; impact on farmland and prime farming soil; estimates on greenhouse gas and general air pollution emission, water and thermal pollution; noise pollution at half mile intervals from the property line; and health and general impacts on data centers.
Florida House Bill 1007: Any proposed large-scale data center within a 5 mile radius of a residential property or school would need to submit an independent study to ensure state and local law compliance, which may also include “low-frequency noise attenuation measures.” Any data center with an average daily usage of 100,000 gallons or more must report anticipated sources, amounts, and losses of water and a plan that incorporates water recycling.
Wisconsin LRB-6377/LRB-6391: Co-sponsorship memorandum calling for mandatory public reporting of electrical and water use, ensuring data centers do not invest in fossil fuels.
Vermont S0205: Requires the public utilities commission to investigate impacts of data center construction and operation on the state and report to legislative committees. Environmental impacts include “water quality and availability, air quality, local ecosystems, noise emissions, and the availability of surrounding land for other purposes, including farming, conservation, recreation, and housing.” Electrical reporting includes increases to electrical load, ways to strengthen grid reliability and security, ways to promote sustainable and efficient energy usage, and ways to reduce increased electrical costs on other customers. Water reporting include consumption of the cooling of computing equipment used.
Oklahoma SB 1488: Requires regulatory agency to investigate the impacts of data centers on the state’s water supply, utility rates, property rates within a 3 mile radius, and anything else determined necessary by the commission.
Nebraska LB1111: Requires annual reports on data center power usage for data centers using 20+ MW.
Appendix 2. Methodological notes
We assumed the stated energy capacity of data centers were their total facility capacity, not just IT capacity (known as critical megawatts, CMW). If the capacity reported was CMW, you have to multiply by the power usage effectiveness (PUE) ratio to calculate total facility capacity. PUE ≥ 1.0, where 1.0 is ideal and means 100% of power is used for IT. We also assumed facilities operate at their maximum capacity at all times, which AI data centers claim to but may not be true in common scenarios, such as when data centers’ IT usage is below capacity and/or when less cooling capacity is required. Water consumption was estimated based on energy consumption assuming a Water Use Efficiency (WUE) of 1.8L / kWh, a stated average for data centers, and that a data center is running at its stated maximum capacity at all hours. This equates to an annual water consumption of up to 4,165,857 gallons of water per MW (1 MW x 1,000 kW / 1MW x 1.8 L /kW x 1 gallon / 3.78541 L x 24 hrs/day x 365 days/yr). The minimum WUE is 0 (no water usage) which two data centers in Colorado Springs are working towards (Project Taurus and NOVVA). For reference, a three building data center totaling 60MW (CoreSite DE3) has a reported maximum water usage of 805,000 gallons a day. This translates to a WUE of 2.12 L / kWh.
We used 2020-24 census data to assume 2.42 people per CO household and 73 gallons of water used per resident daily (based on data from 15 CO cities in 2022). Therefore, an average CO household uses 64,481 gallons per year. To calculate the equivalent energy usage for Colorado households, we used a 2023 estimate of 8,302 kWh for an average household annually.
We used census estimates for 2025 to estimate the population. The population estimate for 1 July 2025 is 6,012,561, or 2,484,529 households assuming 2.42 people per household.
Data centers provide the most economic benefit during the construction phase. The 17 proposed data centers in Colorado could generate $144 million in tax revenue over 10 years and create 28,696 construction jobs, providing a boon to union labor and local economies. However, completed data centers have mixed permanent employment impacts. A hyperscale data center of 100 MW is estimated to result in 43 permanent jobs, with the number of jobs increasing at an unknown rate with the data center size. Most permanent jobs are typically low-wage, term-limited, non-technical positions (e.g. security, janitorial).
While tax breaks to incentivize data center development are becoming popular, they do not necessarily translate to significant permanent job creation. For example, a $77 million tax break in New Jersey resulted in one permanent high wage job. CO HB26-1030, a bill which lost in the 2026 legislative session, only required 10 permanent jobs for a $250 million minimum investment in data center development. Data centers are among the least labor-intensive structures in the economy, with typically no potential for further creation of permanent, high paying jobs without additional expansion.
Colorado’s climate goals include 80% of electricity coming from renewable sources by 2030. The three largest sources of renewable energy in Colorado are wind, solar, and hydroelectric. However, the federal government has cut more than $600 million in clean-energy funding, and droughts have hindered hydroelectric generation capacity in waterways such as the Gunnison River. As renewable energy generation faces challenges, data centers risk further impeding state climate goals. The five proposed hyperscale data centers which total 1,977 MW of capacity alone (see Table 1) could consume about 1/3 of all renewable energy estimated to be generated by 2030. This consumption does not consider the 68 existing data centers or other proposed data centers. It is therefore unlikely that Colorado can meet state climate goals with unregulated data center development.
To meet greater electricity demand, utility companies must add or upgrade transmission and generation infrastructure. This cost can be passed down to the consumer, resulting in increased utility rates. In Colorado, the Public Utilities Commission (PUC) must approve all rate changes. Alternatively, data center developers can pay for infrastructure upgrades. CO HB26-1030, a bill which lost in the 2026 session, proposed having data center developers invest in utility modernization in order to be eligible for tax incentives.
Modernizing Colorado’s Canals to Save Water Lost in Transit
About 86% of Colorado’s water is used for agriculture, but only about 30-60% of that water actually reaches crops. With historic drought, record-low snowpack, and the Colorado River nearing “system crash,” this proposal focuses on a critical and largely untapped source for Colorado’s water future: the water lost in transit. This may be Colorado’s most readily available tool for strengthening drought resilience and meeting Colorado River Compact obligations without further reducing agricultural production.
Many conservation programs try to reduce the amount of water used in agriculture by targeting consumptive use, i.e. the water actually consumed by crops, through changing irrigation practices, adjusting crop choices, or taking land out of production (“fallowing”). These efforts matter, but they place the burden of conservation squarely on farmers and face significant pushback.
This proposal shares that burden upstream. Conveyance systems consist of thousands of miles of century-old canals that transport water from rivers to farms. Irrigation districts and ditch companies (referred to as “districts” throughout this memo) typically manage these systems with operators driving around the clock to manually adjust wooden boards and heavy gates to control canal flow. These systems lose enormous volumes of water due to inefficiency, imprecise delivery, evaporation, and seepage during transit before water ever reaches a crop.
Infrastructure upgrades like automated gates, real-time measurement, lining, and piping can sharply cut conveyance losses, free water up for other uses, and substantially improve day-to-day district operations. Efficiency also makes water more reliable for farmers, especially in dry years. Most districts want to modernize, but face financial and legal barriers. The policy recommendations outlined in this memo address these challenges, simultaneously benefiting Colorado irrigation districts, farmers, and rivers by:
- Protecting water rights from legal challenges when diversions are reduced through efficiency improvements.
- Incentivizing districts to become more efficient by compensating water freed up through modernization.
- Enabling water savings to be flexibly used and reliably planned around to help meet Colorado’s water goals.
Challenge and Opportunity
Colorado is in the midst of a long-term water crisis. The Colorado Water Plan projects a shortage of 560,000 acre-feet (ac-ft) by 2050. The 2026 snowpack peaked at only 51% of average, and in June, Colorado entered a Statewide Drought Emergency. Summer runoff is forecasted at 21-37% of the median, and a Colorado River conference white paper warned of “system crash” as early as 2027.
This water crisis has drawn intense attention and effort, but agricultural water conservation has mostly focused on reducing consumptive use through measures like fallowing fields. While this is effective in reducing total water demand, these measures risk accelerating Colorado’s already-leading rate of farmland loss, put disproportionate responsibility on farmers, and impose real economic and cultural costs.
Less attention has gone to the significant portion of water lost in transit before reaching a field. Given that agriculture uses over 86% of Colorado’s water (Figure 1), and only 30-60% actually reaches crops, this means roughly a quarter to half of all water diverted statewide is lost in conveyance to evaporation, seepage, or unmanaged return flow. While some of this water is reused and returns to the river, much of it is tied up in inefficient canal systems and unavailable for other beneficial use or planning. Harnessing a fraction of these losses in the Colorado River basin would contribute significantly to the 200,000 ac-ft voluntary conservation goal for the Upper Basin detailed in the U.S. Bureau of Reclamation’s (USBR) Final Environmental Impact Statement (EIS).
Conveyance efficiency is also a powerful drought resilience strategy. For example, a canal system operating at 60% efficiency would require 167,000 ac-ft of river water to deliver 100,000 ac-ft of consumptive use to farms. At 80% efficiency, that system could meet the same demand with just 125,000 ac-ft, and withstand a 25% dry-year cut with no reduction in water deliveries. In a wet year, that extra 42,000 ac-ft could be left instream for rivers and habitats, banked in storage, or exchanged under the new Colorado River conservation framework.
The technical feasibility of conveyance efficiency gains has long been proven. For instance, in response to the Millennium Drought, Australia’s Murrumbidgee Irrigation Area completely modernized and was able to cut water losses by two-thirds. In Colorado’s Grand Valley, automated check structures on the Government Highline Canal reduced the minimum flow needed to operate by more than 60%. Combined with other modernization upgrades, these improvements have kept an additional 40,000+ acre-feet per year in the Colorado River. That’s roughly 13 billion gallons, or nearly 20% of Denver’s annual water use.
Is This Really Saving Water?
This is a common objection to efficiency-based conservation, and it’s worth addressing head-on. Reducing conveyance inefficiencies doesn’t necessarily shrink total water consumption the way fallowing does, since most of what’s “lost” isn’t permanently removed from the system, but eventually returns to rivers or aquifers as “return flows.” However, consumptive use isn’t the only thing that matters to water managers. Timing and location matter just as much as quantity. Water saved through efficiency can be metered and delivered to a specific reach or reservoir on a predictable schedule. Water that resurfaces later as diffuse, degraded return flow generally cannot. Tracking water through a modernized delivery system is also far easier than tracking it across thousands of miles of canals, farm runoffs, spills, and geologically complex aquifers. That distinction is critical for initiatives like the Colorado River Upper Basin’s voluntary conservation goal, which requires water to actually reach Lake Powell, not just exist somewhere in the system. Efficiency and modernization can deliver that kind of control and accountability, and they do so without asking farmers to reduce or change what they grow, unlike consumptive-use-focused programs.
Current Barriers to Efficiency
Several barriers discourage efficiency improvements even when the operational case is clear. The primary argument is that conveyance losses are harmless, or even necessary, since return flows are assumed to stay in the basin, and downstream users and habitats often depend on them. However, it’s an inefficient way to manage water. It’s comparable to leaving the tap running while you brush your teeth because the water comes back to the system through the drain. In reality, a portion of return flows is lost to disconnected groundwater systems or evaporation before returning to the river, and what does return is often mistimed or degraded. This status quo results in river depletions and salinity damages estimated at $332 million annually for the Colorado River alone. The fix is not to keep canals inefficient or to eliminate all return flows, but rather to distinguish critical return flows from nonbeneficial losses through the same no-injury review used in existing state programs like water leasing. Modern measurement and control can then precisely deliver critical return flows where and when they’re needed, while the extra water can stay in the river.
A second barrier is that “use it or lose it” legal fears persist among districts. While formal abandonment is rare, the more realistic concern is “diminishment”: a permanent reduction of a portion of a water right. A lower diversion pattern due to efficiency gains may be read as evidence that the right’s true extent is smaller than decreed. Even though these doctrines are meant to reduce waste, not discourage efficiency, districts are reluctant to show they can do more with less for fear of inviting a future challenge to their right. Districts need a statutory guarantee that investing in efficiency won’t threaten their water rights.
Third, modernization is expensive, and districts often lack the funds to pursue it. Upfront capital is hard to recover because districts have no way to monetize the water they save. As it stands, districts have no legal claim to water conserved through efficiency gains; if they don’t divert it, it simply flows to the next user in line. Despite water’s high value, districts receive no return on their investment. This is compounded by growing unpredictability in funding sources water projects have historically relied on, like federal grants and state severance taxes, and by farmers’ resistance to funding upgrades through higher water prices. Without a way to turn saved water into a new source of revenue, modernization will remain a pipe dream for most districts.
To address these barriers, Colorado already has a strong legal foundation. Existing state statutes protect historic consumptive use when diversions are reduced under approved conservation programs, and the Colorado Water Conservation Board’s (CWCB) Instream Flow (ISF) program provides a model for compensating saved water and streamlining no-injury review. Other prior appropriation states also offer precedent. In Idaho, Code § 42-223(9) protects the full extent of a water right for users who decrease diversions through efficiency gains, so long as the full beneficial use is maintained. In Oregon, the Allocation of Conserved Water Program has enabled districts to certify a legal claim on their efficiency savings since 1987, which they can then lease, sell, or in some cases, apply to new consumptive use.
Colorado came close to solving this problem before. In 2014, SB 14-023 passed both the Colorado House and Senate with broad bipartisan support. This bill would have allowed water users to receive compensation for efficiency savings transferred to the CWCB for instream flow protection. However, Governor Hickenlooper vetoed it at the last minute over water rights issues. This proposal takes the same core approach but resolves some of the earlier concerns by allowing flexible use of saved water rather than an instream-only design.
A Growing Sense of Urgency and Window to Act
The time to finally pass this legislation is now. Record drought, an historic state election cycle, and the expiration of the Colorado River operating guidelines have together created a sense of urgency that makes this common-sense, infrastructure-focused solution extremely timely and critical. Two recent announcements add concrete, immediate stakes. In mid-July 2026, CWCB announced a new state-run contribution program to save 100,000 ac-ft across the Upper Basin by 2028. Two weeks later, USBR’s Final EIS for Post-2026 Colorado River operations was released, setting a target of 200,000 ac-ft per year of voluntary Upper Basin conservation.
Both goals depend on the state’s ability to generate real, verifiable savings, which starts with modernization, control, and measurement. We can’t save what we can’t measure. State Engineer Jason Ullmann has called accurate measurement critical to protecting Colorado’s entitlement under the Colorado River Compact, and the Colorado Department of Water Resources (DWR) is already rolling out new basin-by-basin measurement rules. Colorado is on the right track, but gauges alone will not save water. This proposal builds directly on that foundation by treating measurement not as an endpoint, but as an essential step towards modernization and efficiency savings that support Colorado’s conservation goals.
The conditions for this proposal to succeed are as favorable as they have been in years. Heading into the 2026 elections, water security is a front-of-mind, bipartisan issue. Republicans emphasize water rights as property rights, while Democrats champion full funding of the Colorado Water Plan and an end to “buy-and-drys.” Conveyance modernization advances both agendas simultaneously. It expands water security without asking farmers to bear the cost of conservation, while also providing the legal and technical foundation to support the conservation, storage, and exchange objectives set out in the new Colorado River operating framework.
Plan of Action
Figure 3. Recommendations 1-4 mapped onto a breakdown of a district’s total diversion.
Recommendation 1. Protect water users from legal challenges when diversion reductions result from conveyance efficiency savings.
The Colorado General Assembly should amend C.R.S. 37-92-103(2)(b) to suspend abandonment and diminishment when diversion reductions are the result of conveyance efficiency savings. Conveyance efficiency savings are the amount of water by which conveyance loss is reduced as a result of infrastructure and operational improvements. This definition excludes any reductions attributable to changes in consumptive use, cropping patterns, or weather. In other words, a district that can divert less water because it invested in efficiency should not risk losing the full extent of its water right. Districts must retain the ability to divert their full entitlement when needed, regardless of how much they previously diverted, since needs vary from year to year and efficiency measures may fail. This would extend the same tolling protection SB13-019 and HB17-1233 already provide for historic consumptive use under approved conservation programs, applying protection to the entitlement itself.
Recommendation 2. Create a no-injury administrative process to separate conveyance losses into two categories: 1) critical return flows that should be preserved, and 2) nonbeneficial losses that can be targeted and reduced through efficiency improvements.
The DWR (Office of the State Engineer) should develop an administrative no-injury review process that sets a ceiling on how much a district can reduce its conveyance losses without harming other water rights, ecosystems, or Colorado’s compact obligations. This process would identify where, when, and to what extent critical return flows must be preserved. This mirrors how DWR already handles no-injury review for other specific, temporary changes of a water right, such as Substitute Water Supply Plans, where a full water court proceeding is not required since no water right will be permanently transferred. The process would include public notice, comment periods involving basin roundtables, and technical determinations by Division Engineers.
Recommendation 3. Create a default reimbursement pathway for conveyance efficiency savings registration and compensation.
CWCB and DWR should create a program allowing districts to register conveyance efficiency savings for reimbursement. Districts would be compensated for voluntary reductions in diversions attributable to efficiency improvements, conditioned on all payments being reinvested in continued efficiency improvements. Under the reimbursement pathway, districts would be compensated post-season, based on metered savings against a verified pre-modernization baseline, with no pre-season savings commitments and no penalty for falling short of prior years. This structure reflects the reality that modernization unfolds over many years, and savings will vary while upgrades are underway. As a result, these savings volumes cannot yet be predicted ahead of time or relied upon by other water users for planning purposes, but still merit compensation. The saved water would simply not be diverted and remain in the priority system, like any unclaimed water today, and how savings were treated under the Upper Colorado River Commission’s System Conservation Pilot Program (SCPP).
Recommendation 4. Develop a certification pathway to give conveyance efficiency savings a defined legal status and enable flexible use.
The default reimbursement pathway under Recommendation 3 would not be the only option. Similar to Oregon’s certificate model, once a district has registered savings for several consecutive seasons, DWR would issue conservative baseline savings certificates that give districts a choice on how the water is to be used. Once certified, a district may opt to lease the savings to CWCB’s ISF program for instream protection, lease to other users at negotiated rates, simply leave them in the reimbursement pathway, or shepherd them downstream once the legal authority exists. No portion of the certified volume could be used to expand historic consumptive use. Leasing is an equal, fully voluntary option once savings are predictable enough to support it. Of a district’s total year-to-year savings, these certified baseline savings would be the only portion eligible for leasing to other users, and the priority date of the underlying right would be untouched. Everything saved beyond the certified amount would remain in the flexible, default reimbursement pathway described in Recommendation 3. As with the reimbursement pathway, all resulting revenue must be reinvested in continued efficiency improvements. Baseline savings certificates can be reevaluated and increased as districts continue to become more efficient.
Conclusion
Colorado’s water future is at a crossroads, and the window to act is now. The drought is real, and the political moment is rare. This proposal doesn’t require fallowed fields or further depleted rivers. It targets something simpler and largely overlooked: the water we’re already diverting but not putting to use, lost in transit through century-old infrastructure before it ever reaches a field. By addressing the legal risks and financial barriers that have kept irrigation districts and ditch companies from modernizing, this proposal transforms conserved water from a perceived loss into a tangible asset.
For districts, this means legal certainty and new revenue to modernize infrastructure that was overdue for investment a generation ago. For farmers, it means a more reliable water supply, even during drought years, without having to change their practices or dry-up their fields. For rivers, it means more water staying instream for ecosystems, recreation, and interstate compacts. For other water users like municipalities, it means increased water availability and security. For Colorado, it means a replicable and sustainable model of water stewardship for other states to follow.
