As temperatures rise, the strain on energy infrastructure escalates, creating vulnerabilities for the efficiency of energy generation, grid transmission, and home cooling, which have significant impacts on businesses, households, and critical services. Without action, energy systems will face growing instability, infrastructure failures will persist, and utility burdens will increase. The combined effects of extreme heat cost our nation over $162 billion in 2024 – equivalent to nearly 1% of the U.S. GDP. 

The federal government needs to prepare energy systems and the built environment through strategic investments in energy infrastructure — across energy generation, transmission, and use. Doing so includes ensuring electric grids are prepared for extreme heat by establishing an interagency HeatSmart Grids Initiative to assess the risk of energy system failures during extreme heat and the necessary emergency responses. Congress should retain and expand home energy rebates, tax credits, and the Weatherization Assistance Program (WAP) to enable deep retrofits that prepare homes against power outages and cut cooling costs, along with extending the National Initiative to Advance Building Codes (NIABC) to accelerate state and local adoption of code language for extreme heat adaptation.  

Challenge & Opportunity: Grid Security

Extreme Heat Reduces Energy Generation and Transmission Efficiency

During a heatwave, the energy grid faces not only surges in demand but also decreased energy production and reduced transmission efficiency. For instance, turbines can become up to 25% less efficient in high temperatures. Other energy sources are also impacted: solar power, for example, produces less electricity as temperatures rise because high heat slows the flow of electrical current. Additionally, transmission lines lose up to 5.8% of their capacity to carry electricity as temperatures increase, resulting in reliability issues such as rolling blackouts. These combined effects slow down the entire energy cycle, making it harder for the grid to meet growing demand and causing power disruptions.

Rising Demand and Grid Load Increase the Threat of Power Outages

Electric grids are under unprecedented strain as record-high temperatures drive up air conditioning use, increasing energy demand in the summer. Power generation and transmission are impeded when demand outpaces supply, causing communities and businesses to experience blackouts. According to data from the North American Electric Reliability Corporation (NERC), between 2024 and 2028, an alarming 300 million people across the United States could face power outages. Texas, California, the Southwest, New England, and much of the Midwest are among the states and regions most at risk of energy emergencies during extreme conditions, according to 2024 NERC data. 

Data center build-out, driven by growing demand for artificial intelligence, cloud services, and big data analytics, further adds stress to the grid. Data centers are estimated to consume 9% of US annual electricity generation by 2030. With up to 40% of data centers’ total yearly energy consumption driven by cooling systems, peak demand during the hottest days of the year puts demand on the U.S. electric grid and increases power outage risk. 

Power outages bear significant economic costs and put human lives at severe risk. To put this into perspective, a concurrent heat wave and blackout event in Phoenix, Arizona, could put 1 million residents at high risk of heat-related illness, with more than 50% of the city’s population requiring medical care. As we saw with 2024’s Hurricane Beryl, more than 2 million Texans lost power during a heatwave, resulting in up to $1.3 billion in damages to the electric infrastructure in the Houston area and significant public health and business impacts.  The nation must make strategic investments to ensure energy reliability and foster the resilience of electric grids to weather hazards like extreme heat. 

Advancing Solutions for Energy Systems and Grid Security

Investments in resilience pay dividends, with every federal dollar spent on resilience returning $6 in societal benefits. For example, the DOE Grid Resilience State and Tribal Formula Grants, established by the Bipartisan Infrastructure Law (BIL), have strengthened grid infrastructure, developed innovative technologies, and improved community resilience against extreme weather. It is essential that funds for this program, as well as other BIL and Inflation Reduction Act initiatives, continue to be disbursed.  

To build heat resilience in communities across this nation, Congress must establish the HeatSmart Grids Initiative as a partnership between DOE, FEMA, HHS, the Federal Energy Regulatory Commission (FERC), NERC, and the Cybersecurity and Infrastructure Security Agency (CISA). This program should (i) perform national audits of energy security and building-stock preparedness for outages, (ii) map energy resilience assets such as long-term energy storage and microgrids, (iii) leverage technologies for minimizing grid loads such as smart grids and virtual power plants, and (iv) coordinate protocols with FEMA’s Community Lifelines and CISA’s Critical Infrastructure for emergency response. This initiative will ensure electric grids are prepared for extreme heat, including the risk of energy system failures during extreme heat and the necessary emergency and public health responses.  

Challenge & Opportunity: Increasing Household and Business Energy Costs

As temperatures rise, so do household and business energy bills to cover cooling costs. This escalation can be particularly challenging for low-income individuals, schools, and small businesses operating on thin margins. For businesses, especially small enterprises, power outages, equipment failures, and interruptions in the supply chain become more frequent and severe due to extreme weather, negatively affecting production and distribution. One in six U.S. households (21.2 million people) find themselves behind on their energy bills, which increases the risk of utility shut-offs. One in five households report reducing or forgoing food and medicine to pay their energy bills. Families, school districts, and business owners need active and passive cooling approaches to meet demands without increasing costs.

Advancing Solutions for Businesses, Households, and Vital Facilities

Affordably cooled homes, businesses, and schools are crucial to sustaining our economy. To prepare the nation’s housing and infrastructure for rising temperatures, the federal government should:

• Expand the Weatherization Assistance Program (WAP), the Low-Income Home Energy Assistance Program, existing rebates and tax credits (including HER, HEAR, 25C, 179D, 45L, Direct Pay) to include passive cooling technology such as cool walls, pavements, and roofs (H.R. 9894). Revise 25C to be refundable at purchase to increase accessibility to low-income households.
• Authorize a Weatherization Readiness Program (H.R. 8721) to address structural, plumbing, roofing, and electrical issues and environmental hazards with dwelling units to make them eligible for WAP.
• Direct the DOE to work with its WAP contractors to ensure home energy audits consider passive cooling interventions, such as cool walls and roofs, strategically placing trees to provide shading and high-efficiency windows. 
• Extend the National Initiative to Advance Building Codes (NIABC) to include (i) the development of codes and metrics for sustainable and passive cooling, shade, materials selection, and thermal comfort and (ii) the identification of opportunities to accelerate state and local adoption of code language for extreme heat adaptation. Partner with the National Institute of Standards and Technology to create an Extreme Heat clearinghouse for model building codes.
• Authorize an extension to the DOE Renew America’s Schools Program to continue funding cost-saving, energy-efficient upgrades in K-12 schools. 
• Provide supportive appropriations to heat-critical programs at DOE, including: the Affordable Home Energy Shot, State and Community Energy Programs (SCEP), Office of Clean Energy Demonstrations (OCED), Office of Energy Efficiency & Renewable Energy (DOE), and the Home Energy Rebates program

The Federation of American Scientists: Who We Are

At the Federation of American Scientists (FAS), we envision a world where the federal government deploys cutting-edge science, technology, ideas, and talent to solve and address the impacts of extreme heat. We bring expertise in embedding science, data, and technology into government decision-making and a strong network of subject matter experts in extreme heat, both inside and outside of government. Through our 2025 Heat Policy Agenda and broader policy library, FAS is positioned to help ensure that public policy meets the challenges of living with extreme heat.

Consider FAS a resource for… 

• Understanding evidence-based policy solutions
• Directing members and staff to relevant academic research 
• Connecting with issue experts to develop solutions that can immediately address the impacts of extreme heat

We are tackling this crisis with initiative, creativity, experimentation, and innovation, serving as a resource on environmental health policy issues. Feel free to always reach out to us:

President Trump’s executive order “Unleashing American Energy” promises an American economic revival based on lower costs, bringing back our supply chains, building America into a manufacturing superpower again, and cutting reliance on countries. Within this order he tasks the Secretary of Energy to prioritize programs to onshore critical mineral processing and development. Luckily, a little-known office at the Department of Energy (DOE) – the Office of Manufacturing and Energy Supply Chains (MESC) – is already at the heart of that agenda.