Conveyance modernization won’t solve the water crisis alone. However, it is one of the clearest, most actionable steps available right now that protects agriculture, strengthens water rights, and puts more water back in the river.
This is an important concern, especially in Colorado, and this proposal takes it seriously. Not all conveyance losses are equal, and some return flows are genuinely critical to downstream ecosystems, junior water users, or compact obligations. No-injury technical review by Division Engineers must identify and protect critical return flows before any reductions in diversions or conveyance efficiency savings are approved or compensated. However, this proposal argues we shouldn’t keep systems inefficient for the sake of return flows. Instead, we should modernize them, measure what’s actually critical, and deliver it precisely where and when it’s needed. Many return flows are mistimed, degraded, or permanently lost, contributing to depletions along long reaches of Colorado’s rivers and salinity loading that affects water quality across state lines. If that water stayed in the river or in storage, rather than taking a long round-trip through a district, water quality would improve, and Colorado would gain a real ability to plan around that water.
By default, a district’s savings would remain in the river at the point of diversion, just like any unclaimed water today. The Upper Colorado River Commission’s System Conservation Pilot Program operated the same way, leaving voluntarily saved water to reenter the priority system. While this approach is most straightforward in early years when savings volumes are unpredictable, after several consecutive seasons of registered data, conserved volumes would become reliable enough to certify and plan around. At that point, districts could choose to keep the savings in the default reimbursement pathway, formally enroll them in a CWCB ISF lease, lease to a municipality, or share with junior users. These certified volumes are also strong candidates for shepherding once state legislation enables it. Efficiency savings cannot, however, be used to increase historic consumptive use within a district. How efficiency savings are treated in this proposal is one of the biggest departures from the vetoed SB 14-023, which designated savings for protected, instream use only.
Only the proposed default pathway, essentially unclaimed water, falls entirely outside expansion-of-use. Once a district certifies savings to lease to other users, that may be an expansion of use, but a narrowly bounded one. In fact, it’s narrower than Oregon’s program, which permits conserved water to be used toward new consumptive use on farms of participating districts. No recommendation here increases historic consumptive use of farms in Colorado. What does expand is who benefits from water that’s currently tied up in inefficient canals. The Colorado Water Plan projects a 560,000 ac-ft supply gap by 2050, and new supply is unlikely to come and help close it. Making better use of the water already diverted is one of the few options left that doesn’t entail drying up farms. Oregon’s own prior appropriation system has been successfully carving out exceptions to expansion-of-use limits to incentivize efficiency for nearly 40 years. Given that, this proposal is best understood not as a departure from prior appropriation’s principles, but as a practical, limited step toward making them work under conditions the system wasn’t originally designed for. This proposal offers a genuine win-win where farmers can continue farming, while cities, rivers, and other water users gain resilience that doesn’t currently exist under the status quo.
Conveyance losses are already a recognized part of districts’ total entitlement, and they can continue diverting that full amount (if available) until the moment they no longer need it. In other words, if they stay inefficient, they’re entitled to that water. If they become more efficient, they’re not. That’s the crux of the “use-it-or-lose-it” disincentive. Under current law, a district that voluntarily diverts less than its entitlement thanks to efficiency has no claim to the saved water. In this proposal, districts would not divert more water than they were historically entitled to; they’d take less and be paid for the difference. Compensating it isn’t a windfall; it’s recognition of the value the district created through their investment in modernization. Payments must also be reinvested in continued efficiency improvements, so the incentive compounds instead of stopping at one upgrade.
It is fundamentally different in that it does not ask farmers to change their operations or fallow their land. Demand management and fallowing reduce consumptive use by requiring farmers to grow less, change what they grow, or stop farming. This carries real economic and cultural costs and has contributed to Colorado losing more farmland than any other state from 2017 to 2022. (AgDaily, January 2026). Conveyance efficiency, on the other hand, reduces the total amount of water diverted by districts while enabling the same consumptive use and farming operations, even in drier years. There’s a strong perception in Colorado that reducing consumptive use is the only way to generate “real” water savings, but that view rests primarily on assumptions rather than concrete data. Efficiency generates real savings too, not just by cutting evaporative loss, but by capturing water currently assumed to return to the river or aquifer. In reality, no one has precise measurements on where, when, if, or how much return flow actually makes it back. Efficiency offers a path to help meet Colorado’s conservation goals while actually strengthening agriculture rather than scaling it back.
Conspiracy Theories Are Not a Good Reason to Ban Geoengineering Research
Can you hear that? It’s the sound of attempted climate intervention bans and harsh regulations against research failing across the country. Twenty-nine states attempted to curtail research or deployment of geoengineering, solar radiation modification, and/or weather modification by introducing 70 ban bills this past legislative session. But it didn’t work. Only one passed into law – and only one succeeding is a big win!
These bills mostly attempted to prohibit geoengineering, also known as “climate stabilization” or “climate interventions,” which refer to a broad set of emerging strategies designed to deliberately modify Earth’s systems in an effort to stave off the worst impacts of climate change. Examples of climate interventions include cloud seeding (in use since the 1940s) and solar radiation modification (SRM), which is still largely theoretical.
Climate intervention (CI) ban bills put the cart before the horse. They are attempting to ban techniques that have not been thoroughly studied or even deployed, without regard to the potential benefits that these techniques may bring globally – or the unintended consequences of banning relevant research.
Science shows that climate impacts are getting worse and that there is a real possibility of passing critical climate “tipping points,” such as sea level rise, Atlantic meridional overturning circulation (AMOC) collapse, and irreversible melting of glaciers, before the mitigation strategies we have in place have sufficient impact. It may therefore be critical to pair mitigation and the continued clean energy transition with climate interventions to avoid or limit the consequences of overshoot and reduce tipping point risk. This could save countless lives from extreme weather and reduce irreparable harm to our climate systems. But premature ban bills would take this option off the table and keep us from accessing a valuable hazard response tool.
Misinformation in the Driver’s Seat
Three states have succeeded in banning CI research and deployment: Tennessee, Louisiana, and Florida. Florida’s bill, for example, prohibits the injection, release, or dispersion of chemicals or substances into the atmosphere within the state “for the express purpose of affecting the temperature, weather, climate, or intensity of sunlight.” The state touts the bill as successful in stopping CI activity, even though CI activity wasn’t happening in the first place. Florida could achieve the same track record if it passed a bill banning rocks from floating.
Why ban something that’s not happening? At the most basic level, these bills are driven by misinformation. Climate interventions, specifically stratospheric aerosol injection (SAI), have been wrongly conflated with chemtrail conspiracy theories – the false claim that airplane emissions known as contrails (not chemtrails) are comprised of toxic chemicals that hurt human health…and serve as a form of government-orchestrated weather and mind control… (which sounds like a great plot for a science fiction movie, but is far from reality of what’s happening here on Earth). This argument has resonated with the Make America Healthy Again (MAHA) movement, adherents of which are also strong supporters of many of the state ban bills. (I don’t need to point out the irony here, but I will, that geoengineering research is exploring ways that we can reduce the health impacts of heat, wildfires, and other climate driven threats.) This vocal faction also influenced the Clear Skies Act, federal legislation introduced by Rep. Majorie Taylor Green last year to criminalize CI and weather modification research.
Even though the Clear Skies Act didn’t become law, it is a worrying example of how public policy from the state level all the way up to the federal level is being influenced and informed by conspiracy theories instead of fact. This can become a self-perpetuating cycle, in which policy predicated on misinformation ends up giving increased visibility and credibility to that misinformation, which in turn helps it spread further.
Far Flung Impacts
TLDR: research bans have real consequences for public health and American innovation.
The public health sector suffers from research bans because we need experiments and other research in order to accurately characterize and guard against adverse health effects of proposed CI techniques. This includes potential impacts to humans as well as the systems humans depend on, like agriculture, where some research suggests that disrupting weather patterns can affect crop yields. On the flip side, there is other evidence that the stabilization of climate temperatures will create more ideal growing conditions for certain crops and with the lowering of temperatures, comes the decrease in heat related illness and deaths. The reality is, without additional field research, we won’t know what to expect, if the adverse consequences of CI outweighs the benefits, and how to minimize ill effects to the greatest extent possible.
Research bans also impact American innovation. I know you may be thinking, why should I care about that? It’s because stifling science in any domain creates a chilling effect, can introduce knowledge gaps, and can hinder the development of new and potentially beneficial technologies. Imagine if we had banned research into vaccines because of the contingent of anti-vaxxers that exist. We wouldn’t have saved 154 million lives worldwide. The U.S. also needs to keep pace with the scientific advances and innovations of other nations so we can verify new approaches, technologies, and research outcomes that advance our own national goals and priorities. AKA – if another country is able to harness the benefits of climate interventions, we will want to know if the same benefits are replicable here.
Walking hand in hand with the necessity of research are the frameworks that inform its design. Research frameworks need to be grounded in transparency, accountability, and legitimacy. How else do you expect the public to support a large-scale climate intervention? It only works if the researchers can tell the public exactly what they are going to do, detail how they plan to do it, and give impacted communities a seat at the table to give critical feedback (and even veto power) along the way. This will be evermore important as laboratory research evolves into outdoor experiments.
What Experiments Have Actually Happened
Currently, most of what we know about CI comes from computer models, not field research or outdoor experiments. SRM 360, a nonprofit organization that supports informed and evidence-based discussion of SRM, tracks completed, cancelled, and upcoming outdoor experiments related to CI from 2008 to 2028. The grand total? A whopping…14, only three of which have been completed. So it’s not that there’s a lot of real-world CI experiments going on, counter to what the ban bills would have you believe. It’s that a couple of experimenters haven’t done a great job of communicating their plans.
Consider an experiment that was planned in the Bay Area city of Alameda a couple of years ago. Researchers at the University of Washington were planning to test marine cloud brightening (MCB), a technique that involves spraying sea water particles into the air to brighten clouds to aid in blocking the sun’s rays (Australia has had success experimenting with this approach to reduce coral bleaching). The city council unanimously voted no against the experiment – not because they outright opposed the concept, but because the researchers took the “ask for forgiveness instead of permission” approach by not disclosing the experiment to the public or to local leaders well in advance. Another similar incident arose from Make Sunsets, a start-up that has experimented with small-scale applications of SAI, also without gaining public support. The public had questions, and they deserve answers, but banning research keeps us completely out of the loop.
These examples demonstrate the need for regulation surrounding transparent oversight (instead of outright bans). Having a blanket ban risks losing valuable information and advances into modeling, laboratory research, and small-scale outdoor experiments needed to resolve the questions and uncertainties of climate interventions. Outdoor experiments especially are an important tool to understand the most pressing research questions related to CI and how it could mitigate the worst impacts of climate change, but the experiments need to have sufficient guardrails built in.
With outdoor experiments, scientists can test what computer models predict will happen, rigorously assessing in real-world conditions both the potential benefits of CI and what it would take to deploy at scale, as well as potential adverse consequences and strategies for avoiding them. These experiments will need to be done carefully, with transparent oversight and consultation with affected communities. Experiments that violate good research and engagement practices should be shut down. We do that in plenty of scientific disciplines. But responsible experiments should be allowed to proceed and we should reap the benefits of that responsible research. The right policies can make that happen.
Venturing into the Unknown
In an ideal world, we would not have state or federal climate intervention research bans. We would have affirmative policies and protections for researchers to be able to research climate interventions and solar geoengineering technologies. We would have researchers and institutions that would not shy away from revealing the good, the bad, and the ugly of these technologies and doing so responsibly. That world does not yet exist, but FAS believes it is worth building. Creating that world and believing that robust research is needed to answer the tough questions, alongside the creation of forward-thinking governance structures grounded in transparency and legitimacy will take time. But stopping bad policy and premature bans is the floor, not the ceiling. The path forward is building a research environment where good science can thrive, governed by frameworks worthy of the problems we are trying to solve.
Let’s Build America’s Climate and Health Capacity Together
I’ve spent most of my career at the intersection of climate change and human health. During my 15 years in federal service, I helped build the scientific foundation for the government’s work on climate and health, stewarding the health work of the U.S. Global Change Research Program and directing the NIH’s Collaborating Centre for Environmental Health Sciences. In 2021, I took on a new challenge, establishing and leading the Health and Human Services (HHS) Office of Climate Change and Health Equity (OCCHE), to guide HHS and the whole-of-government strategy on climate and health. It was both the best opportunity of my professional life and the hardest thing I’ve ever done.
At OCCHE, we worked to meet that challenge with the relevant federal government levers. We built the country’s first seasonal health forecast, the Climate and Health Outlook, so communities could see hazards like heat and wildfire smoke before they arrived. We supported Centers for Medicare and Medicaid Services in enabling health systems to use microgrids as emergency backup power, opening the door to scaling clean energy. We launched the HHS-White House Health Sector Climate Pledge that drew commitments from 900 hospitals. We ran dozens of webinars to help the nation’s rural and safety net hospitals learn how to access vital Inflation Reduction Act funding. None of it was the whole answer, especially because we were never given sufficient resources for the work that needed to be done, but all of it showed that the capabilities and coordination were worth having.
OCCHE no longer exists. It was eliminated, along with much of the federal infrastructure built to address climate’s health threats. I won’t pretend that was easy to experience. But I have been in this field long enough to know that its most stubborn obstacle is not any single administration. It is attention, recognition, and political will. We need to build a durable coalition that can fight for sustained progress.
Ask people what worries them most right now, and they’ll say the cost of living and their livelihoods, not climate change. But those concerns are not separate. The heat that sends someone to the emergency room, the smoke that keeps a child home from school, the drought that drives up food prices, the storm that knocks out the power of a rural clinic: these are the moments when climate change stops being an abstraction and starts costing people money, time, and their health. This summer, none of that has been hypothetical. During the hottest month the country has ever recorded, towns across Washington fled from wildfires, combined heat and smoke waves across the Midwest and East Coast made it deadly to be outside, and critical water sources along the Colorado River hit their lowest levels ever.
When we lead with those costs, and with solutions that bring them down, we reach people who would never call themselves climate voters. A family whose home is weatherized stays cooler in a heat wave and pays less every month in energy bills. We too often treat health, climate and cost reductions as competing priorities. Done well in our space, they are one and the same investment.
The work has not stopped despite federal headwinds. States and local governments, health systems, researchers, community organizations, philanthropies, and private-sector partners are making progress on decarbonization and resilience, often more creatively than before. When I talk with them, I rarely hear a shortage of ideas or commitment. I hear about a shortage of cross-sector collaboration and resources. There is a need to bring stakeholders across the country together to co-develop a shared sense of priorities, identify better ways to collaborate, and articulate a practical strategy for building national capacity that can outlast any one office or administration.
That is why I’ve taken on a new effort at the Federation of American Scientists, in partnership with the Aspen Global Change Institute’s Climate Reserve, to strengthen America’s climate-health capacity. We are bringing together leaders to look honestly at where the climate and health field stands and where we can accelerate progress together. We will map where capabilities have been diminished, identify the state, local, and private-sector models worth scaling, and build a shared strategy for coordinated action. That means taking on some of the hardest pieces: building trust amidst groups with different perspectives, identifying opportunities where political will, capacity and impact align, and creating a pipeline of sustainable funding for work at the climate and health nexus.
I believe by working together, we can reduce pollution from a health system responsible for roughly 8.5 percent of U.S. greenhouse gas emissions, strengthen the resilience of hospitals, community clinics, and nursing homes, support the health and social services workforce, restore the data and early-warning systems that let us anticipate risk, and direct investment toward building healthy, thriving communities. And in the process we can reduce operating expenses for health care facilities and improve the health of everyone in the country. These are the capabilities a changing climate demands of us, and they are well within our reach.
OCCHE was a beginning, not a finished model. We need to define the capabilities the nation needs to protect health in a changing climate, and to make sure they exist and can be used, wherever they ultimately live. America has extraordinary expertise in climate and health. The work ahead is to turn that expertise into coordinated national capacity and into the connections that make it useful when a community needs it most.
If your organization is working on climate and health, I would like to hear from you. This is a moment for building, let’s do it together.
I Want to Talk About Solar Geoengineering and You Should Too!
It’s been a little over a month since the Federation of American Scientists’ (FAS) inaugural panel on Climate Interventions at DC Climate Week, hosted alongside the Chesapeake Climate Action Network…and I’m still thinking about it.
Why? Because with our climate rapidly deteriorating, the idea that there’s an underresearched suite of technologies that could buy us more time to decarbonize and save countless lives is one that sticks with you.
Sure, shooting particles into the stratosphere to reflect sunlight back into space, or spraying seawater on glaciers to stop them from falling into the ocean, sound like ideas from a science fiction novel. But so does New Orleans falling into the ocean, or extreme heat making parts of the world unlivable, or (more nerdily) Atlantic meridional overturning circulation (AMOC) collapse. These things are all now in the realm of the possible – or already happening. So what do we do about it?
For one, I think we hear out the experts that take these technologies, collectively known as “climate interventions” or “climate stabilization” approaches, seriously. Some of those experts spoke on the DC Climate Week panel and gave me the brain worm that is this blog.
- Andrew Light, Former Assistant Secretary of Energy for International Affairs and Distinguished Fellow at the University of Chicago Institute for Climate and Sustainable Growth
- Shuchi Talati, Executive Director of Alliance for a Just Deliberation on Solar Geoengineering
- Natasha Vidangos, Associate Vice President, Innovation and Technology, at the Environmental Defense Fund
- FAS’ very own Hannah Safford, Associate Director of Climate and Environment
The panelists made one thing loud and clear: we need better tools to respond to the climate crisis, as well as transparent, equitable research governance frameworks for developing them.
Climate Interventions 101
If you’re new to the climate intervention space, welcome! The TL;DR: if we can’t stop the most catastrophic impacts of climate change with current tools quickly enough, then we need a bigger toolbox.
To put it another way, think of climate interventions as a life jacket instead of a rescue boat. In this metaphor, the rescue boat is continued clean energy deployment and carbon capture, entrepreneurial re-thinking of our climate laws and policies, and a holistic approach to decarbonization that’s grounded in transparency, equity, and legitimacy. Climate interventions are what keep you afloat long enough for the real help to arrive.
The panelists focused on one specific type of climate intervention: solar geoengineering, also called Solar Radiation Modification (SRM). SRM aims to artificially lower global temperatures by reflecting incoming sunlight back into space, thereby potentially stalling the worst impacts of climate change. There are three main types of SRM approaches: Stratospheric Aerosol Injection (SAI), Marine Cloud Brightening (MCB), and Cirrus Cloud Thinning (CCT). SAI is usually the subject of most conversation given that it has by far the greatest potential to affect temperatures on a global scale.
Research ≠ Deployment
The panelists were clear that talking about the need for SRM research isn’t the same as calling for deployment (i.e., ultimate large-scale use of SRM techniques). Take hurricanes – Meteorologists study hurricane patterns not because they want a hurricane to make landfall, but to understand what might happen if it does. You can support the research without being pro-hurricane. Same idea here.