MESC and the Manufacturing Renaissance

Energy manufacturing in the U.S. is experiencing a historic momentum, thanks in large part to the Department of Energy. Manufacturing was the backbone of the 20th century U.S. economy, but recent decades have seen a dramatic offshoring of domestic supply chains, in particular to China, that has threatened U.S. economic and national security. With the global supply chain crises of the early 2020s, driven by COVID and Russia’s invasion of Ukraine, Congress finally took note. Through the Bipartisan Infrastructure Law, CHIPS and Science Act, and Inflation Reduction Act (IRA), lawmakers gave the federal government first-of-a-kind tools to reassert U.S. leadership in global manufacturing. This included creating, in 2021, a program (MESC) at the DOE that focuses on critical energy supply chains, including critical minerals.

Created in 2022 after the Bipartisan Infrastructure Law that infused DOE with new funds to reshore advanced energy manufacturing, the Office of Manufacturing and Energy Supply Chains (MESC) has been hard at work executing on reshoring manufacturing. Since inception, MESC has achieved a remarkable impact on the energy supply chain and manufacturing industry in the US. It has resulted in over $39 billion of investments from both the public and private sector into the American energy sector in companies that have created over 47,000 private sector jobs. Many of these jobs and companies that have been funded are for critical minerals development and processing.

MESC will be central to the energy dominance mission at the core of President Trump’s playbook along with Energy Secretary Chris Wright.

Why MESC is Crucial for Energy Dominance

MESC’s funding for energy infrastructure will be critical to American energy dominance and to address the energy crisis declaration that Trump signed on day one in office. Projects funded through this office include critical minerals and battery manufacturing necessary to compete with China, and grid modernization technology to ensure Americans have access to reliable and affordable power. For example, Ascend Elements was awarded two grants totaling $480M to build new critical minerals and battery recycling programs in Hopkinsville, Kentucky. This grant will yield an estimated $4.4 billion in economic activity and over 400 jobs for Hopkinsville. Sila Technologies was granted $100M for a silicon anode production facility in Moses Lake, Washington, which will be used in hundreds of thousands of automobiles, and strengthening the regional economy

The Trump administration can build on these successes and break new ground along the way:

1. Work with congress to permanently establish MESC with statutory authority and permanent appropriated funds.
2. Continue funding projects that will result in a resilient domestic energy supply, including projects to update our grid infrastructure and those that will create new jobs in energy technologies like critical minerals processing and battery manufacturing.
3. Use DOE’s Other Transaction Authority (OTA) to ensure prices for critical minerals and other energy manufacturing technologies that are primarily created or manufactured in China or other foreign entities of concern are profitable for companies, and affordable for customers.

Cost-conscious citizens should enthusiastically support these efforts because MESC has already proven its capability to punch above its weight. By making funding more permanent, Congress can 10x or more the speed and scale with which we assert energy dominance.

MESC is small but mighty. Its importance to continuing U.S. dominance in energy manufacturing cannot be overstated. Despite that, its funding in the budget is not permanent. The Trump administration has an opportunity to supercharge American energy dominance through MESC, but they must come together with Congressional leaders to permanently establish MESC and its mission. 2025 is an opportunity for new leaders to invest in creating American manufacturing jobs and spur innovation in the energy sector.

Earlier this week, the Senate confirmed Chris Wright as the Secretary of Energy, ushering in a new era of the Department of Energy (DOE). In his opening statement before Congress, Wright laid out his vision for the DOE under his leadership—to unleash American energy and restore “energy dominance”, lead the world in innovation by accelerating the work of the National Labs, and remove barriers to building energy projects domestically. Prior to Wright’s nomination, there have already been a range of proposals circulating for how, exactly, to do this.

Of these, a Trump FERC commissioner calls for the reorganization – a complete overhaul – of the DOE as-is. This proposed reorganization would eliminate DOE’s Office of Infrastructure, remove all applied energy programs, strip commercial technology and deployment funding, and rename the agency to be the Department of Energy Security and Advanced Science (DESAS). 

This proposal would eliminate crucial DOE offices that are accomplishing vital work across the country, and would give the DOE an unrecognizable facelift. Like other facelifts, the effort would be very costly – paid for by the American taxpayer, unnecessary, and a waste of public resources. Further, reorganizing DOE will waste the precious time and money of the Federal government, and mean that DOE’s incoming Secretary, Chris Wright, will be less effective in accomplishing the goals the President campaigned on – energy reliability, energy affordability, and winning the competition with China. The good news for the Trump Administration is that DOE’s existing organization structure is already well-suited and well-organized to pursue its “energy dominance” agenda. 

The Cost of Reorganizing

Since its inception in 1977, the Department of Energy has evolved several times in scope and focus to meet the changing needs of the nation. Each time, there was an intent and purpose behind the reorganization of the agency. For example, during the Clinton Administration, Congress restructured the nuclear weapons program into the semi-autonomous National Nuclear Security Administration (NNSA) to bolster management and oversight. 

More recently, in 2022, another reorganization was driven by the need to administer major new Congressionally-authorized programs and taxpayer funds effectively. With the enactment of the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA), DOE combined existing programs, like the Loan Programs Office, with newly-authorized offices, like the Office of Clean Energy Demonstrations (OCED). This structure allows DOE to hone a new Congressionally-mandated skill set – demonstration and deployment – while not diluting its traditional competency in managing fundamental research and development.

Even when they make sense, reorganizations have their risks, especially in a complex agency like the DOE. Large-scale changes to agencies inherently disrupt operations, threaten a loss of institutional knowledge, impair employee productivity, and create their own legal and bureaucratic complexities. These inherent risks are exacerbated even further with rushed or unwarranted reorganizations.

The financial costs of reorganizing a large Federal agency alone can be staggering. Lost productivity alone is estimated in the millions, as employees and leadership divert time and focus from mission-critical projects to logistical changes, including union negotiations. These efforts often drag on longer than anticipated, especially when determining how to split responsibilities and reassign personnel. Studies have shown that large-scale reorganizations within government agencies often fail to deliver promised efficiencies, instead introducing unforeseen costs and delays. 

These disruptions would be compounded by the impacts an unnecessary reorganization would have on billions of dollars in existing DOE projects already driving economic growth, particularly in rural and often Republican-led districts, which depend on the DOE’s stability to maintain these investments. Given the high stakes, policymakers have consistently recognized the importance of a stable DOE framework to achieve the nation’s energy goals. The bipartisan passage of the 2020 Energy Act in the Senate reflects a shared understanding that DOE needs a well-equipped demonstration and deployment team to advance energy security and achieve American energy dominance. 

DOE’s Existing Structure is Already Optimized to Pursue the Energy Dominance Agenda

In President Trump’s second campaign for office, he ran on a platform of setting up the U.S. to compete with China, to improve energy affordability and reliability for Americans, and to address the strain of rising electricity demand on the grid by using artificial intelligence (AI). DOE’s existing organization structure is already optimized to pursue President Trump’s ‘energy dominance’ agenda, most of which being implemented in Republican-represented districts. 

Competition with China

As mentioned above, in response to the 2021 Bipartisan Infrastructure Law (BIL), DOE created several new offices, including the Manufacturing and Energy Supply Chains Office (MESC) and the Office of Clean Energy Demonstrations (OCED). Both of these offices are positioning the U.S. to compete with China by focusing on strengthening domestic manufacturing, supply chains, and workforce development for critical energy technologies right here at home. 

MESC is spearheading efforts to establish a secure battery manufacturing supply chain within the U.S. In September 2024, the Office announced plans to deliver over $3 billion in investments to more than 25 battery projects across 14 states. The portfolio of selected projects, once fully contracted, are projected to support over 8,000 construction jobs and over 4,000 operating jobs domestically. These projects encompass essential critical mineral processing, battery production, and recycling efforts. By investing in domestic battery infrastructure, the program reduces reliance on foreign sources, particularly China, and enhances the U.S.’s ability to compete and lead on a global scale. 