Since there’s no world in which we don’t benefit from learning all we can about these technologies and their potential risks and benefits, research should be nonnegotiable.
The Big Deal About Research Governance
The next question is: who’s in charge and gets to make the decisions about how we do said research? That’s what “research governance” is about. Research governance sounds like one of those abstract terms that elites use to confuse people but really just refers to the nuts and bolts of how research into SRM (and other climate interventions) gets done – what the regulations are, who’s involved, and what principles inform decision making.
The panelists felt strongly that the “who” of research governance is almost as important as the “what.” A global intervention needs global involvement in the research design. Impacted countries and communities need a seat at the table to shape the work and think collectively about how research moves forward.
Whether impacted communities are involved can be the difference between success and failure. Two attempted outdoor experiments, SCoPOx (at Harvard) and SPICE (in the UK), failed to secure public buy-in from the beginning. Both were shut down and became unnecessarily politicized. Australia offers a counter-example. That country has successfully carried out MCB research without much backlash because it prioritized public engagement and targeted something tangible the public cares about (protecting the Great Barrier Reef) in its outreach. When you hit people in their hearts, they’re more likely to listen.
Multilateral Action, Please!
SRM is global in nature, so it matters how other countries are approaching (or ignoring) this issue. As of now, there’s no multilateral governance framework for climate interventions, or even an appropriate forum for developing one. Which is a little crazy considering there seems to be a multilateral group for almost everything. Given this, a path forward may be for small groups (or “clubs”) of countries to begin setting norms, standards, and research frameworks together, similar to other international science coordination. For example, the Global Methane Pledge is a coalition of countries that agree to take voluntary action to reduce global methane emissions. A similar research coalition could form around SRM, or climate interventions more broadly.
Research requires money. Currently, only the United Kingdom (UK) funds climate interventions research at any significant scale. And even the UK’s program, structured under their Advanced Research and Invention Agency (ARIA), has a budget of only about $76 million USD – a minuscule amount compared to other critical research areas. Multiple countries working together could pool resources to increase the amount of funding in climate intervention research, and probably should, given what I’ll call “The Stardust Situation”. That situation is the reality that when the government leaves gaps, the private sector sometimes fills them. And in the SRM space, an American-Israeli private company called Stardust is developing its own particles for SAI to fill the gap. Stardust has raised about $60 million to date – almost the entire budget of ARIA.
One could argue that private-sector innovation is good, and there’s some truth to that. But as Hannah Safford put it recently, we might also “not like the choices” that the private sector makes without any guardrails or shared goals and norms around SRM research and experimentation. After all, few people these days are loving our unregulated AI overlords. But, and I’ll quote Hannah again, the United States “government has shown more interest in banning climate science than in thoughtfully governing emerging technology.” The panel agreed it’s past time for this to change.
Building Something New
To sum it up: research can’t responsibly proceed without governance, but governance shouldn’t strangle research. Figuring out that balance is the work ahead in the SRM space. The path is filled with tough questions, but the exciting thing is that we have an opportunity to respond right the first time, since we already know what doesn’t work. So many policy areas are either deeply politicized and/or cluttered with outdated laws or old, creaky institutions. This isn’t the case for climate interventions. Here, we can build new frameworks for climate interventions research and governance that have equity, transparency, and legitimacy baked in from the start. We don’t have to fit a square peg into a round hole. That’s something I won’t stop thinking about anytime soon.
Interested in FAS’ or CCAN’s work on climate interventions? Visit the FAS & CCAN websites.
Disaster Policy Nerds Explain the Good, Bad, and Ugly in FEMA Review Council Report
It’s here! After months of delay, the council tasked by President Trump to review the Federal Emergency Management Agency (FEMA) released its final report earlier this month.
If you’re not a disaster policy nerd like we are, here’s some quick background.
Up until the founding of FEMA in 1979 under President Jimmy Carter, disaster response in the United States was largely disorganized and reactive. The agency has since gone through several major updates. Passage of the Robert T. Stafford Act in 1988 established the formal mechanism for disaster declarations and federal disaster response, while in the years following the 9/11 attacks FEMA transitioned from an independent cabinet agency to part of the newly established Department of Homeland Security.
Recently, FEMA has come under intense scrutiny from the second Trump administration for being seen as ineffective, bureaucratic, and in some cases politically biased against him. While FEMA has had issues in the past related to delayed response times and survivors receiving aid (and criticism with how it handled Hurricane Maria), reports show that many of these issues may be related to an increase in major disasters due to climate change, as well as a lack of regular training, sufficient funding, and adequate staffing – rather than structural issues with the agency. In addition, traditionally “red” states (like Texas, Louisiana, and Florida) typically receive more FEMA funding due to the amount of disasters they experience, so claims of political bias are largely unfounded.
Yet when Trump took office for the second time, there were calls to get rid of FEMA altogether. However, after pushback from citizens and lawmakers and several major disasters, the aforementioned council has opted to avoid recommending completely dismantling the agency. Instead, the council proposes major changes to the way FEMA operates (the council repeatedly refers to a “transformed agency”), via ten general recommendations. Here’s our quick snapshot of the good, the bad, and the ugly of these recommendations, with more detail below:
- The Good: An emphasis on mitigation and streamlining the application process for disaster survivors, along with a focus on getting money to states and survivors quicker.
- The Bad: Shrinking and privatizing most of the National Flood Insurance Program (NFIP), while slashing overall federal funding for disaster response and recovery.
- The Ugly: An unrealistically short timeline for implementing recommendations in the report, as well as a reductionist approach to how disasters enact damage.
Also, a quick note on the United States’ approach to disasters: there is generally an overemphasis on acute economic impacts, and not what they do to systems as a whole long-term. As many disaster researchers will tell you, while hazards can be natural, disasters are not. Disasters are the result of hazards adversely impacting people and their communities due to decisions that increase vulnerability and risk exposure. If we limit our approach to disaster recovery to include only economies and infrastructure, we’ll tend to overlook other critical factors, like public health, social connection, and community wellbeing, that contribute to these vulnerabilities. Just because a house has been rebuilt or power has been restored does not mean recovery has been achieved. Before we implement sweeping changes to the agency responsible for disaster response, it’s important that we as a nation consider this in our approach to disasters.
With that aside, onto the deeper dive into the good, the bad, and the ugly of the review council’s report.
The Good
First, the council re-emphasizes FEMA’s core mission of “[reducing] the loss of life and property and [protecting] the Nation from all hazards”, with the guiding principle of disaster response being “locally executed, state or tribally managed, and federally supported”. This is in line with the survivor-led response approach that many local recovery groups have recommended. Communities have the local knowledge and boots-on-the-ground presence needed to ensure that recovery efforts are appropriate for their situations and contexts, but often lack the funding to implement tailored solutions. The council suggests that FEMA strengthen regional coordination, which could in turn support community- and survivor-led response.
Another positive is the council’s emphasis on rapid mitigation and hardening support to increase efficiency and prevent damage from future disasters. This includes modernizing the federal disaster response by implementing the National Resilience Strategy and updating flood risk information and land use to prevent building in flood plains, both common-sense solutions that can prevent the worst damage from disasters before they even occur. They additionally recommend a two-phase program that would replace the Hazard Grant Mitigation Program (HGMP) with a new program designed to more rapidly distribute federal funding to states (the first 5% of federal funds within the first 30 days following a disaster declaration, followed by an additional 10% within six months). The council calls this new program the “Refined Risk Reduction” Program (R3P), and could potentially address issues survivors have brought up with administrative burden around disaster aid, such as by modifying the Individual Assistance Program and consolidating relief applications into a single direct payment program. There are also specific relief allocations for renters (who often get left out of recovery discussions), including the equivalent of three to six months of rent.
Finally, a recommendation could be either positive or negative (depending at least partially on the details of implementation) is changing how surviving homeowners get reimbursed for individual assistance, including how the amounts are calculated. Currently, home repair assistance payments are capped at $25,000 and based on loss estimates, regardless of property value. The council suggests changing this cap to no more than 15% of the home valuation (so a home valued at $250,000 would qualify for a maximum payment of $37,500), but expanding the purpose of such payments to cover everything from home repairs to funeral costs – i.e., requiring the payments to stretch further than they do currently. Another issue is that FEMA funding has been found to favor wealthier individuals, and basing funding on home valuation has the potential to further drive disparities in aid. Supplemental funding opportunities and/or proactive aid and assistance for lower-income families could potentially reduce this risk.
The Bad
Perhaps the most concerning recommendation of the council is its call for a “lean FEMA workforce”. While the council is less aggressive overall in demanding FEMA staffing reductions than previous drafts (and now just calls for a strategic review of requirements to “determine appropriate staffing levels”), further staffing reductions could exacerbate issues we’re already seeing with FEMA from previous personnel cuts. Disaster survivors have also condemned further FEMA staffing cuts. The council also suggests adjusting how insurance rates are calculated under the National Flood Insurance Program (NFIP) and shifting more flood insurance policies to private markets, which could prohibitively increase premiums, decrease regulation, and lead to more uninsurance and underinsurance in risk-prone areas unless there are appropriate safety measures in place.
Finally, the council recommends decreasing the overall federal share of disaster assistance funding from 75–100% to 50–75% of costs, with states expected to cover the rest. Many states do not have resources to cover the difference – at least in the near term. With a sufficient transition period, though, more heavily weighting state responsibility for disaster aid may increase sustainability in the long term given that the Disaster Relief Fund repeatedly runs low on funds, and that there are concerns with fund depletion as disasters continue to increase in frequency and severity. Another concern is the council’s prioritization of “high performing states”. While this would encourage more states to have hazard mitigation plans in place, it could result in biased decision-making that would favor certain states, and may leave states with fewer financial resources or rare disaster occurrence with less support when it’s most needed.
The Ugly
The biggest overall issue with the council’s suggestions is that they recommend a 2–3 year timeline for states and tribal governments to prepare their fiscal and physical resources to lead disaster response efforts (rather than relying on FEMA). This is an unrealistic timeline, as many states do not currently have sufficient emergency management resources, legislation to establish and support relief funding, or identified revenue streams to pay for the increased cost-share for states. And on top of that, some state governments (like Texas) only meet every two years, making the 2-3 year timeline impossible. Another issue with the council is the apparent bias in its makeup. While it did include representatives with leadership and emergency management experience from hard-hit states like Florida, Texas, Louisiana, Mississippi, and Virginia, there was a notable lack of members from other disaster-prone parts of the country, like California.
Another problem is the council’s recommendation of using a parametric insurance program to replace FEMA’s current Public Assistance Program (the main funding source for community-level disaster recovery). Parametric insurance is a type of insurance where payments are disbursed almost immediately following certain trigger events, and while it has demonstrated potential in rapidly distributing funds after certain hazardous events, there are too many variables to feasibly consider replacing the entire Public Assistance Program in 2-3 years. For example, the council includes an example of determining payment amounts by hurricane category (e.g.,: a Category 2 hurricane would disburse less funds than a Category 4). However, hurricane categories are based on wind speed alone, and hurricanes with weaker winds can still do extensive damage through other means, like storm surge and rainfall (Hurricane Ike in 2008 and Hurricane Harvey in 2017 are two such examples). These complexities would have to be accounted for when establishing the thresholds of a parametric insurance framework, and without rigorous pilot testing, runs the risk of over or underpaying states following disasters.
One final concern is the council made no mention whatsoever of the BRIC (Building Resilient Infrastructure and Communities) grant program. This absence from the report likely means BRIC is not a priority for current leadership, despite it being one of the largest sources for proactive mitigation funding for states and communities. BRIC has been the subject of much consternation following its abrupt cancellation in April of 2025 and its later reinstatement in March of 2026 (following a lawsuit from several states). However, there is now a heavy focus on “shovel-ready projects” (i.e. physical infrastructure projects that have already been planned out). While this sounds good for efficiency, as we noted earlier, not all infrastructure critical to community wellbeing and recovery is physical and “shovel-ready”. Things like social and public health infrastructure are just as important for disaster recovery, but tend to be overlooked in recovery efforts. In limiting BRIC funding to these types of projects, states and local governments will be unable to be truly proactive in their mitigation efforts to prevent future damage from disasters.
Conclusion
The review council’s recommendations are not as bad as they could have been and FEMA’s continued existence seems to be safe (for now). Indeed, many of the recommendations could yield positive results, especially when it comes to reducing the burden and obstacles that survivors face in getting help. However, some of the recommendations (like using parametric insurance methods, reducing state assistance, and attempting to implement sweeping changes over a fast 2–3 year timeline) could pose problems for states, communities, and survivors, and a longer transition period with pilot testing will be needed to ensure these changes happen efficiently and effectively.
Four Innovations Driving Climate Progress in State Government
Subnational governments—cities, states, and counties—took some of the earliest steps in the United States to protect air quality, water quality, and public health. Over the last several decades, as the federal government has wavered in its commitment or failed to take a leadership role on climate change, states and cities have continued to act, both by bold pronouncements and aggressive targets and in more quiet, subtle ways that have eased the path for clean energy and other investments. This has resulted in a diverse cohort of cities and states that have made great progress in advancing clean energy and other climate solutions and are well-positioned to continue this leadership and innovation.
However, the federal government is taking aim at subnational authority and leadership, including threats to states’ actions deemed “overreach.” This threat from the federal government not only limits the ability of subnational governments to develop innovative tools to address climate challenges, but can hinder opportunities for economic development by limiting access to lower cost energy solutions, stifling innovation in emerging industries, and hampering global competitiveness.
Subnational Governments as Innovators and Leaders
Subnational governments, in liberal and conservative states, have long been the drivers of clean energy and climate progress in the United States.
Iowa adopted the first renewable portfolio standard in the United States in 1983, which laid the foundation for the state to remain one of the top renewable energy producing states in the country. George W. Bush and Christine Todd Whitman took aggressive actions as governors to reduce greenhouse gas emissions. Like Iowa, this early commitment in Texas has proven durable as the state continues to lead on renewable energy and energy storage deployment – due in large part to the state’s work to accelerate deployment of renewable energy projects, including permit streamlining and speeding interconnection for new projects. Renewable electricity generation reached a new high in the United States in 2024 and four of the top five producing states were “red” states .
U.S. cities and states have also taken a lead to affirm global commitments to achieve greenhouse gas emission reductions. In 2005, the U.S. Conference of Mayors launched its climate commitment when 141 mayors committed to meeting the emission targets included in the Kyoto Protocol. That same year, Governor Arnold Schwarzenegger issued an executive order in California, establishing economy-wide greenhouse gas emission reduction targets for 2010, 2020, and 2050.
Subnational actions are far more than symbolic. As of today, 33 states have climate action plans, 24 states have economy-wide greenhouse gas emission reduction targets, and 36 states have renewable energy or clean electricity standards. These commitments spotlight state leadership and serve as a reminder of the role of states’ authority and commitment to environmental leadership and their ability to serve as a backstop to federal inaction. They are important in several important ways. These commitments to reduced emissions and clean energy targets send a signal to developers, investors, and other governments that they have customers, markets, and willing partners. This has driven investment in companies and created opportunities for workers and industries in these states.
Subnational leadership is equally important for reimagining the systems, governance, and institutions to make these targets, goals, and investments a reality. For example, cities and states have developed streamlined permitting and inspecting processes for residential solar and energy storage installations (167 jurisdictions in 47 states), identified least conflict areas for large scale renewable energy projects (California and Washington), and developed innovative finance structures and institutions to support clean energy investment and development (e.g., Green Banks in 29 states, the District of Columbia, and Puerto Rico). Scaling these innovations can accelerate the energy transition and boost economic development, workforce development, and local communities.
The Need for Subnational Leadership
Subnational leadership on decarbonization is a practical necessity. Modeling shows that meeting global emission reduction commitments requires actions by subnational governments and businesses. In the United States, existing commitments by subnational governments and businesses could reduce national emissions 25% below 2005 levels by 2030. State level action can be approximately cost-comparable to federal (top-down) action and it tends to focus more on electrification of energy end uses, clean energy, and direct air capture, all solutions that fall under the authority of subnational.
Subnational governments hold primary authority over infrastructure development, siting and development of energy generation and transmission, energy efficiency in buildings, and land use decisions that determine development and conservation patterns. For example, scaling electrification to levels needed to achieve climate goals requires massive build out of clean energy resources and installation of heat pumps and other electric appliances at the household level. At the same time, state and local economies and communities are intimately connected to legacy industries that have shaped local fiscal structures, workforce, and cultures. Therefore, realizing the transformation necessary to decarbonize requires strategic action by state and local government.
Current regulatory structures are not optimized to navigate the challenges of decarbonization. Decarbonization is a systems challenge that depends on successful transformation of technical, social, and economic systems. Decarbonizing the energy system requires building new, clean energy and transportation systems, while at the same time making the investments needed for an orderly transition away from carbon in legacy industries like oil and gas. This dual approach enables environmental progress, while also protecting the workers and communities reliant on legacy industry. This requires linking environmental goals and policy in alignment with economic development, industrial policy, and environmental justice and equity goals. Failing to take an integrated approach repeating patterns of earlier transitions that concentrated pollution and contributed to growing inequity and environmental justice problems. Subnational governments are well positioned to take this integrated approach.
Working at a state or local level means that policies can be tailored to meet local contexts (e.g., economic, political, or social) in a way that top-down federal policies cannot. This is especially important because “successful implementation” means more than reducing emissions. Successful implementation means meeting climate and environmental goals while promoting prosperity and equitable opportunities for all residents, businesses, and communities. Success depends on accelerating project implementation while also addressing affordability issues and promoting society-wide benefits. Successful implementation stories are needed across a diversity of places to demonstrate approaches that are easy for others to follow and will resonate with cities and states that face different political, economic, and social situations. State and local government provide the right scale for building these solutions.
Challenges to Subnational Leadership and Innovation
It must be noted, especially at this point in time, that while the United States has a strong tradition of subnational leadership, it is not guaranteed. Subnational governments are experiencing many challenges that threaten to erode their leadership position—some inherent in the nature of the energy transition and other external factors.
A challenge of the energy transition is the need to build up new, clean energy systems while also carefully phasing out old, polluting systems. Governments need to accelerate investment in new clean energy, while continuing to invest in legacy industries. Failing to do both can introduce threats that can erode or even stall progress on decarbonization. California is experiencing this challenge now as the state navigates the impact of reduced demand for gasoline, a success of the state’s clean transportation policies, and what that means for the state’s oil and gas industry. The instability for oil and gas has resulted in the planned closure of two of the state’s refineries. While these closures will reduce pollution in host communities, they will also result in lost jobs and revenue and have the potential to increase the price of gasoline for California consumers. These dynamics have required the state to take actions to stabilize the oil and gas industry, while also accelerating its clean energy investments.