In passing BIL, Congress understood that to compete with China, R&D alone is not sufficient. The United States needs to be building large-scale demonstrations of the newest energy technologies domestically. OCED is ensuring that these technologies, and their supply chains, reach commercial scale in the U.S. to directly benefit American industry and energy consumers. OCED catalyzes private capital by sharing the financial risk of early-stage technologies which speeds up domestic innovation and counters China’s heavy state-backed funding model. In 2024 alone, OCED awarded 91 projects, in 42 U.S. states, to over 160 prize winners. By supporting first-of-a-kind or next-generation projects, OCED de-risks emerging technologies for private sector adoption, enabling quicker commercialization and global competitiveness. With additional or existing funding, OCED could create next-generation geothermal and/or advanced nuclear programs that could help unlock the hundreds of gigawatts of potential domestic energy from each technology area. 

Energy Affordability and Reliability

Another BIL-authorized DOE office, the Grid Deployment Office (GDO), is playing a crucial role in improving energy affordability and reliability for Americans through targeted investments to modernize the nation’s power grid. GDO manages billions of dollars in funding under the BIL to improve grid resilience against wildfires, extreme weather, cyberattacks, and other disruptions. Programs like the Grid Resilience and Innovation Partnerships (GRIP) Program aim to enhance the reliability of the grid by supporting state-of-the-art grid infrastructure upgrades and developing new solutions to prevent outages and speed up restoration times in high-risk areas. The U.S. is in dire need of new transmission to keep costs low and maintain reliability for consumers. GDO is addressing the financial, regulatory, and technical barriers that are standing in the way of building vital transmission infrastructure.  

The Office of State and Community Energy Programs (SCEP), also part of the Office of Infrastructure, supports energy projects that help upgrade local government and residential infrastructure and lower household energy costs. Investments from BIL and IRA funding have already been distributed to states and communities, and SCEP is working to ensure that this taxpayer money is used as effectively as possible. For example, SCEP administers the Weatherization Assistance Program (WAP), which helps Americans in all 50 states improve energy efficiency by funding upgrades like insulation, window replacements, and modern heating systems. This program typically saves households $283 or more per year on energy costs.

Addressing Load Growth by Using AI

The DOE’s newest office, the Office of Critical and Emerging Tech (CET), leads the Department’s work on emerging areas important to national security like biotechnology, quantum, microelectronics, and artificial intelligence (AI). In April, CET partnered with several of DOE’s National Labs to produce an AI for Energy report. This report outlines DOE’s ongoing activities and the near-term potential to “safely and ethically implement AI to enable a secure, resilient power grid and drive energy innovation across the economy, while providing a skilled AI-ready energy workforce.” 

In addition to co-authoring this publication, CET partners with national labs to deploy AI-powered predictive analytics and simulation tools for addressing long-term load growth.

By deploying AI to enhance forecasting, manage grid performance, and integrate innovative energy technologies, CET ensures that the U.S. can handle our increasing energy demands while advancing grid reliability and resiliency.

The Path Forward 

DOE is already very well set up to pursue an energy dominance agenda for America. There’s simply no need to waste time conducting a large-scale agency reorganization. 

In a January 2024 Letter from the CEO, Chris Wright discusses his “straightforward business philosophy” for leading a high-functioning company. As a leader, he strives to “Hire great people and treat them like adults…” which makes Liberty Energy, his company, “successful in attracting and retaining exceptional people who together truly shine.” Secretary Wright knows how to run a successful business. He knows the “secret sauce” lies in employee satisfaction and retention. 

To apply this approach in his new role, Wright should resist tinkering with DOE’s structure, and instead, give employees a vision, and get off to the races of achieving the American energy dominance agenda without wasting time, the public’s money, and morale. Instead of redirecting resources to reorganizations, the DOE’s ample resources and existing program infrastructure should be harnessed to pursue initiatives that bolster the nation’s energy resilience and cut costs. Effective governance demands thoughtful consideration and long-term strategic alignment rather than hasty or superficial reorganizations.

The Nuclear Regulatory Commission (NRC), the Nation’s regulator of civilian nuclear technologies, should shift agency staff, resources, and operations more flexibly based on emergent regulatory demands. The nuclear power industry is demonstrating commercialization progress on new reactor concepts that will challenge the NRC’s licensing and oversight functions. Rulemaking on new licensing frameworks is in progress, but such regulation will fall short without changes to the NRC’s staffing. Since the NRC is exempt from civil service laws under the Atomic Energy Act (AEA) of 1954, the agency should use AEA flexible hiring authorities to launch the Next Nuclear Corps, a staffing program to shift capacity based on emergent, short-term workforce needs. The NRC should also better enable hiring managers to meet medium-term workforce needs by clarifying guidance on NRC’s direct hire authority.

Challenge and Opportunity

Policymakers, investors, and major energy users, such as data centers and industrial plants, are interested in new nuclear power because it promises unique value. New nuclear power technologies could add either additional base load or variable power to electrical systems. Small modular or micro reactors could provide independent power to military bases, many of which are connected to power grids and vulnerable to disruption. Local governments can stimulate economies with high-paying and safe jobs at nuclear plants. The average nuclear power plant also has the lowest lifecycle greenhouse gas emissions compared to other available electricity-generating technologies, including wind, solar, and hydropower. Current efforts to expand nuclear power are different from those of the 1970s and 1980s, the most recent decades of significant building. Proposals today include building plants designed similarly to plants of those decades or even restarting power operations at up to three closed plants; but more activity is focused on commercializing advanced and small modular reactors, diverse concepts incorporating innovations in reactor design, fuel types, and safety systems. The government has partnered with private companies to develop and demonstrate advanced reactors since the inception of nuclear technology in the 1950s, but today several companies demonstrate advanced technical and business progress toward commercialization. 

Innovation in nuclear power challenges the NRC’s status-quo approaches to licensing and oversight. Rulemaking on new regulatory frameworks is necessary and in progress, but changes to the agency’s staffing and operations are also needed. Over time, Congress, the President, and the Commission itself have adjusted the agency’s operations in response to shifts in international postures, comprehensive national energy plans, and accidents or emerging threats at nuclear plants, but the NRC’s ability to respond to sudden changes in the nuclear industry is a long-standing challenge. To become more flexible, NRC initiated Project Aim in 2014 after expectations of significant industry growth, spurred in part by tax incentives in the Energy Policy Act of 2005, were not realized due to record-low natural gas prices. More recent assessments from the Government Accountability Office (GAO) and NRC Office of Inspector General (OIG) acknowledge the challenge of workload forecasting in an unpredictable nuclear industry, but counterintuitively, some recommendations focus on improving the ability to workforce plan two years or more in advance. Renewed expectations of growth, spurred by interest from policymakers and energy customers, reinforces a point from the 2015 Project Aim final report that, “…effectiveness, efficiency, agility, flexibility, and performance must improve for the agency to continue to succeed in the future.”

Congress also called on the NRC to become more responsive to current developments as expressed in legislation enacted with bipartisan support. Across the Fiscal Responsibility Act of 2023 and the ADVANCE Act of 2024, Congress requires the NRC to update its mission statement to better reflect the benefits of civilian nuclear technology, establish regulatory frameworks for new technology, streamline environmental review, incentivize licensing of advanced nuclear technologies, and position itself and the United States as a leader in civilian nuclear power. Meeting expectations requires significant operational and workforce changes. Since NRC is exempt from civil service laws and operates an independent competitive merit system, widespread changes to the agency’s hiring practices will be determined by future Commissioners, including the President’s selection of Chair (and by extension, the Chair’s selection of the Executive Director for Operations (EDO)), and modifications to agreements between the NRC and the Office of Personnel Management (OPM). In the meantime, NRC is well equipped to increase hiring flexibility using authorities from existing law and regulations.