These challenges, inherent to the transition, are being exacerbated by other factors that threaten to erode subnational leadership and innovation, including:
- Rapid policy shifts at the federal level including termination of federal funding for clean energy projects, permitting uncertainty, and other disruptions that create significant uncertainty for governments, project developers, and labor.
- Growing inequity resulting from systematic racism, economic structures, and lack of opportunity poses a risk that some communities and populations will be left behind in the energy transition.
- Attacks on subnational authority to establish and implement climate, energy, and environmental policies.
While daunting, these challenges make the need for subnational innovation more important than ever.
Current Opportunities for Subnational Leadership and Innovation
Now, more than ever, subnational governments need to be places for regulatory ingenuity and action in the face of strong headwinds. The urgency of climate change requires immediate acceleration of the implementation of climate solutions—to reduce greenhouse gas emissions, protect public health and wellbeing, align economic development with environmental goals, and build resilience to changing climate and extreme events. Cities and states are best positioned to design policies to accelerate clean energy, innovation, and economic development because they can design approaches that work in different social, political, and economic contexts.
Innovation lies in the “how”—how to scope the challenges and design solutions that recognize the complexity of the decarbonization challenge. Subnational governments have already demonstrated several the power of regulatory innovation in several areas that show how rethinking regulatory and governance systems can accelerate progress:
- Innovation 1: Least conflict siting
- Innovation 2: Automated permitting
- Innovation 3: Making projects work for all
- Innovation 4: Deploying innovative approaches to funding and finance
These innovations by subnational governments show how government can accelerate the deployment of clean energy and other climate projects, implement projects that work in specific contexts, and deliver benefits to people and local economies.
Innovation 1. Least Conflict Siting
Uncertainty, conflict, and complex permitting and siting processes are major impediments to project implementation. Developing new approaches to siting and permitting can reduce uncertainty and delays that can increase project costs and diminish developer confidence. State and local governments can develop and deploy several innovative tools that can make it easier and less expensive to implement climate solutions, while also increasing transparency and engagement.
Cities, states, and counties can improve the siting and permitting processes by removing barriers to implementation, engaging with diverse stakeholders, and reducing costs for developers, government, and residents and businesses. For siting, this can include thinking at a regional or multi-project scale to identify priority areas for development. Engaging stakeholders early in the process can reduce objections and challenges later in the project process. Least-conflict siting processes provide one approach to innovate in the siting process.
Siting Innovation: Least Conflict Siting Process
Least conflict siting is a data-driven, participatory siting process guided by stakeholder priorities. A least conflict siting process uses spatial data that reflect stakeholder priorities (e.g., prime agricultural lands, sensitive habitat, etc.) to identify areas for infrastructure siting that avoid areas of high conflict. Using a participatory, stakeholder-driven process can avoid conflict at later stages in the development process, reduce uncertainty for developers, and provide a more transparent process for local residents, business, and other stakeholders. By identifying least conflict lands, stakeholders can then focus on removing obstacles to development on those lands (e.g., access to transmission). The process is non-binding, so can be adjusted as conditions or priorities change.
A least conflict siting process has been used in two regional contexts. The Center for Law, Energy, and the Environment and the Conservation Biology Institute piloted a least conflict siting approach for solar energy development in the western San Joaquin Valley in California in 2016. The project aimed to identify areas with least conflict for renewable energy development in a six-month process. A least conflict siting process has also been piloted for the Columbia Plateau in Washington. The project spanned eight months and concluded in 2023.
Both processes used geospatial data made accessible to all stakeholders through a collaborative gateway. Following this pilot program, Washington State passed a law in 2023 to improve project siting and permitting includes this least-conflict approach as a tool to be referenced for large scale renewable projects.
While this approach was developed in the context of large-scale renewable development, a least conflict-type process can be applied to a range of project types. This could include minerals mining, carbon removal, or transmission projects. The least conflict approach surfaces priorities and concerns in each region and the results of the process can be applied to different types of climate and energy projects, providing an opportunity to provide efficiency. A least conflict siting process requires commitment from a local permitting authority (e.g., local government), project developers, and stakeholders, including environmental, business, economic development, and other groups. The process also requires some investment to establish a robust process, including: spatial data showing energy, environmental, and other characteristics on the landscape, robust engagement, and strong facilitation.
Innovation 2. Automated Permitting
Delays in permitting increase project costs for developers and households. Developing transparent and simpler approaches to permitting can reduce delays, errors, and costs. Analysis of rooftop solar permitting in the United States shows that nearly 80% of a system’s cost is attributable to “soft costs.” These include design, project management, permitting, inspections, and interconnection. Reducing these soft costs through streamlined and/or automated processes can significantly reduce the costs of these projects. Streamlining can address many stages of the permitting process, including application, evaluation, and inspection – saving time and money for applicants, installers, and permitting agencies. For large-scale projects, mapping the permitting process to identify opportunities for creativity, flexibility, and efficiency can improve the permitting process.
Permitting Innovation: Automated Permitting and Inspection
Cities and counties are the permitting authorities for many clean energy projects, including rooftop solar and storage systems. Permit Power is a U.S.-based non-profit organization focused on reducing the bureaucratic impediments to deploying residential solar and battery storage. The organization’s research finds that a typical residential solar installation in the United States is up to seven times more expensive than a similar installation in Australia or Germany. To address this disparity, Permit Power is working at the state and local level to advance permitting and interconnection reform to reduce barriers to residential solar and battery storage projects.
Developers have identified permitting and inspection as major barriers to residential solar and storage project deployment—increasing both the cost and timeline for projects. Several states have adopted laws allowing or requiring cities and counties implement automated or streamlined permitting processes, while others have opted in on their own. The state laws that encourage or require automated permitting for solar projects have taken different approaches, generally with a nod to maintaining flexibility. New Jersey’s law directed a state agency to develop an automated permitting platform, but also to allow local jurisdictions to adopt an alternate platform with oversight from the state agency. Texas and Florida passed laws allowing the use of automated platforms but not requiring them. Maryland passed a law requiring local jurisdictions to use an automated permitting platform.
The Solar Automated Permit Processing Plus (SolarAPP+) provides a free, widely applicable platform to streamline permitting for rooftop solar and solar plus storage projects. SolarAPP+ is available free to jurisdictions designed to make the installation process easier for contractors and permitters, reducing needed staff resources, project timelines, and permitting delays. The National Renewable Energy Laboratory (NREL) developed SolarAPP+ in collaboration with industry and building inspectors. The platform streamlines permit approval for installations that meet specific requirements.
SolarAPP+ was launched in 2021. At the end of 2023, 167 permitting jurisdictions have adopted or piloted use of the SolarAPP+, and close to 600 additional jurisdictions have expressed interest in the application. Annual evaluations of the platform’s use show that permits for code-compliant systems is nearly instantaneous and that SolarAPP+ projects complete the full permitting process faster than installations that use the traditional permitting process. The evaluations also document savings in staff time and reductions in project delays.
SolarAPP+ is now managed by an independent foundation and is available to all jurisdictions free of charge.
Innovation 3. Making Projects Work for All By Using Community Benefit Tools
A risk of moving projects at a more rapid pace is the potential for harmful, unintended impacts on communities and the environment, including concentration of industrial activities, damage to habitat and natural systems, and reductions local quality of life. At the same time, these projects can bring economic development, workforce, and associated benefits to host communities. Community benefits tools can reduce conflict and improve project delivery by minimizing harms and harnessing benefits from these investments.
Community benefit tools can provide a mechanism for ongoing accountability and transparency for host communities, businesses, residents, and other stakeholder groups. These tools include community benefits agreements, community and cooperative ownership structures, and community oversight structures. If carefully crafted, community benefits tools have the potential to deliver meaningful benefits to infrastructure host communities, provide opportunities for community oversight and shared governance of projects, and reduce friction between developers and communities. Including community organizations and stakeholders as planning and implementation partners is vital to the success of these tools.
Subnational governments can require or create incentives for the development and use of community benefits tools for project deployment and they also have an important role to play in building community capacity to engage in the development and deployment of community benefits tools. They are also well-positioned to create the guidance and accountability tools to create the conditions for more effective community benefits structures. However, the existence of a community benefits agreement or related tool is not sufficient in and of itself, these tools need to be developed and designed well to deliver benefits to communities.
Importantly, linking community benefits to siting and permitting innovations can provide durable assurances of project performance and that a project will deliver benefits to a host community.
While requirements and incentive structures have promise, it is critical that tools are available to ensure that community benefits agreements are done well. These include guidelines for agreement development and technical and legal assistance for communities to ensure that agreements deliver real benefits to communities. It is worth noting that developing project by project community benefits agreements could result in two unintended and undesirable outcomes: the added process could slow down or discourage wanted projects and host communities end up with piecemeal benefits that cannot deliver meaningful and transformative investments in a community (e.g., comprehensive workforce development, integrated infrastructure investments, etc). Imagining scaled approaches (e.g., across a city or county scale) to deliver community benefits in a holistic manner across multiple projects in that area could increase efficiency for developers and support transformative investments in places hosting multiple projects or project elements.
Community Innovation: Models to Deliver Community Benefits
Community benefits agreements associated with development projects can deliver meaningful benefits to host communities, including investments in infrastructure, workforce development, and other community investments. State or local governments can require community benefits frameworks for projects in a specific geography (e.g., a community benefit ordinance) or create incentives for the development community benefits agreements or other structures to streamline project development (e.g., California Assembly Bill 205).
Detroit adopted a Community Benefit Ordinance in 2016. The ordinance requires that projects valued above $75 million or that receive significant subsidies from the city provide additional benefits to the community where a project is sited. When the ordinance is triggered, a Neighborhood Advisory Council from the project’s impact area is formed to work directly with the developer. The City of Detroit tracks progress on the commitments made through the agreements developed under the ordinance. Since its passage, eleven projects have finalized agreements under the ordinance and four more are in progress. Regular review of the ordinance’s performance has identified areas for improvement but monitoring shows that it has delivered measurable benefits in Detroit communities.
In accordance with California Assembly Bill 205 (2022), the California Energy Commission (CEC) has developed an Opt-In Certification program for clean energy projects including large-scale renewable energy (i.e., greater than 50MW), energy storage, and some clean technology industrial facilities. Through the opt-in certification program, the CEC can issue a permit for the project and enable it to forego permitting by local land use authorities and most, but not all, state permits. To qualify for the Opt-In Program, a project must meet a set of requirements, including entering into at least one legally-binding and enforceable agreement that benefits one of more community-based organizations in the project area (e.g., a community benefits agreement). For most qualifying projects, the Opt-in Program provides a faster timeline for environmental review (within 270 days of a project’s complete application, in most cases). However, implementation of the Opt-In Program is limited to date.
Innovation 4. Develop Innovative Financing Tools
Funding and finance for climate actions is a major barrier to advancing action, especially as the federal government claws back and reduces federal funding for energy, environmental, emergency response, and other programs that states, cities, and project developers have depended on. Now more than ever, developers, cities, and states need to be innovative in how they access and deploy funding and finance tools to support project development.
Subnational jurisdictions can initiate various revenue generation strategies to support project development. They can also access or establish different funding (i.e., grants) and financing strategies (i.e., loans) to support public and private project development. Subnational revenue generation tools include bonding authority, taxing structures, credits programs, and implementation of pricing programs (e.g., congestion pricing in New York City). They can also establish and/or access financing institutions like green banks and public-private structures to finance project development.
Subnational governments need to deploy a suite of revenue generation, funding, and financing strategies to support implementation and unlock access to private capital and investment. This is especially true given current threats to municipal finance, including withdrawal of federal funds, increasing climate risks and disasters, and the fiscal dimensions of the energy transition that affect local revenue structures. An analysis of options to support implementation of San Francisco’s Climate Action Plan found that the City needed to access all tools available to it to achieve the levels of investment necessary to implement the plan. This included development of new tax and fee structures, use of financing districts, integrating climate actions in the City’s schedule of general obligation bonds, establishment of a green bank, and implementation of pricing policies, including congestion pricing. Since the time of the analysis, the City of San Francisco passed Proposition A in March 2024, the city integrated climate-related actions into a scheduled general obligation bond to support affordable housing.
Financing Innovation: Public Finance for Transmission Infrastructure
Thirty states either have or are considering development of a green bank. A green bank provides access to capital for clean energy and other sustainable projects by issuing loans to projects that might otherwise have difficulty accessing capital. Programs within the California’s Infrastructure and Economic Development Bank (I-Bank), the State’s financing institution to support public infrastructure and private development projects that benefit California’s economy and quality of life, serve as the state’s green bank. Recent legislation established a program within the I-Bank to support investment in transmission infrastructure.
Transmission infrastructure is needed in many regions to distribute clean, renewable energy from where it is generated to load centers. California anticipates a quadrupling of in-state renewable energy generation by 2045, which will include offshore wind generation off the northern and central coasts, large scale solar generation in the Central Valley, and geothermal energy from the inland south regions of the State. Currently new transmission is funded though investor-owned utilities that pass costs on to ratepayers or by private developers.
To provide an alternative model, California recently established a public financing mechanism for new transmission infrastructure, the California Transmission Accelerator Revolving Loan Fund Program. The Accelerator will exist in the State’s I-Bank, the State’s financing institution to support public infrastructure and private development projects that will benefit California’s economy, jobs, and quality of life. The Governor’s Office of Business and Economic Development will develop a financing and development strategy in coordination with the State’s energy agencies to guide the implementation of the Transmission Accelerator. The program is designed to reduce burdens on ratepayers by using State funds to support needed transmission infrastructure development.
Closing Thoughts
We are at a critical moment for climate progress—given both the urgency of climate change and political polarization in the United States. However, this combination provides an opportunity for creative thinking and innovation at the subnational level. State and local governments have an opportunity, and perhaps obligation, to reimagine the regulatory, institutional, and governance structures to design decarbonization strategies that work for state and local economies, communities, and the environment. If undertaken at scale and implemented quickly, these subnational actions can have a significant impact on carbon emission reductions.
Some ways to help realize this innovation include:
- Build Subnational Capacity. Cities and states need additional resources and capacity to develop policies and programs, access funding and financing to implement projects, and partner with industry, communities, and labor to build durable solutions—especially in rural and under-resources areas. Building additional capacity requires creative use of existing public resources; partnership with the private sector, non-governmental organizations, research institutions, and philanthropy; and building networks for peer to peer learning, sharing, and collaboration.
- Leverage Networks to Replicate and Scale Successes. Subnational governments have strong platforms to share and scale successful policy actions. When President Trump withdrew the United States from the Paris Agreement in 2017, a bipartisan group of states established the U.S. Climate Alliance. The members of the U.S. Climate Alliance have committed, collectively, to achieve net-zero emissions as soon as possible and by 2050 at the latest. Climate Mayors, established in 2014, is a network of almost 350 mayors from nearly all fifty states that are committed to upholding the Paris Agreement. Together, these networks—and others—represent a significant share of the U.S. population and economy and provide a community of practice to support policy development and implementation. Subnational collaboration extends beyond the United States, with subnational networks like the Under2 Coalition that includes over 180 subnational governments across six continents committed to achieving deep GHG emission reductions. These networks can provide durable platforms for replication and scaling of successful policy innovations.
- Respect the Power and Potential of Subnational Governments. Subnational governments have a long legacy of leadership and innovation, due in large part to the country’s history of cooperative federalism. This system has provided room for creative solutions and policies tailored to each state’s unique economy, environment, and culture. Congress and the White House need to respect this and build capacity in cities and states to enable them to align economic and environmental goals.
Hot Takes: What the FY27 Presidential Budget Request Means for Climate and Energy
President Trump released his FY27 budget plan last week. What should we think about it?
Once upon a time, the President’s budget was a realistic proposal to Congress about what the federal government should spend money on. These days, it’s essentially just a declaration of everything the President would do if Congress didn’t matter at all.
There’s an argument, then, that we shouldn’t take the President’s budget too seriously: after all, recent history shows us that Congress doesn’t. President Biden repeatedly asked for, and failed to receive, massive IRS expansion, housing investment, and tax hikes on the wealthy and corporations; President Trump last year suggested massive cuts to federal science funding that Congress essentially ignored.
Yet the current Trump administration has also shown that it’s not taking seriously Congress not taking it seriously: including by impounding funds and pursuing other avenues to push its spending (and cutting) priorities through using executive action.
The way to calibrate is by treating the President’s budget as a fever dream…albeit one that might come true. With that in mind, here are some of the key dream sequences we’re paying attention to from a climate, environment, and energy perspective. Warning: some may keep you up at night.
Topline numbers
In terms of non-defense discretionary spending, the $660 billion FY27 request is a 10% decrease from current levels – a smaller swing than last year’s $557 billion FY26 request, which proposed a 23% cut that Congress largely ignored. However, the difference can be attributed almost entirely to the fact that Congress reset the baseline upwards when it rejected those FY26 cuts, as well as to proposed increased spending at the Department of Veterans’ Affairs (for improving medical care) and Department of Justice (including funding for increased law enforcement in cities, funding FBI salaries, and re-opening Alcatraz).
For climate and energy policy specifically, FY27 largely runs the same plays as FY26: slashing line items related to climate change and advancing a fossil-oriented “Energy Dominance” agenda while rolling back clean energy and environmental justice investments from what this administration terms the Biden-era “Green New Scam”. As with FY26, the request targets climate, energy, and environmental programs with demonstrated bipartisan congressional support. One example is the CDFI Fund, which finances clean energy and community development lending in underserved communities and which Congress explicitly preserved last year after the administration first proposed eliminating it.
Overall, the President’s FY27 budget request is less a new proposal than a budget formalization of many climate- and environment-related cuts that the Trump administration has pursued over the past year through executive action and impoundment.
Energy
For the second year in a row, the Trump administration is requesting to cancel almost all remaining unobligated IIJA funding across the Department of Energy ($15.2 billion in total). What’s striking about these cuts is how indiscriminate they seem to be, including cuts to programs that align with this administration’s stated priorities (including critical minerals, geothermal energy, and hydropower). The throughline appears to be less about policy judgment than about demonstrating categorical opposition to anything passed under the IIJA banner.
Yet not all of this funding is being outright cancelled: some is being redirected. $4.7B of unobligated IIJA funding intended for Hydrogen Hubs is being steered toward baseload power and AI supercomputers instead. When you dig deeper into that redirect, it’s a mixed bag. $1.2B will go to new supercomputers at Argonne and Oak Ridge National Labs, as part of DOE’s new Genesis Mission. The remaining $3.5B would largely support coal, oil, and gas infrastructure upgrades and prevent 4 GW of coal plants from retiring as planned. The same tranche of funding will also support some genuinely needed improvements, such as strengthening grid reliability, installing new battery storage, and improving the power output of nuclear and hydropower facilities. Funding for geothermal, ostensibly an administration priority, is surprisingly absent given its status as a firm baseload power source.
Mixed messages around geothermal continue in the budget for the new Hydrocarbons and Geothermal Office (HGEO), created during DOE’s November 2025 reorganization by merging the Geothermal Technologies Office with Fossil Energy. The administration requests $676 million for the combined office, a 14.1% decrease from the FY26 enacted. The most striking line item within HGEO is a 329% surge in funding to modernize coal mining processes and extend the productive life of existing mines, including through the use of AI and robotics. Geothermal funding is preserved at $150 million, emphasizing pilots and R&D over commercial-scale projects. Again, what’s conspicuously missing – given the administration’s stated enthusiasm for geothermal as a firm baseload source – is any meaningful push toward commercial-scale deployment.
Beyond the IIJA cancellations, the administration is requesting a massive 63% cut to the budget of the new Office of Critical Minerals and Energy Innovation (CMEI) – the reorganized successor to the former Office of Energy Efficiency and Renewable Energy – compared to the FY26 budget of the offices folded into it. The only winner seems to be critical minerals, which receives a $281 million (339%) increase in funding compared to FY26. Similar to FY26, the request zeroes out the budgets for hydrogen, solar, and wind programs, as well as state and community energy programs and the Federal Energy Management Program. The request also nearly zeroes out budgets for bioenergy, vehicle, and building technologies, while making deep cuts to hydropower and industrial efficiency and decarbonization technologies.
Cuts continue for DOE offices responsible for keeping America’s lights on. The Office of Electricity (OE) and the Office of Cybersecurity, Energy Security, and Emergency Response (CESER) face cuts of 22% and 16%, respectively, from FY26 enacted levels: significant indeed at a moment when electricity demand is surging, extreme weather is straining grid infrastructure with increasing frequency, and the U.S. grid is already widely acknowledged to be aging and vulnerable. Underfunding these offices now carries real risk for the administration’s own energy dominance goals, let alone broader reliability and resilience.
Wildfire resilience
The two largest federal landowners – the Department of the Interior (DOI) and the U.S. Department of Agriculture (USDA) – are both slated for significant cuts under this budget, at 13% and 19% reductions from FY26 enacted levels, respectively. The takeaway: while the FY27 budget makes some new investments in wildfire resilience, it does so against a backdrop of overall austerity.
That said, the budget request acknowledges the escalating urgency of the wildfire crisis. Wildland fire suppression resources at DOI received a modest 3.5% increase; preparedness and fuels management at the agency also saw a slight bump. Additionally, the budget introduces a Fire Intelligence and Technology line item in DOI’s budget funded at $123.5 million. This includes $20 million to support a Wildfire Intelligence Center that appears broadly aligned with proposals such as those laid out in the bipartisan Fix Our Forests Act (S. 1462), which FAS endorsed.
The real-world efficacy of these wildfire-specific investments could be undermined by cuts to fire-relevant research and monitoring infrastructure. While the request states that “the USWFS will fund all wildland fire resources currently funded separately by [USDA and DOI],” proposed cuts to Forest Service programs such as State, Private, and Tribal Forestry and Forest and Rangeland Research could also impact fire resilience. Budget cuts and layoffs at FEMA, NOAA, NASA, and EPA could also materially compromise capacity for other critical wildfire tasks the government is responsible for (e.g., fire detection, fire response, weather forecasting, smoke monitoring, and post-fire ecosystem assessment). For example, the NASA/USGS Landsat program helps us understand the impact of wildfires on the landscape and support better management. NASA’s FY27 budget justification allocates $109 million “to support a phased transition of the Landsat program to a commercial solution” rather than continued government involvement. The justification offers no detailed rationale for why privatization is the right path forward.
Cuts to USDA Forest Service Wildland Fire Management accounts reflect the Administration’s intent to consolidate wildland fire functions across DOI and the Forest Service. Echoing an earlier Executive Order, the budget proposes fully unifying the USDA Forest Service’s wildland fire resources and operations into Interior’s newly created U.S. Wildland Fire Service (USWFS). While DOI has reportedly begun consolidating wildfire operations across its own agencies under the USWFS, integration of the Forest Service is on hold; FY26 appropriations bills directed Interior and USDA to contract a feasibility study of this approach. It is unclear how this reorganization would interact with the recent proposal to move Forest Service headquarters to Salt Lake City.
Environmental pollution
From an environmental protection standpoint, the most glaring single number in this budget is President Trump’s proposal to cut EPA’s budget by $4.6 billion — a 52% reduction that would bring the agency to its smallest budget since the Reagan administration. How does the administration propose slashing the EPA’s budget by more than half? By targeting specific programs that have historically done some of the agency’s most consequential work.
Among the casualties: the program that oversees Superfund site cleanup. Superfund sites are locations that are so contaminated by pollution that they’re considered dangerous to human health. Think sites of former mines, toxic waste dumps, and other nastiness that make the families that live around them very sick. There are more than 1,800 Superfund sites across the United States, concentrated heavily in Texas, California, Pennsylvania, New York, New Jersey, Florida, and Washington. Without the Superfund program, cleanup won’t happen, and families living nearby – who often can’t afford to move or don’t even know the risk exists – will just keep getting sick.
Like breathing clean air? Happy the ozone layer is healing? Too bad. If Congress follows the President’s proposed budget, then the Atmospheric Protection Program will be eliminated. The APP is the EPA office responsible for reducing air pollution, restoring the ozone layer, improving energy efficiency, and researching climate change. These aren’t marginal cuts. They’re core federal functions that have measurably improved air quality and public health over decades.
The contrast with what the EPA is being asked to invest in is telling. One notable increase in EPA’s budget is a $14 million boost for NEPAssist, the web-based tool that streamlines permitting under the National Environmental Policy Act. This boost reflects the administration’s vision of what EPA is for: making it faster to approve projects, but not study or reduce the pollution they might produce.
Energy affordability, extreme heat, and public health
The FY27 proposal once again tries to eliminate the only sources of funding to support families struggling with energy affordability. The proposed budget would fully defund the Low Income Home Energy Assistance program, which supports families with heating and cooling bills at a time when one in three American households are facing energy insecurity and electricity rates are surging across the country. The budget also zeroes out the Weatherization Assistance Program, which funds home retrofits that reduce energy consumption and help families stay safe during extreme heat and cold. Getting rid of both LIHEAP and WAP simultaneously leaves no federal backstop for the most vulnerable households at the precise moment that climate-driven temperature extremes are intensifying.
The FY27 proposal also targets research and data collection critical to evaluating extreme weather and heat’s risks and impacts. The proposed $1.6 billion cut to NOAA’s Office of Research and Development by $1.6 billion would eliminate programs to help communities prepare for and protect against extreme heat events, flooding, and other climate-linked weather hazards. The planned commercialization of NASA’s Landsat raises further concerns about data continuity and access, particularly for local governments and planners who depend on Landsat data to assess heat islands, drought conditions, and other environmental risks.
On the health system side, the budget would eliminate the Hospital Preparedness Program (HPP), the only program supporting health care systems ready for all hazards – including floods and storm surge that can inundate hospitals, and extreme heat waves that can overwhelm emergency rooms. HPP funding has helped regions such as the Pacific Northwest, where extreme heat has already been deadly, avoid repeating past disasters. The budget proposes redirecting these functions to the CDC’s Public Health Emergency Preparedness program, which experts have long identified as insufficient for the scale of the need.
Workers and families face additional exposure under this budget, which scales back prevention and enforcement dollars for workplace safety. The proposal budget cuts the Occupational Safety and Health Administration’s budget by 10%, with reductions focused on enforcement capacity and workplace safety training funding. And two of the primary federal vehicles to support community-level climate resilience would be eliminated. The Community Services Block Grant and the Community Development Block Grant, have both been backbone sources of funding to support efforts to prepare communities for extreme weather’s impacts. For example, the Community Services Block Grant provides the operational funding for Community Action Agencies, which are a key pass-through organization for implementing efforts like home weatherization.
Climate and environmental science
The FY27 budget doesn’t just target programs aimed at reducing emissions and cleaning up our environment. It targets the scientific infrastructure that tells us what’s happening and how to fix it. The President’s budget request would systematically defund the agencies, offices, and university programs responsible for climate observation, modeling, and research across the federal government. NSF has historically been the nation’s primary funder of basic research, including the university-based science that generates most of what we know about climate systems, ecosystems, and environmental change. The administration proposes cutting roughly 55% (~$5 billion) from NSF’s budget, with about a third (~$1.8 billion) of this coming from the parts of NSF (geosciences, biological sciences, engineering, and polar programs directorates) most directly relevant to climate and environmental science. AI and quantum computing are the only areas the administration proposes to protect or grow within the agency.
The DOE’s Office of Science would take a $1.1 billion hit, with just under half of that coming from the Biological and Environmental Research program, which funds atmospheric science, climate modeling, and ecosystem research. The administration’s own budget language is candid about the intent: these cuts will, it states, “stop wasting Biological and Environmental Research resources on climate change” and refocus funding toward “AI-enabled earth-energy system modeling to support the Energy Dominance agenda.” At the same time, $1.1 billion is being invested in the new Office of Critical Minerals and Energy Innovation (CMEI), though this number is both a cut compared to FY26 enacted levels from CMEI and is framed explicitly around supply chain security and domestic resource extraction rather than decarbonization.
For the second year in a row, the budget proposes eliminating NOAA’s Office of Oceanic and Atmospheric Research, which houses the nation’s core weather forecasting and climate modeling capabilities (including the Geophysical Fluid Dynamics Laboratory, the birthplace of modern climate modeling). What’s notable about the FY27 request, as analyst Alan Gerard points out, is that it doesn’t even acknowledge OAR’s existence despite Congress having essentially fully funded it in FY26. This illustrates the administration’s willingness to pursue its biggest priorities by hook or by crook.
Finally, EPA’s research and development budget would be reduced to only what federal law legally requires, effectively eliminating the agency’s in-house capacity for the modeling, technical research, and expert analysis that underpins national environmental regulation. An EPA stripped of scientific capacity is an EPA that can neither generate the evidence base for new rules nor credibly defend existing ones.
FAS Launches New “Center for Regulatory Ingenuity” to Modernize American Governance, Drive Durable Climate Progress
WASHINGTON, D.C. — February 12, 2026 — The Federation of American Scientists (FAS) today announced the launch of the Center for Regulatory Ingenuity, a new hub designed to reimagine how the government tackles “wicked” modern problems while delivering everyday benefits for Americans.
“We can’t manage today’s problems with yesterday’s laws,” said Dr. Jedidah Isler, FAS Chief Science Officer. “The Center for Regulatory Ingenuity will bridge the gap between high-level policy design and on-the-ground implementation, ensuring that government promises translate into real-world results that Americans experience.”
FAS is launching the Center for Regulatory Ingenuity (CRI) to build a new, transpartisan vision of government that works – that has the capacity to achieve ambitious goals while adeptly responding to people’s basic needs. CRI does this by (1) creating high-trust environments to brainstorm and refine the big ideas that will breathe new life into government, and (2) building a “network of networks” that supports policymakers and practitioners in implementing those ideas at scale.
“The administrative state has delivered extraordinary achievements in the past, but today’s operating model is a complete mismatch for the complexity we face. As a result, trust in government has been in the basement for decades,” said Loren DeJonge Schulman, Director of Government Capacity at FAS. “Strengthening government capacity is an investment in democracy and deeply intertwined with climate progress. It requires thinking creatively about how to build the government we need, not endlessly pointing fingers at the government we have–CRI aims to do just that.”
CRI is launching with a focus on climate: a space where there’s an increasingly evident mismatch between the functions the government needs to provide and the tools it has to deliver. FAS is pleased to welcome Climate Group North America, ICLEI USA, and the Environmental Law Institute as core partners in this initial work.
“Today’s rollback of the endangerment finding underscores that we are in a new era for U.S. climate policy,” said Dr. Hannah Safford, Associate Director of Climate and Environment at FAS. “To be clear: there’s no credible scientific basis for that rollback, which FAS strongly opposes. At the same time, it’s worth recognizing that while foundational environmental laws like the Clean Air Act worked to curb industrial pollution, they weren’t designed to guide the economy-wide transition to clean technologies that’s currently underway. There’s tremendous opportunity for innovation on how we design and deliver climate policies that are equitable, efficient, effective, and durable. With EPA stepping back on this front, it’s time for others to step forward.“
With the support of contributors from across the ideological spectrum, CRI is already charting paths for a renewed administrative state, a more responsive government, and ambitious climate policy that lasts. These paths are explored in CRI’s inaugural essay collection, Bureaucracy as Social Hope: An Argument for Renewing the Administrative State. The first two of these essays, “Rebuilding Environmental Governance: Understanding the Foundations”, by Jordan Diamond and collaborators at the Environmental Law Institute, and “Costs Come First in a Reset Climate Agenda”, by Devin Hartman (R Street Institute) and Neel Brown (Progressive Policy Institute) are available now; the remainder will be released in coming weeks. Other authors featured in the collection include:
- Nana Ayensu (Unaffiliated)
- Beth Bafford (Climate United)
- Angela Barranco (Climate Group North America)
- Louise Bedworth (UC Berkeley Center for Law, Energy & the Environment)
- Shaibya Dalal (PolicyLink)
- Kirti Datla (EarthJustice)
- Jennifer DeCesaro (Carnegie Endowment for International Peace)
- James Goodwin (Center for Progressive Reform)
- Kristi Kimball (ICLEI USA)
- Jennifer Pahlka (Recoding America Fund/Niskanen Center/FAS)
- Hannah Safford (FAS)
- Loren Schulman (FAS)
- Craig Segall (FAS)
- Nicole Steele (Amalgamated Bank)
- Ali Zaidi (University of Pennsylvania)
In addition, CRI is today releasing “From Ambition to Action: Shovel-Ready Policy Solutions for Climate Leaders”. This policy primer, crowd-sourced from dozens of experts and policy entrepreneurs, outlines how motivated public leaders – especially at the state and local level – can turn big ideas into reality, cutting emissions while delivering cheaper electricity, ensuring affordable housing, and improving transportation for all of America.
Moving forward, CRI intends to deliver more detailed playbooks illustrating how an approach grounded in regulatory ingenuity can improve outcomes and achieve goals in these key sectors, which collectively account for two-thirds of U.S. emissions and contribute at least 25% of U.S GDP.
More information about CRI is available here. For updates, and to stay connected, click here.
ABOUT FAS
The Federation of American Scientists (FAS) works to advance progress on a broad suite of contemporary issues where science, technology, and innovation policy can deliver transformative impact, and seeks to ensure that scientific and technical expertise have a seat at the policymaking table. Established in 1945 by scientists in response to the atomic bomb, FAS continues to bring scientific rigor and analysis to address national challenges. More information about FAS work at fas.org.
Media Contact: Katie McCaskey, kmccaskey@fas.org, (202) 933-8857
From Ambition to Action: A Policy Primer
How public leaders can boost climate progress, restore trust in government, and make lives better…starting today.
People across the nation are clamoring for solutions that make their lives better. And they’re frustrated by the responses they’re getting. Confronting massive inequality, Americans watch leaders finger-point on the price of eggs; yearning for security and stability, Americans watch politics lurch between radically different agendas. No wonder, then, that public trust in the U.S. government has been in the basement for decades. Americans are facing both everyday challenges and a deep, growing sense of discontent. But they’ve lost faith in government to resolve either.
That sense of stuckness doesn’t need to last. But change means focusing on outcomes, eliminating bottlenecks, and prioritizing delivery. It means embracing tools and talent that better connect big ideas to real-world results. It means resisting the temptation to chase buzzwords – from “abundance” to “dominance” to “affordability” – and focusing on the method over the message.
One place to start is with the shift to clean technologies, a place where there is powerful momentum. One in five cars globally are already electric, while heat pumps have outsold gas furnaces in the United States for four consecutive years. The vast bulk of new energy generation is renewable: globally, clean energy investment is now double the amount spent on all fossil fuels combined.
While the transition to clean technologies is unstoppably underway, it is also in its messy middle. Rival technologies and energy systems (and the economic and political systems on which they depend) are now colliding. Many counties and cities depend heavily on fossil fuel revenues; meanwhile, job quality and union density in the renewable energy industry leaves much to be desired. And core parts of our infrastructure – from the power grid to gas stations – are complex and expensive to convert to serve renewable and clean industries, even if those industries will ultimately boost affordability.
Put simply, remaining globally competitive on critical clean technologies requires far more than pointing out that individual electric cars and rooftop solar panels might produce consumer savings. But we also can’t afford to cede the space. Internationally, clean energy spending is booming. China’s clean energy industry by itself would be the world’s eighth largest economy if it were a country, and Europe’s investments have almost doubled over the last decade. Even if current estimates hold, fossil fuel demand will peak mid-century. If the U.S. continues to hold fast to existing policies until then, we’ll be 30 years behind the rest of the world’s energy economy, and it will be impossible to catch up. The bottom line? Good climate policy is good economic policy, and vice versa.
Good climate policy is also good politics. Climate-induced disasters are increasing by the day, and are impacting both safety and affordability. Americans generally see climate and energy policy as important as immigration. Most Americans, on both sides of the political aisle, support environmental regulations and clean energy development. Many say electricity costs are just as stressful as grocery bills, and they worry about higher insurance rates and local market problems. And they’re tired of entrenched corporate interests calling the shots.
What’s needed are creative, clever strategies that boost climate progress while delivering everyday benefits. The Federation of American Scientists (FAS), as part of our new Center for Regulatory Ingenuity (CRI), developed this primer to put a bunch of those strategies in one place. Our goal is for this primer to serve as a resource for public-sector leaders at the federal, state, and local levels who believe that government can do great things for our communities and our planet.
The strategies herein are open-sourced from a diverse network of contributors and collaborators, and are shovel-ready. Many of these strategies are already being deployed across the country. They’re designed to make energy, housing, and transportation better this year.
Indeed, we hope that readers see the actionability of these solutions not just as a benefit, but as an imperative. Americans aren’t looking for the magic message or the magic moment. They’re looking to government for leadership. Every day that government is paralyzed by gridlock, indecisiveness, or fear of failure is another day that it fails to realize the potential of the good that it can achieve, and that public trust in government further erodes. That’s a downwards spiral that we’ve got to stop.
Finally, we emphasize that this primer is a starting place. We’re at the precipice of a new era for climate and energy policy in the United States, and the strategies that will form the backbone of this new era – by adeptly fitting together government capacity, private innovation, and democratic decision-making – are just starting to come into view. As they do, CRI and its partners are committed to working hand-in-glove with bold doers and thinkers, sharpening our collective focus, and realizing the vision of a more responsive government, more optimistic society, and more resilient nation.
Getting to Work: Opportunities in Energy, Transportation, and Housing
Solving problems requires framing them accurately. As observed above, the truth is that clean technologies are increasingly dominant, and that the United States is rapidly falling behind. A response predicated on propping up the 20th-century fossil economy is doomed to fail. So too, we’ve learned, is a response that relies on the U.S. federal government to muscle the clean-technology transition forward single-handedly.
Fortunately, because so many clean technologies are now commercial, the opportunity for leadership on multiple levels, and multiple fronts, has never been more available – or more crucial. For example, simple economics will do much to propel wind, solar, and battery technologies if needed supporting infrastructure is in place and clean technologies are given the chance to compete on fair terms. Policymakers can worry less about expending political capital on expensive public subsidies for clean power, and focus instead on transpartisan policies enabling broad market access, streamlined interconnection processes, and swift power grid build-out. In the transportation sector, policies that ensure transparent vehicle pricing or increase market competition for legacy car companies may matter more than traditional regulatory standards.
This new reality also makes thoughtful economic, industrial, and social policy indispensable. The advent of new technology often comes with the promise of broad societal benefits, but making good on that promise is hardly a guarantee (witness the emergent effects of AI). It’s incumbent on government to ensure that the clean-technology transition reduces inequality and improves quality of life at scale, and that the transition doesn’t abandon workers in fossil-dependent regions and industries to the vagaries of the market. And it’s government, working across multiple scales, that can assess regional comparative advantages and figure out where the United States can still compete – as well as where it must innovate and diversify.
Government leaders, in short, have the unique ability to see all the way from the kitchen table to the commanding heights of the global economy, and to mediate between them.
We illustrate below the types of approaches that entrepreneurial policymakers can adopt to secure U.S. leadership on critical clean technologies, in ways that benefit all Americans. We focus on energy, transportation, and housing, which are collectively the largest sources of climate pollution and key elements of household and regional economies nationwide. The list below is not exhaustive, or comprehensive, but exemplary – a demonstration that there are real opportunities for change.
Unleashing Modern Energy
There’s massive untapped potential for clean energy in the United States. To realize it, we’ve got to make room for new energy to move.
This isn’t primarily a project of continued renewable energy subsidies: there’s good evidence that renewable energy can compete on a level playing field when it’s given the chance. Rather, the project is one of clearing away barriers to financing and building projects, fixing broken market incentives that favor existing players over new entrants and distort energy pricing, and accelerating construction of major grid infrastructure.
This project looks a lot like the successful national push towards rural electrification that the United States led a century ago: a serious effort that aligns private and public investments to rethink how and where we deliver energy. In executing this effort, we must grapple with the full set of barriers to building – not just cost and permitting, but also thorny local siting processes, misaligned incentives for electric utilities, and lengthy wait times to connect projects to the grid.
Today, of course, we’ve also got to reckon with the growing threats of cyberattacks and extreme weather to energy infrastructure, as well as the unprecedented, unpredictable energy demands of hyperscalers. Such challenges can only be managed by a mix of climate stabilization policies, economic risk-sharing strategies, and investments in infrastructure modernization. That’s not a cheap or easy proposition, but it is one with major lasting benefits.
At the consumer level, building more clean energy can help stabilize residential electricity prices (though many other factors also contribute to electricity prices and price volatility). More broadly, clean energy could unlock billions of dollars in potential efficiencies, such as by reducing costs associated with redundant natural gas transmission infrastructure. Expanding clean energy, especially distributed energy resources and virtual power plants, can also upgrade outdated grid infrastructure and secure it against cyber threats. But getting to these benefits requires government leadership.
Energy ingenuity could look like:
- Protecting consumer electric bills from data centers. New power-hungry data centers could raise bills for families and small businesses if we aren’t careful. States and public utility commissions (PUCs) can use ratemaking proceedings to protect households and small businesses from the costs of meeting the demand of large new customers like data centers. For instance, Kentucky’s PUC requires utility contracts with these types of large-load customers to include certain protections for other consumers: any extra costs generated by the large-load customer must be covered by that customer and not place undue load or cost on the utility that can be passed on to general consumers.
- Guarding against confusing and opaque bill increases. Utility companies drive the process of setting electricity rates, submitting justifications for rate hikes that are often tens of thousands of pages long. They frequently lobby regulators and other state policymakers to accept these proposals – and in almost all states, they can recover their lobbying and political expenses from customer bills. As a result, customers are paying more for energy, and it’s difficult for any regular person to understand why. States can help by playing a larger role in evaluating utility proposals and finding bill reductions. In Hawai’i, for instance, the PUC reformed its planning process to engage more stakeholders to produce analysis to inform grid investments and provide more transparency on key decisions. New York passed a law that requires PUCs to explain why rate changes are requested and how the proposed revenue would be spent, while California’s recent statute barring utilities from charging customers for their own lobbying helps even the playing field to ensure rates are set in a more balanced way.
- Making government more responsive to clean energy project needs. Many clean energy projects get stuck in clunky, outdated state and local processes, run by understaffed agencies that weren’t designed for speed and dynamism. Most clean energy projects don’t need federal permits, but almost all must secure state and local approvals before getting built. States can engage industry and communities to identify the biggest roadblocks and then make targeted changes to reduce permitting timelines and increase certainty without sacrificing quality of projects. For example, Pennsylvania recently updated its guidance for stormwater permitting for solar projects to provide developers with more clarity on how projects will be modeled to assess their impacts. A New York law sets standard timelines for permitting decisions and creates a centralized team to improve information sharing and help projects get through the approval process. At the local level, the Sol Smart program has helped hundreds of local governments streamline their permitting processes for solar projects.
- Getting more out of existing grid infrastructure. Modernizing transmission and distribution infrastructure is expensive and takes time; it has to happen but isn’t going to all get done at once. Longer-term investments must therefore be complemented with strategies to reduce operating costs and improve performance of the grid infrastructure we have in the near term. States and PUCs can push utilities, through planning and ratemaking processes, to prioritize integration of distributed energy resources, virtual power plants, battery storage, upgrades to existing transmission lines, and other grid-enhancing technologies. Colorado, Nevada, Washington, and South Carolina are examples of states that have adopted this approach.
- Using public finance and ownership to get projects built. Relying solely on private finance raises project costs (and therefore customer bills) and limits the types of projects that get built. Public finance and ownership can help fill the gaps and reduce costs. States and cities can move towards a variety of public utility models that champion clean energy. New York’s Build Public Renewables Act allows the state-owned power authority to build and own clean energy projects. Municipally owned utilities are not a new idea, but unlocking those public dollars for clean energy can help stabilize the investment landscape. But states don’t have to own the infrastructure to make a difference. They can also help finance projects. A 2025 California law, for instance, unlocked several new tools to use public finance to reduce the costs of new transmission projects.
- Empower regular people and small businesses to be part of the solutions. Community power – also known as distributed energy resources (DER) – can complement large-scale power plants to meet demand growth and lower bills. But households and businesses must overcome major hurdles to take advantage of small-scale solar, battery storage, and flexible appliances. In most places, utilities have not made it easy for customers to participate, as community power solutions do not align with their traditional business model. State leaders can change the status quo by creating mechanisms to compensate distributed resources for the value they bring to the grid, requiring utilities to procure a minimum amount of distributed clean energy, and making it easier to connect small-scale projects to the grid. For example, a 2024 Colorado law required the utility to create a mechanism to properly compensate customers for the grid benefits of distributed resources. And New Jersey Governor Sherill directed the PUC to take steps to make it easier to connect community power projects to the grid and allow new customers to register for community solar.
- Improve planning to attract more investment. Many regions with abundant clean energy resources simply do not have enough transmission capacity to deliver that power to population centers. As a result, developers are increasingly unable to move generation projects forward even when other barriers—like siting and permitting—are addressed. Outdated planning processes have led to inefficient decisions and dampened investment, which raises costs for customers and limits clean energy growth. States can address this issue by building out smart planning processes, working with PUCs, utilities, and other stakeholders to conduct integrated planning of new transmission lines and power plants to take advantage of low-cost clean energy resources. New Mexico, for example, created a new state entity to plan and finance transmission lines that can help move electricity from solar- and wind-rich parts of the state to population centers.
- Stop forcing customers to foot the whole bill for natural disasters and cyber attacks. Under the default utility ratemaking model, electricity bills include the costs of preparing for and recovering from disasters and cyber threats. In Western and Gulf Coast states, these costs have driven bills up fast. Disaster recovery is far more expensive than mitigation, so one way for states to take this on is to invest upfront in mitigation and resilience measures. States can increase scrutiny and analysis to ensure that utilities are focusing on the most economic mitigation and resilience measures, use public financing tools to reduce costs, and consider other approaches to paying for these investments outside of customer bills. A bill introduced in California last year, for instance, would shift wildfire recovery costs off of customers and onto fossil fuel companies.
Making Transportation Cleaner and Cheaper
People just want to get to where they’re going safely, efficiently, and affordably. Yet despite record levels of federal transportation spending, traffic, emissions, and pedestrian deaths keep rising. And as the Cato Institute observes, “U.S. policy contributes to an inefficient and costly transportation system that reduces workers’ time and incomes.”
We can do better. This starts by recognizing that in much of the United States, cars are both essential and increasingly unaffordable. There’s opportunity for a suite of policies that break market strangleholds while expanding consumer choice, moving us away from involuntary dependence on expensive cars and towards a future with transit that people actually want to ride – as well as affordable yet excellent, and often zero-emission, personal transportation. Core federal clean transportation programs have supported $4.6 billion in domestic investments and created at least 14,000 jobs in manufacturing, demonstrating the large-scale benefits of such programs and the economic case for continued federal support. Because the tools involved are nearly all within the authorities of state and local governments, and independent of ongoing federal regulatory disputes, they also can go into effect quickly.
On the vehicle side, this agenda includes governmental efforts to address legacy company market power. Incentives and protections for domestic manufacturing are sensible so long as they boost local economies, support American workers, and drive American innovation – but they’ve got to be coupled with policies ensuring price transparency and other oversight mechanisms, to ensure that benefits flow to consumers rather than pad company profits. Unlocking a more affordable, competitive, zero-emission vehicle (ZEV) market – with more options for buyers at lower prices – is also a key political foundation to the next round of vehicle regulatory mandates, by creating a larger constituency for further progress.
On the system side, states and cities can significantly build up regional budgets with savvy transportation investments. The data are clear that transit and walkability investments bring more valuable housing into cities and connect people with jobs, raising economic activity and raising property values. Investments in electric-vehicle charging similarly boost local business revenue and spurs economic vitality. Communities thrive when their members have transportation options (that all work well), instead of being steered towards legacy vehicle technology and wrestling with creaky 20th-century infrastructure.
On the vehicle side, transportation ingenuity could look like:
- Focusing on capital access to drive ZEV technology forward. Clean vehicles are now cheaper to run, in most cases, than fossil vehicles – a success of the initial wave of regulatory ZEV policy. But purchase prices remain high, making it difficult for many consumers and businesses to realize these long-term savings. The traditional way of solving this problem (incentive checks) runs hard into budget realities. The alternative is to focus ever more on lower-cost financial instruments, including loans, that can provide a return on investment and which can draw in private capital. Rather than writing grant checks, states can focus on de-risking ZEV finance, starting with state-backed loans for key consumer classes, and moving rapidly towards de-risking private loans (e.g., by guaranteeing the resale value of EVs – a far smaller investment than new-car subsidies). The goal should be to make a standard consumer or fleet loan for a ZEV as easy to secure as an internal combustion engine car loan is today. That possibility is on the horizon, and available for states that rapidly bring together financiers, consumer groups, and business interests to map out the financial products needed. Unlocking ZEV affordability is also a key foundation for the next round of regulatory progress, in states and at the federal level. States could implement a fee on retail deliveries—like Colorado has done—and put the revenue towards EV charging infrastructure or towards unlocking ZEV affordability. Like California is doing, states could consider an EV incentive program that requires participating OEMs to match state funds dollar-for-dollar.
- Stop legacy companies from jacking up prices. In addition to creating new capital flows, states need to make sure that investments translate into low prices. Especially in the heavy-duty truck and the bus sector, concentrated markets and non-public pricing have given manufacturers far too much power to keep prices high. One straightforward intervention is to use existing sales and pricing data held by state DMVs on every vehicle transaction to publish pricing information across vehicle markets, and then to task state market oversight bodies (including attorneys general) with addressing overconcentrated market power using antitrust and business law tools. State financing mechanisms can also be explicitly tied to lowering prices year over year, driving affordable vehicles into the market.
- Drive competition in the ZEV market. The ZEV market is a big one, and state support through economic development offices for new market entrants can drive down prices and boost options for consumers. States are well-positioned to support new companies – both in-state (as California did by creating Tesla a decade ago) and via working to onshore competitors, with adequate protections, from overseas. These companies can compete on price, onshore overseas companies that are making more affordable electric vehicles, or figure out ways to lower the costs of imports, to lower overall consumer costs and provide healthy competition to incumbent companies that are slow-walking incorporation of new vehicle technologies. Charging state business offices with clearing away red tape for new market entrants, while using convening powers to bring companies together with both public and private capital, is a powerful way forward.
- Normalizing ZEVs through visible MDV and HDV deployment. Expanding the number and diversity of zero-emission medium- and heavy- duty vehicles (MDVs and HDVs) on the road itself is a powerful adoption strategy. When the public regularly sees and interacts with ZEVs, they shift from being perceived as niche or experimental to practical, proven solutions. State leaders can drive this shift by prioritizing ZEV deployment in public, municipal, and contracted fleets like school buses, transit buses, garbage trucks, and last-mile delivery vehicles.
- Supporting secondary infrastructure. States have multiple tools to drive the charging infrastructure build-out. Continued federal funding, unlocked in part by state litigation, can be deployed along key corridors – but broader efforts by the states can accelerate infrastructure independent of federal support. Importantly, federal dollars remain available through NEVI, the Low- or No- Emission Vehicle (Lo-No Program), EPA’s Clean School Bus Program, and other initiatives, and states should move quickly to deploy these funds. Beyond direct funding, states can use their convening authority to coordinate construction and investment (or apply for investments) along key corridors, amending building codes to ensure chargers can be quickly added (especially to apartment buildings), easing permitting approval processes, and providing maps to transportation agencies and the public on locations of existing high-power electricity capacity for use in siting EV charging stations. States also have significant opportunities to design vehicle-to-grid electricity rate programs that leverage the benefits of charging to lower overall electricity rates and to store energy for when it is needed, providing major savings to both drivers and to the general public.
On the system side, transportation ingenuity could look like:
- Using transportation infrastructure to support goals in other sectors. With 48,000 miles of interstate highways and 140,000 miles of freight railroads, the United States has a vast network of transportation rights-of-way (ROWs) that can be leveraged for new infrastructure – such as high-speed EV charging infrastructure and long-distance electrical transmission – without the need for costly land acquisition or major structural change. States including New York and Wisconsin have already constructed several hundred miles of co-located transmission lines along highway/interstate corridors. Not far behind, states like Minnesota have conducted feasibility studies and are currently in the process of removing barriers to transmission construction in its publicly owned ROWs.
- Employing effective land use strategies. States have significant authority to dedicate both state and federal funds towards transportation, which can include bringing additional housing and transit to suburban areas. There is also a major opportunity to avoid ineffective investments in major new highway capacity, which almost always increases traffic congestion and is rarely the highest and best use of urban land.
- Using transportation funds to expand public revenue and public choice. Providing transportation choices – from transit to biking to safe sidewalks for kids – raises property values and quality of life. States can build these design principles into their transportation funding and planning processes. States can also go further by shifting funding to narrow or remove excess roadway capacity, or by swapping costly underused infrastructure for new housing and improved urban fabric (and hence greater public tax revenue that can then again be reinvested in communities). These financing models were once used to support excess highway construction, but now can be used to invest in transportation solutions that also address housing needs and budget crunches. Leaders at all levels can also expand eligibility for micromobility (e.g., walking, biking, and scooters) in federal transit grant programs.
- Improving planning processes. Transportation accounts for a large chunk of most state budgets. Conducting a close review of the existing project pipeline for state-funded transportation, in order to identify and prioritize projects that genuinely expand mobility choices and connect to broader regional and urban development goals, is therefore in state fiscal interests – and can have the happy consequence of also improving air quality and quality of life. Indeed, the California Air Resources Board has determined that the climate impacts of reducing car dependency are on the same scale as its world-leading vehicle electrification rules; meanwhile Minnesota and Colorado have both initiated audits to prioritize funding to reduce car dependency, with good early results. Because these alternate projects are generally much less expensive than major road construction projects, and more likely to raise overall property values, they are an exceptionally good approach for public officials looking to make climate progress.
Building Affordable, Abundant Housing
Housing shouldn’t be a luxury: it’s a prerequisite for a stable, healthy life. Yet Americans – facing prohibitively high (and increasing) rental costs as well as unrealistic down payments and pathways to ownership – are struggling to meet this basic need. And with extreme weather on the rise, renters and owners alike are facing concerns about physical safety and skyrocketing insurance as well as price hurdles. The emissions that the housing sector produces only worsen these problems.
Delivering more affordable, resilient, and climate-friendly housing means making it easier to build housing of all shapes and sizes; tailoring solutions to rural communities, urban communities, and different geographies generally; and striking a better balance between development for housing and development for other purposes. These strategies need to be paired with deep investments in government capacity to facilitate permitting and approval of new housing construction, as well as to facilitate more complex projects – like retrofits, infill development, and office-to-residential conversion – at scale. Also critical is reimagining community and stakeholder engagement on housing questions, aiming to maintain trust, democratic process, and local buy-in without overvaluing the perspectives of existing homeowners, developers, or any other particular constituency. at the expense of the rest of the community.
Housing ingenuity could look like:
- Reforming zoning to support more flexible and mixed-use buildings. Zoning makes sense when it stops a refinery from being built next to a playground. Zoning is a problem when it overprioritizes one kind of development, artificially limiting construction of diverse housing types. Policymakers can prioritize zoning and land use reforms to increase housing supply for a range of budgets and families. Policymakers have been working on creative zoning fixes for years: Houston led the way in reducing minimum lot sizes to encourage denser housing, while Minneapolis got rid of parking requirements, legalized accessory dwelling units (ADUs) to get more out of existing lots, and ended single-family zoning. These changes have helped stabilize rent prices, diversified housing mixes, and given more people an entry point into the housing market.
- Investing in infill housing. Infill developments can often be expensive, restricted by zoning, or face public opposition. Public leaders can get creative with solutions, such as by pre-identifying and providing data on infill development opportunities to help reduce costs for developers, or by reforming zoning laws to allow more flexibility in what type of development can fill in. Leaders can also facilitate retrofits and upgrades of existing buildings to convert those buildings to residential housing, which is effectively another type of infill strategy.
- Limiting incumbent interests. Large institutional investors like private equity firms can drive up rental costs and reduce housing supply when they purchase single-family homes as investment opportunities. State and federal policymakers can make these homes less appealing investments by introducing tax penalties, removing tax breaks, and encouraging firms to offload the homes they currently own over time, as proposed in recent legislation. This is a bipartisan issue: President Trump signed an executive order aiming to prevent firms from buying single-family homes outright; this directive was followed by a similar commitment by Governor Newsom.
- Streamlining permitting. Part of the housing supply issue is related to long permitting processes and high upfront development costs. The solutions are straightforward: invest in human talent and AI tools (in tandem with consistent AI governance and technical support) to clear permitting backlogs; provide limited, clear, and objective standards for rejecting permits; and create pre-approved plans to fast-track permitting of resilient, efficient homes. These actions will get homes on the market faster and cheaper, since every day a lot sits waiting for a permit increases development costs. Form-based zoning codes, for example, are designed around what the physical building form is rather than on what the building will be used for. These codes streamline review processes, but also help enable neighborhoods with good character and safe streets.
- Building safer and more resilient houses. Every year, one in ten homes in the United States are directly impacted by fires, floods, storms, and other types of extreme weather. As extreme weather increases, investments in home resilience are critical to keep people safe and long-term costs low. Policymakers can support safer and more intentional development in high-risk areas, with second-order benefits for energy access, reliability, and cost. Holistic approaches, like combined risk-reduction and pooled insurance “Housing Resilience Agencies” are the types of overhauls needed, but policymakers can also use tools like insurance premium reductions to lower the costs of roof improvements, like in Alabama. Other solutions target the community level, like using shared infrastructure and nature-based solutions to reduce risk for a group of homes.
- Simplifying building codes to allow for more flexibility and innovation. Building codes are responsible for ensuring consumer safety, but are often so complex and restrictive that they can drive up build times and increase construction costs. Policymakers can act to simplify codes without compromising safety by incorporating new research. Codes requiring buildings over three stories to have two staircases in the name of fire safety, for example, are more expensive and less space-efficient than single-stair buildings. Single-stair buildings that exist in much of the rest of the world are not necessarily less safe, and have cost benefits. States are starting to implement changes: Texas, Colorado, Montana, and New Hampshire all legalized single-stair buildings in some form in 2025.
- Stabilizing insurance markets. As extreme weather risks increase, home insurance providers are bumping up premiums and dropping policies for high-risk areas, leaving homeowners with few or no options for coverage. State policymakers can help keep consumers safe, limit additional costs, and improve transparency within the market. Colorado passed a law requiring providers to report on their risk assessment methods when using catastrophe risk models and to account for homeowner mitigation when setting rates. Other states, including Arkansas and Florida, expanded access to mitigation funds for homeowners.
- Supporting technologies that cut home energy costs. Housing policy offers an indirect yet effective way to bring down rising energy bills. For instance, “bring your own device” programs, such as those that have been deployed in Arizona and Vermont, enables homeowners to participate in virtual power plants using solar, batteries, and potentially energy-storing equipment like water heaters. States like Vermont have established on-bill financing programs for weatherization and efficiency upgrades, helping all Americans access the comfort benefits and long-term energy savings of these upgrades.
- Enabling more choices for homeowners. As families change, so do their housing needs. But there are often financial barriers to moving. Policymakers can design policies that allow for flexibility in different stages of life, like tax reforms to lower the barriers for moving into smaller homes. States can also offer tax credits for developers to build more accessible housing that’s more attractive to older homeowners, or implement policies (as in California) that allow older homeowners to maintain their property tax rate if they move into a similarly priced home. Giving people the capacity to live in places and housing types that fit their needs can reduce emissions from extended commutes and overbuilt homes.
- Lowering construction costs to increase supply. High development costs make it difficult to meet housing supply needs quickly. Modular housing, made up of standardized and interchangeable parts and assembled on site, can significantly reduce build times and construction costs – and those savings can ensure housing prices that work for more Americans. Modular homes can often be lower-emission and more energy efficient than traditional homes. Policymakers can direct funds specifically towards modular housing, or reform building codes to make it easier for modular housing to qualify (unlike manufactured housing, modular housing has to adhere to state and local building codes).
Making Solutions Stick: The Cross-Cutting Benefits of Government Capacity, Pro-Democracy Design, and Innovative Financing
Each of the policy solutions above offers a way to boost climate progress while delivering everyday benefits across energy, transportation, and/or housing. But how do we make those solutions stick? With trust in government at historic lows, public-sector leaders must quickly follow ambition with action, investing in both ideas and the building blocks that turn ideas into reality. Below, we outline how public leaders can use three of these core building blocks – government capacity, financing, and pro-democracy design – to get on the scoreboard early…and stay there for the long term.
Government Capacity
Government capacity refers to the ability of government to get things done, whether through efficient processes, effective talent, or fit-for-purpose tools. Americans are frustrated by the slow pace of government, but they don’t want the functions that keep them safe and supported dismantled: they want them improved. Accomplishing this requires more than new programs or new funding streams or new inventions. It requires leaders to seriously (and systematically – not via a “wrecking ball” approach) consider which government functions are working, which need to be overhauled, and which should be retired.
Rebuilding government capacity is inseparable from strengthening democracy itself. Both of these goals are wholly intertwined with climate progress. When government acts competently, transparently, and in partnership across levels, it restores public faith that collective action is possible and worthwhile. When it can’t, even well-designed policies stall under the weight of fragmented authority, procedural burden, risk aversion, and institutional inertia. Treating government capacity as a core investment is therefore much more than administrative housekeeping. It’s a prerequisite for durable climate progress.
To boost government capacity, public leaders can:
- Align on policy outcomes, owners, and indicators. Governments should establish collective, ambitious, and executable goals, not just agency outputs; clear and cross-cutting responsibility, not siloed authority, and collective signals that show when things are getting off track or are moving to success. These shouldn’t be one-off reporting exercises, but valued north stars with relentless attention. And to enable shared outcomes, owners, and indicators, public sector leaders need to consider the full “map” of the climate-oriented transition they are aiming for: how the various puzzle pieces of planning, utilities, transit, infrastructure and more will sequence logically and in resourcing; how tactical actions that are possible now intersect with ambitious long-term planning; how to mitigate barriers in advance of key inflection points; and how to storytell what may be a long transition to residents.
- Shore up linchpin talent. Government delivery often fails at the human bottleneck. No program, however brilliant, will work if it’s not adequately staffed with the people needed to run it. Emphasis on talent growth, talent sharing, and talent strategy can be game-changing for governments if undertaken at the front end, such as:
- Empowering “machinery” expertise. Functional roles like procurement officers, finance specialists, engineers, and lawyers, are the engines of the government capacity needed to drive climate action. Instead of treating people in these roles as workhorses, jurisdictions can treat them as strategic enablers, giving them time, authority, and political cover to redesign how work gets done.
- Sourcing technical talent creatively. Leaders can think outside the box when it comes to talent for high-impact roles and roles that involve specialized, high-demand technical expertise. For instance, leaders can establish shared services and shared delivery teams that enable individuals to contribute across internal departments, or regional implementation offices that support multiple jurisdictions at once. Leaders can also explore pathways to bring in fellows and detailees from external organizations for short-term tours of service.
- Upskilling current workforces. With significant evolutions in technology, funding, and collaboration coming every year, public sector entities can’t pursue new hires every time something new emerges. Investing space, patience, and resources into upskilling current workers and setting a culture where collaborative learning is the norm will pay off far more than relying on expensive consultants.
- Investing in delivery and relational capacity. Understanding local context is a technical skill like any other, and when regional partners trust each other, decisions accelerate. Federal leaders can build regional roles and teams, and invest in intergovernmental capacity for working with states and localities on implementation, not just convening.
- Establish “safe-to-experiment” parameters and expectations. Creating safe-to-experiment space is less about changing statutes and more about leadership setting expectations and guardrails, as well as working collaboratively to shift from risk minimization to risk management. Leaders can consider:
- Testing regulatory sandboxes. A regulatory sandbox is a mechanism that provides a structured environment for testing new technologies and business approaches under modified rules to increase the speed of adoption. The goal of sandboxes is to test, learn, and collect data, not strive for immediate perfection. Once an approach is proven promising, pilots can be set up to be scaled rapidly. In 2023, for instance, the Connecticut Public Utilities Commission established a regulatory sandbox called the Innovative Energy Solutions (IES) Program to pilot innovative technologies to expand its electric grid.
- Collaborating on pathways to scaling. Before beginning an experiment, those involved should collaborate to create milestones and criteria for discontinuing unsuccessful experiments, as well as a clear transition and ownership path for working experiments to get to the next level.
- Using proactive messaging. Leaders should be clear with public sector workforce, media, advocacy, and oversight communities when the objective of a policy experiment is to learn. Such messaging should also emphasize that while successes are valuable outcomes, so too are well-understood setbacks.
- Use collective-action tools. Ambitious policy decisions are often inaccessible for cities, states, and even federal agencies acting alone because of limited capacity, procurement constraints, and fear of litigation from incumbent interests. Collective-action tools let local and state governments pool risk and resources, smoothing out the cost and bumpiness of transitions while helping governments deliver more together, including:
- Coordinated and reinforcing public funding instruments: Government institutions have a range of market shaping tools available to them to facilitate climate innovations, whether demand side (procurement, advanced market commitments) or supply side (grantmaking, loan guarantees). In a resource-limited environment, public sector organizations can work together to share insights and risk, to balance across the stages of innovation they want to drive to (higher risky experiments? near term performance criteria? sustainable supply?), and align the timeline and ROI of their policy levers in order to shape access to the capabilities they need. That might include:
- Pooled procurement. Joint Powers Authorities are agreements or entities created between multiple public-sector organizations to collectively deliver services or exercise authorities. JPAs or lead entity models can aggregate buying power for emerging tech and new clean energy capabilities. JPAs in California have been used to aggregate procurement for clean energy, insurance, and shared services. Standardizing technical specifications for transit procurements across transit districts can similarly help drive down transit costs.
- Build a shared information base: Rebuild the environmental data backbone at the state/local level, including working to preserve and sustain current environmental resources; over time, expand interoperable data collection and make it genuinely usable to support consistent, evidence based state and local action.
- Pooled legal funds. Public sector entities can establish or engage with agile pooled legal funds addressing legal and regulatory barriers that block climate innovations and getting access to specialized regulatory and litigation expertise that would be cost-prohibitive to maintain in-house.
- Reciprocity. States and municipalities can invest in shared permitting, licensing or certification schemes in areas enabling climate action. If a green tech design or contractor is authorized in one jurisdiction, reciprocity would ensure that their eligibility extends to others, helping enable a common market and reducing the burden needed to obtain duplicative certifications.
- Coordination across technical assistance resources. Many TA resources for state and local implementers exist for the multiple phases of clean energy projects. But they tend to be siloed, and few usable maps exist for resource and time-strapped state and local entities to take advantage of.
- Coordinated and reinforcing public funding instruments: Government institutions have a range of market shaping tools available to them to facilitate climate innovations, whether demand side (procurement, advanced market commitments) or supply side (grantmaking, loan guarantees). In a resource-limited environment, public sector organizations can work together to share insights and risk, to balance across the stages of innovation they want to drive to (higher risky experiments? near term performance criteria? sustainable supply?), and align the timeline and ROI of their policy levers in order to shape access to the capabilities they need. That might include:
- Design processes and feedback loops for outcomes, not box-checking. There’s significant value in government consistency and legibility in decision-making, but maximal interpretation of rules for rules sake serves no one. Government agencies should make a regular practice of assessing frustrating process flows for accumulated “kludge,” duplication, and poor user experience (grantmaking and permitting are obvious targets). At the same time, agencies should upgrade how performance measures serve as feedback loops throughout complex processes: are metrics telling you what you need to know about performance when you need it to take action, or months after the fact?
- Design for (sustainable) decisions. Government processes are often over-engineered, lacking clear guidelines for who is ultimately in charge of making a decision. To speed up permitting, deployment, rulemaking, and community engagement, governments should:
- Clarify authority. Speed requires empowering specific decision-makers with cover to say yes, authority to change course, and will to stop a failing experiment.
- Enable collaboration, not duplication. A well designed cross-functional team breaks down silos and acts with fluidity, agility, and overcommunicating focus–not doubling up meetings or reporting, not relying on standalone dashboards, and overcommunicating. Teams can be oriented around common outcome goals rather than teams grouped by administrative departments.
- Build transition resilience. Invest in transition planning across administrations for key initiatives – especially when there are shifts in political ideology.
- Deliver excellent frontline services. Particularly at the state and local level, the front lines of climate action are in day-to-day public services that can get slowed by burdensome processes. Agencies can apply journey-mapping techniques, already used in benefits delivery and permitting reform, to climate-facing services like interconnection approvals or home retrofit permits. Such techniques identify slow-downs and places where residents drop out from frustration.
- Engage the private sector as a partner and source of capacity. Governments can harness external capacity (without giving up oversight) by shifting how responsibility is allocated while remaining clear on outcomes, enforcement, and accountability. Examples of this sort of approach might include adopting self-certification options when strong third-party verification is feasible; using market discipline to reinforce public outcomes, engaging insurers, reinsurers, and lenders to incent safer construction, resilient infrastructure, and better operational practices; or leveraging credible existing private standards instead of reinventing compliance regimes.
Finance
Capital is a powerful tool for policymakers and others working in the public interest to shape the forward course of the economy in a fair and effective way. Very often, the capital needed to achieve major societal goals comes from a blend of sources; this is certainly true with respect to climate action and facilitating the transition to clean technologies.
States, cities, banks, community-driven financial institutions (CDFIs), impact investors, and philanthropies have long worked in partnership with the federal government on clean-technology projects – and are stepping up in a new way now that federal support for such projects has been scaled back. These entities are developing bond-backed financing, joint procurement schemes, and revolving loan funds – not just to fill gaps, but to reimagine what the clean technology economy can look like.
In the near term, opportunities for subnational investments are ripe because the now partially paused boom in potential firms and projects generated by recent U.S. industrial policy has generated a rich set of already underwritten, due-diligenced projects for re-investment. In the longer term, the success of redesigned regulatory approaches will almost certainly depend on creating profitable firms that can carry forward the clean-technology transition. Public sector leaders can assume an entrepreneurial role in ensuring these new entities, to the degree they benefit from public support, advance the public interest: connecting economic growth to shared prosperity.
To be sure, subnational actors generally cannot fund at the scale of the federal government. But they can have a truly catalytic impact on financing availability and capital flows nevertheless.
To boost finance, public leaders can:
- Combine financing and procurement policy. As electrification reaches individual communities and smaller businesses, many face capital-access problems. Subnational actors should consider packaging similar businesses together to provide financing for multiple projects at once. Leaders can also consider complementary public procurement policies to pull forward market demand for projects and products. For instance, grant programs can preference applications that utilize joint procurement, thereby helping public grant dollars go further. This strategy was previously employed in the Federal Transit Agency’s Low or No Emission Grant Program for clean buses.
- Blend public and private capacities. Dollars go further and the funding landscape is easier to navigate when public and private funders work together. Public and private entities can join forces around flexible finance mechanisms (e.g., bond-backed financing, rapid permitting pilot zones, and revolving loan funds) needed to push projects “over the finish line”, particularly in high-demand power markets. One compelling example is the Connecticut Green Bank, which has successfully blended public and private capital to deploy over $2 billion in clean energy investments since its founding. States can similarly support programs like the Municipal Infrastructure Fund (MIF), facilitated by ICLEI USA and the Coalition for Green Capital (CGC), to provide seed grants to local communities for market building and development of clean energy project pipelines. Groups like CGC also develop loan products specifically targeted at municipal energy infrastructure projects that can help cities access larger investment tools.
- Provide project certainty. Uncertainty around federal policy and the likelihood of project completion is constraining available finance as well as increasing costs for both project developers and involved counterparties (e.g., those helping finance a project by purchasing its tax credits). Though the public sector has a key role to play in reducing uncertainty, an emerging strategy for living with uncertainty is the formation of “coalitions of the credible”: i.e., “governments, industrial firms, and financiers who are capable of showing sustained, coordinated commitment to building clean energy systems despite global [and national] discord.” State and local leaders can help kick-start these coalitions.
- Help smaller developers and investors access needed components. Despite optimistic growth prospects, shrinking profit margins and tighter financing conditions in the near term are making it harder for smaller and less liquid developers and community financial institutions to remain solvent. Industry concentration could lead to less innovation and higher prices in the long term. State energy financing institutions can create warehouses to buy key clean-technology components in bulk and then resell these components to smaller developers and investors. As the Center for Public Enterprise observes, “these cooperative purchasing structures are already how some states in the Northeast procure heating oil and fuels, and how Climate United intended to mobilize investment into electric trucks for independent drivers working at the Port of Long Beach.”
- Leverage the power of information. Deep, shared, information architectures and clarity on policy goals are key for institutional investors and patient capital. Shared information on costs, barriers, and rates of return would substantially help facilitate the clean technology transition. Simple RFIs targeted at businesses and developers can function as dual-purpose information-gathering and outreach tools for these investors. By asking basic questions through these RFIs (which can be as short as a page!), investors can build the knowledge base for shaping their clean technology and energy plans while simultaneously drawing more potential participants into their investment networks.
- Tapping into new markets. As demand for electricity increases, new markets and business models are opening in the clean economy. General Motors and Redwood Materials, for instance, joined forces to use surplus and used EV batteries to help power data centers and other hyperscalers. There is a surprising but potent opportunity to market and finance clean energy and grid upgrades as a national security imperative, in response to the growing threat of foreign cyberattacks that are exploiting “seams” in fragile legacy energy systems. And as climate-linked disasters grow, so has the market for adaptation and resilience solutions, including many that reduce emissions as a co-benefit. Public leaders can work with the private sector to identify and support these types of innovative strategies, including by working with existing economic development agencies, chambers of commerce, accelerators, and other components in the innovation ecosystem.
- Keep eyes on the long-term prize. Investing with a short-term mindset can hobble state economic strategy before it gets started; moreover, many clean technology projects may have higher upfront costs balanced by long-term savings. States can set themselves up for long-term gains by:
- Helping firms stand on their own. States should design incentive programs with an eye for long-term business growth. States can focus, for instance, on incentives that intentionally partner well with other financing tools, thereby attracting new industries and market players to make durable investments. State strategies outlining multi-year economic plans (such as the one that New Mexico has published) can help businesses develop workable investment and growth strategies.
- Taking active equity stakes. Debt equity, provided through revolving loan funds, can play a large role in accelerating deployment of clean technologies by buying down entry costs and paying back the public investor over time. Moreover, the superior bond ratings of state institutions substantially reduce borrowing costs; sharing these benefits is an important role for public finance. State financial institutions can explore taking equity stakes in some projects they fund that provide substantial public benefits (e.g., mega-charging stations, large-scale battery storage, etc.) and securing an attractive long-term rate of return over time in exchange for buying down upfront risk.
- Adopting portfolio approaches. Diversified subnational institutions can use cash flows from higher-return portions of their portfolios to de-risk lower-return or higher-risk projects that are ultimately in the public interest. States with operating carbon market programs can consider expanding their funding abilities by bonding against some portion of carbon market revenues, converting immediate returns to long-term collateral for the green economy.
Public Participation
Public participation in climate action is often treated as a procedural requirement to be satisfied late in the process, rather than as a core function of governing well. The result is familiar: performative town halls, notice-and-comment processes that invite frustration rather than insight, and transparency tools that are easily weaponized by organized interests. This dynamic erodes trust, slows projects, and fuels the perception that government is both unresponsive and incapable. Yet participation, when designed well and tailored to the moment, is not an obstacle to effective governance: it is how government discovers what will work, where friction will arise, and how to build solutions that communities will defend rather than resist. Treating participation as a functional component of state capacity means seeing it as an input to smarter design, faster implementation, and more durable outcomes.
Upgrading how government listens and engages is vital to upgrading how government delivers. When residents see clearly how their input shapes decisions, participation builds legitimacy and reduces the incentives for obstruction and litigation later in the process. When agencies invest in the infrastructure, tools, roles, and expectations that make participation meaningful, they create a feedback loop that improves policy design and strengthens democratic trust at the same time. And when climate leaders meet the public where they are in terms of how they experience and make consumer choices in the the climate transition, we can strengthen the connective tissue between government action and public trust.The recommendations below are aimed at helping public leaders move beyond compliance-driven engagement toward participation models that are relational, deliberative, and integrated into the machinery of experience and delivery. This approach ensures that climate solutions are not only technically sound, but socially resilient and democratically grounded. These take time, but we encourage recognition that they enable enormous time, risk and failure saved.
To boost public participation, public leaders can:
- Invest in government participation capacity: Engagement fails when it is treated as a public-affairs sideline. To be effective, it must be integrated into the agency’s internal machinery and the community’s external ability to show up. There is no one size fits all toolkit for engagement, and the scope of the topic defines the method, energy, and limits.
- Know the stakeholders: Leaders should have the expectation that program leads know the full set of impacted (near term and long term) stakeholders in their policy area and have early and iterative engagement with them. Likewise, leaders should know, cultivate, and rely on trusted messengers in key communities.
- Have a plan for engagement: Define the purpose, scope, and timeline of participation at the outset of an intervention or change, including how it does and does not shape decisions. When residents see a clear path for their influence and co-design (and staff see it as a core function) it’s easier to become vested stakeholders in a project’s success.
- Participation training and roles for staff: Community engagement, facilitation, listening, and conflict transformation are technical skills that agencies can invest in across the span of a project team, in addition to relational roles.
- Recognize the full range of impacts: Every policy has near and long term winners and losers, and these voices may be unintentionally elevated or muted in design. Leaders should incentivize their staff to recognize and validate that full set of impacts, bring in communities early to understand parameters and co-design solutions, be clear about intentions to weigh or mitigate, and be direct about decision ownership.
- Leadership cover: Leadership needs to set the expectation that surfacing weak signals of concern early is a success, not a failure. Providing political cover for staff to iterate based on early feedback prevents catastrophic delays later in the cycle, as does enabling staff to move to the next phase with informed decisions.
- Feedback loop accountability: Proactively message to the public how community input changes project design or outcomes. People stop engaging when they feel unheard and demonstrating that participation matters build investment in long term success (even if not wholly in line with their feedback).
- Upgrade listening tools: Traditional feedback mechanism (like notice-and-comment) are often overengineered for compliance and late stage. Government agencies should prioritize investing in their listening plumbing.
- Experiment with deliberative models: Move beyond one-way listening sessions toward deliberative democracy models, which have some great pilots in California. These allow residents to grapple with real-world trade-offs (e.g., local land use vs. regional grid stability) alongside experts, leading to more durable mandates that are less vulnerable to litigation.
- Listening at scale tools: Investigate and invest in tools and methods that make taking the pulse of a broad or targeted community possible. Find opportunities where the people are (Reddit? Community Centers? ) rather than expecting them to navigate a govt.exe portal. Utilize tools that lower barriers to entry and analysis, like SMS-based surveys, AI-assisted triage for public comments, and digital town halls.
- User experience toolkits: Agencies should invest in user experience tools to understand how a particular proposal, innovation, or ecosystem works and feels from an immersive resident standpoint. Small tweaks may be barriers that prevent adoption.
- Invest in how people experience and adopt the solutions government is trying to deploy. The clean-energy transition is not implemented solely through permits and public meetings: It is implemented through millions of household decisions about heating systems, vehicles, appliances, and power sources. Too much of the climate movement’s engagement strategy still treats Americans primarily as political constituents to persuade. People are far more likely to embrace clean-energy solutions when they see how those choices improve their daily lives. To strengthen consumer-centered climate engagement, public leaders can:
- Broaden from policy messaging to benefit messaging: Frame clean-energy programs around concrete improvements people care about (like comfort, savings, reliability, and service quality) rather than abstract climate goals or technical policy descriptions.
- Invest in understanding residents as consumers: Use market research, behavioral insights, and segmentation to understand what different communities value, what barriers they face, and what motivates action.
- Elevate trusted messengers: Partner with the people residents already rely on for advice about their homes and services (like neighbors, contractors, utilities, tradespeople, and community organizations) rather than relying solely on government spokespeople.
- Meet people where decisions happen: Integrate or encourage outreach into the places and moments where people make choices: point-of-sale materials, contractor visits, utility communications, home-improvement stores, and neighborhood groups.
- Use social modeling and peer effects: Highlight visible examples of adoption within communities and create opportunities for residents to learn from one another through open houses, neighborhood pilots, and group demonstrations.
- Remove friction through group and guided programs: Support group purchasing models, concierge-style assistance, and personalized coaching that simplify complex decisions and reduce perceived risk.
- Align infrastructure investments with visible benefits: Use the reality of extreme weather and infrastructure upgrades as opportunities to demonstrate how clean-energy improvements strengthen local resilience and service reliability.
- Build the infrastructure for community trust. Effective engagement is not a one-off transaction, it is a relational investment. Because governments often lack the time and personnel for deep localized work, they must build the connective tissue between agencies and the ground, and several models exist to work from:
- Community navigator hubs: To make existing capacity go further, governments can work with civil society and community organizations to leverage non-governmental talent through initiatives like community navigator programs, that use local and state-level expertise to guide policy design and implementation and combine it with government technical assistance – in the process creating public buy-in and trust of a policy. It’s worth it to set up these programs in advance, as it can reduce opposition later on and help design future policies that are better suited for the communities they’re for.
- Community capacity support for participation: Recognize that participation has a cost. While some agencies are able to support compensation models for community participants for their time, there are other ways to reduce the burden of participation, whether scheduling flexibly, providing childcare or transport, offering translation, or simply using plain language rather than technical jargon.
- Implementer partnerships: Work on lowering barriers between the public and program implementers in the private sector, bringing them together early to align on community benefits agreements early.
About The Primer
Ambition to Action was authored by Angela Barranco, Zoë Brouns, Megan Husted, Kristi Kimball, Arjun Krishnaswami, Hannah Safford, Loren Schulman, Craig Segall, and Addy Smith.
Many individuals contributed ideas and input to this primer. The authors are grateful to the following individuals and organizations for their time, expertise, and constructive feedback: Patrick Bigger, Laurel Blatchford, Heather Clark, Ted Fertik, Danielle Gagne, Kate Gordon, Betony Jones, Nuin-Tara Key, Alex McDonough, Sara Meyers, Shara Mohtadi, Saharnaz Mirzazad, Beth Osborne, Alexis Pelosi, Sam Ricketts, Bridget Sanderson, Lotte Schlegel, Igor Tregub, Louise White, and Clinton Britt. The content of this primer does not necessarily reflect the views of individuals or organizations acknowledged. Any errors are the sole fault of the authors.
To scale up climate solutions, local governments need to accelerate system changes
When I ran for city council in Boulder, Colorado in 2023, everyone talked about climate change. Forum after forum, all ten candidates spoke up for the climate.
And cities saying climate change matters is typical. The number of US cities with adopted climate action plans is in the hundreds.
That’s what we need, since cities drive the bulk of greenhouse gas emissions and are on the front lines of climate havoc.
More specifically, for large-scale climate solutions to work, cities have to really stretch. That’s according to the Intergovernmental Panel on Climate Change (IPCC), which says cities need to rapidly become compact, efficient, electrified, and nature‑rich urban ecosystems where we take better care of each other and avoid locking in more sprawl and fossil‑fuel dependence.
Yet, big-picture progress in the United States is critically insufficient. Those are the words of Climate Action Tracker, an independent scientific analysis evaluating climate commitments. The US has pledged to reduce 2030 GHG emissions levels by 50–52% below 2005, yet the latest projections show we are on track to achieve at best only 29–39%—assuming no further backsliding.
And earlier this month, the Trump administration withdrew our federal government from the international climate agreement process.
So when local governments say “we’re on it,” what is a concerned citizen to think?
What local government climate solutions look like
Climate advocates are used to talking about climate action. But for local governments, the measuring stick for climate progress isn’t simply action. What counts is measurable progress towards specific, substantive transitions.
Transitions to walkable, compact neighborhoods where abundant, space-efficient middle housing near jobs and services let most residents meet daily needs within a short walk or bike ride, reducing trip lengths and housing and transport costs.
To transit-rich, highly bikeable towns where frequent, accessible service and a connected, protected network allow seniors and youth travel independently and where per-capita car dependence falls.
To fully-electrified communities in which homes and transportation run on clean, distributed power, working efficiently, that delivers lower bills, healthier indoor air, and outage resilience, with benefits accruing equitably to residents.
To enhanced landscapes of bioswales, permeable streets, restored wetlands, and drought- and fire-resilient shade trees that cool neighborhoods, absorb stormwater, and buffer heat, flood, and smoke risks.
To resilient local food systems that blend urban agriculture with regional producers, food hubs, cold storage, and compost-to-soil loops to deliver reliable, affordable, nutritious food even during heat, drought, or supply disruptions.
There is good news: The transitions we need, and the solutions and capacity we need to implement them, are showing new signs of life. That’s evident in two trends.
One trend is local governments playing a bigger role in climate solutions. The number of U.S. cities reporting to the CDP, a global system for disclosing climate progress, has grown to over 150. Now more than 200 US cities have committed to 100 percent clean electricity. And cities’ climate action plans are showing a visible shift from a focus on municipal operations to community‑wide impacts of buildings, transportation, and waste, and more sophisticated thinking about resilience.
As the federal government has retreated, advocates are increasingly realizing cities and counties have tools to lead. Local governments manage streets, land use, buildings, public fleets, transit, and major service contracts. They can strongly influence state-level actors, like energy utilities and air quality programs, and be providers of those services directly.
There is proof of this awakening in the large numbers of people suddenly running for local office on climate. Political organizing coalitions such as Run on Climate and Climate Cabinet helped elect more than 50 local leaders running on climate in 2025. One of the year’s most high-profile candidates, Zohran Mamdani, won with “fast and free” buses–one of the measures IPCC has highlighted as a meaningful mitigation measure that saves more money than it costs–as a centerpiece of his campaign.
The other trend is a greater focus on wellbeing. Research included in the latest IPCC report shows demand-side measures can cut end-use emissions by roughly 40 to 70 percent by 2050 while improving daily life and making communities stronger. And wellbeing is the currency of local governments and local politics. Concrete quality of life issues dominate local elections and policymaking, which is where climate action takes root—or doesn’t.
Climate action prompted by a desire for healthier, happier, and less expensive lives is happening. People are adopting electric cars, e-bikes, heat pumps, and induction stoves because they work better, are cheaper to operate, and healthier. The intersection of climate solutions and wellbeing is central to a 2025 bestseller Abundance and to the national conversation it kicked off about defining and achieving “abundance.” The topic of wellbeing was a bright spot at the COP30 climate talks via the World Health Organization’s report, “Delivering the Belém Health Action Plan.”
These two trends reinforce each other. Local governments oversee the services where wellbeing, decarbonization, and resilience meet. When those services are designed as a system, investments can compound to create more value for more people, who then have a stake in continuing the transition. And the importance of rallying around local governments to carry climate solutions forward is becoming clearer as U.S. national policy looks structurally less reliable than most experts used to think.
Difficult conditions for change
But local governments face headwinds. Existing policies and markets, like those that have created widespread car dependence and extensive natural gas systems, create momentum that favors the status quo and encourages continued investments that lock us in further. Simply put, it’s easiest to keep doing it the way we’ve done it before, and then we dig ourselves in deeper.
Local governments purposefully design systems to keep things stable. Most likely, whatever your town or county is doing is based on the direction of long-term plans, from departmental plans to bigger comprehensive plans. Those plans often come up for renewal only every few years or longer, and if you miss that window or fail to follow procedures, making big change is nearly impossible. Related, local governments tend to have policies and practices for conducting community engagement that deliberately create a high bar for making major turns.
On top of all that, local governments in the U.S. are suffering a long-term decline in investment that leaves them with significant and growing cash flow constraints, heavy workloads, limited time to deliberate, and pressure to deliver. The pandemic and recent national political forces reduce their maneuverability even more.
Political will necessary but not sufficient—concrete transitions are needed
In order to drive climate transitions under such tough conditions, political will is necessary but it is not sufficient. For local governments to scale up climate solutions, they need to take tangible, visible steps to change systems, consistent with evidence-based recommendations, outlined by institutions like the IPCC.
Here is what that can look like – and what advocates can look to encourage:
1. Transition plans
Climate issues touch everything, so all local governments can point to doing climate things. But the difference between lists of activities and high-reward strategic commitments that make good use of time is everything. The latter requires a clear plan to make transitions happen, with defined outcomes and milestones, and dogged pursuit.
Ambitious climate action at the local government level means being clear about the transition(s) the community is focused on, which could include the previously mentioned examples, along with what successful completions looks like and by when. This involves working on at least two tracks concurrently—both integrating ambitious transformations into long-term planning exercises, for which adopting changes may or may not be available right away, and taking whatever more tactical action is possible now to support such planning and concrete action to the fullest extent possible.
- Transition plans might consider: What needs to be different? Who are the elected officials and partners needed to make the transition work? What barriers could inhibit progress, and what is the strategy for overcoming them? What are the key inflection points in behavior adoption, and what is the change model to reach them?
2. User experience
Cities often add a bike lane in one place or restore a bus line in another. What truly changes behavior is a complete experience that makes the pro-climate option the intuitive choice. Kids can bike around town without parents fearing they could be hit by a driver. You can count on bringing a large electric bike anywhere and park it safely. Buses are within a 10-minute walk of home and arrive every 10 minutes. Utility investments in electrification actually lower monthly bills. To make climate transitions attractive and sticky, we have to confront gaps that get in the way of people’s experience from their vantage point.
A practical opportunity for local governments is to use the tools of user experience (“UX”) and be responsible for how the ecosystem works and feels from the immersive standpoint of users. UX is an interdisciplinary field that uses research, psychology, and design to remove friction and ensure a seamless journey for users.
- Some questions for managing the user experience: Who is/are the transition(s) for—who are the “users” involved that will experience change? What do they need to do and stick with to make the transition work? What performance measures are needed to constitute progress, and how do we get elected officials and executives to care about them? Where are there persistent, hard-to-reach gaps that can be spotlighted as “known issues” for partners and other jurisdictions to see and possibly be helpful with? What are the gaps between our intent and reality, and how can we overcome them?
3. Public service delivery
One of the core jobs of local government is to provide public services like zoning, safe transportation, building standards, air quality protections, and emergency management. Providing services is also generally the justification for spending public money. And services are where the planning activities that local governments tend to be so careful about materialize in the real world. So if local governments are going to be engines of climate action, then day-to-day service delivery—their core product—is where most of that action will show up. Climate action will appear in what gets approved, funded, built, maintained, enforced, measured, and improved.
Local governments already deliver public services. So the opportunity is to evaluate how core local government services can or should be tuned and/or reorganized to drive climate and resilience outcomes. This includes formal adoption in comprehensive plans, capital improvement programs, and strategic plans, and clear alignment with budget priorities. When leaders routinely report on progress and adjust course publicly, it signals that climate transitions are a core organizational responsibility rather than a side project.
- An evaluation of services might consider: How is climate action aligned with where money is actually spent? What changes in standards, contracts, and operations are needed to lock in better outcomes? How can the thinking and tools of service development improve user experiences?
4. High-level ownership
Plans only come to life when people who have the right level of power and accountability own delivery. Inside local government, that means both the elected body (mayor, city council, and/or their equivalents) and executives (city manager, their deputies, and in the case of a “strong mayor” form of government, the mayor) adopt the initiative as their own. Roles and accountability are defined and gaps are addressed. Resources are allocated through direct investments and through partnerships that expand capacity.
High-level ownership of climate solutions in local government happens when transitions are included in the agency’s highest-level plans and strategies.This includes formal adoption in comprehensive plans, capital improvement programs, and strategic plans, and clear alignment with budget priorities. It also looks like leaders routinely communicating to the public about the transitions under way, the progress against them, and how community members can help support the journey.
- Some ways to gauge high level ownership: Do staffing, partnerships, procurement, budgets, and intergovernmental advocacy support transition intent? Is change management happening as needed, with a clear vision and ongoing communication expressed to the public? Is the work of transitions integrated into core functions and the day-to-day responsibilities of staff necessary for success? How are electeds supporting and leading?
5. Playbook of procedures
Local government commitments are heavily shaped and constrained by procedure, like protocols for what gets a hearing and when, annual or biennial work plans, and comprehensive plans that may come around only every few years or longer. Communications between elected officials and staff may be limited by city ordinance, and communications among elected officials may be very limited by state law. There are also often arcane, highly-localized meeting customs. Getting things done requires working through these procedures and often landing decisions in small windows that are easy to miss.
A playbook for how climate transitions are going to make their way into staff proposals, planning processes,and budgeting is fundamental to turning a good idea into something real. Such a playbook is needed to spell out who does what, when, and through which formal channels, so that key decisions do not depend on heroic one-off efforts. It also helps new staff and elected officials quickly understand how to use existing procedures to advance climate goals, rather than be derailed by them.
- Some questions to ask: What are the relevant scheduled planning processes and upcoming meetings, and who is required to fully elevate the work there and how? What learning systems or listening structures exist, and how are they being used to surface discrepancies and continuously drive improvement?
Conclusion
To scale up climate solutions through local government, we need at least two things. First, political will, which is familiar to most advocates. Looking into 2026 and beyond, climate advocates have great opportunities to continue increasing the proportions of elected local bodies who are led by politicians serious about climate solutions. Everyone has a role to play: run for local office, support local climate candidates, use whatever powers of creativity and persuasion you have–from writing to speaking to organizing and beyond–to help make climate action a core election issue in your community.
The second—and where we need greater shared focus—is to make local governments responsible for specific, strategic commitments to systems change. To do that, help build transition plans that commit to providing great user experiences, an approach to public service delivery that is aligned with those objectives, ownership by city council and the city manager or mayor, and a clear playbook for how strategic climate commitments are going to be adopted and rolled out.
Not everything is going right for the climate movement. But there are some fantastic bright spots, and one of those is big new local government innovations that are starting to unfold.
Looking into 2026, I’m excited to be a part of the movement to help local governments drive the next generation of climate progress. And a big hat tip to FAS with its regulatory rethink and government capacity work as well as ICLEI USA, both partnering with local officials like me to map out how cities can translate ambitious climate goals into durable systems change.
There are great things ahead, and so much room to work together.