Plan of Action

Recommendation 1. The NRC EDO should launch the Next Nuclear Corps, a staffing program dedicated to shifting agency capacity based on short-term workforce needs.

The EDO should hire a new director to lead the Corps. The Corps director should report to the EDO and consult with the Office of the Chief Human Capital Officer (OCHCO) and division heads to develop Corps positions to address near-term priorities in competency areas that do not require in-depth training. Near-term priorities should be informed by the NRC’s existing yearly capacity assessments, but the Corps director should also rely on direct expertise and insights from branch chiefs who have a real-time understanding of industry activity and staffing challenges.

Recommendation 2. Hiring for the Corps should be executed under the special authority to appoint directly to the excepted service under 161B(a) of the Atomic Energy Act (AEA).

The ADVANCE Act of 2024 created new categories of hires to fill critical needs related to licensing, oversight, and matters related to NRC efficiency. The EDO should execute the Corps under the new authorities in section 161B(a) of the AEA as it provides clear direction and structure for the EDO to make personnel appointments outside of the NRC’s independent competitive merit system described in Management Directive 10.1. 161B(a)(A) provides up to 210 hires at any time and 161B(a)(B) provides up to 20 additional hires each fiscal year which are limited to a term of four years. The standard service term should be one year as near-term workforce needs may be temporary because of the nature of the position or uncertainty in future demand.

The EDO should adopt the following practices to allow renewals of some positions from the prior year without reaching the limits described in the AEA:

• 161B(a)(A): Appoint up to 140 new staff each fiscal year and consider staggering appointments to address capacity needs that arise later in the year. After the initial one-year term, up to half of the positions should be eligible for a one-year renewal if the need continues. After the initial cohort off-boards, an additional 140 new staff should be appointed alongside up to 70 renewed staff from the prior cohort without exceeding the maximum of 210 appointments at any time.
• 161B(a)(B): Appoint up to 20 new staff each fiscal year and consider staggering appointments to address capacity needs that arise later in the year. All positions should be eligible for a one-year renewal for up to three additional years if the need continues.

Recommendation 3. The EDO should update Management Directives 10.13 and 10.1 to contain or reference the standard operating procedure for NRC’s mirrored version of OPM’s Direct Hire Authority.

The proposed Corps addresses emergent, short-term capacity needs, but internal policy clarity is needed to solve medium-term hiring challenges for hard-to-recruit positions. As far back as 2007, NRC hiring managers and human resources reported that DHA was highly desired for hiring flexibility. The NRC OIG closed Recommendation 2.1 from Audit of the U.S. Nuclear Regulatory Commission’s Vacancy Announcement Process in June 2024 because NRC updated Standard Operating Procedure for Direct Hire Authority with more details. However, management directives are the primary policy and procedure documents that govern the NRC’s internal functions. The EDO should update management directives to formally capture or reference this procedure so that NRC staff are better equipped to use DHA. Specifically, the EDO should:

• amend Management Directive 10.13 Special Employment Programs to add Section IX. Direct Hire Authority, that formalizes the procedure in the Standard Operating Procedure for Direct Hire Authority
• update Management Directive 10.1, Section I.A. to reference the amended Management Directive 10.13 as the general policy for non-competitive hiring

Conclusion

The potential of new nuclear power plants to meet energy demand, increase energy security, and revitalize local economies depends on new regulatory and operational approaches at the NRC. Rulemaking on new licensing frameworks is in progress, but the NRC should also use AEA flexible hiring authorities to address emergent, short-term workforce needs that may be temporary based on shifting industry developments. The proposed Corps structure allows the EDO to quickly hire new staff outside of the agency’s competitive merit system for short-term needs while preserving flexibility to renew appointments if the capacity needs continue. For permanent hard-to-recruit positions, the EDO should clarify guidance for hiring managers on direct hire authority. The NRC is well equipped with existing authorities to meet emergent regulatory demand and renewed expectations of nuclear power growth.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

As a fusion energy future becomes increasingly tangible, the United States should proactively prepare for it if/when it arrives. A single, commercial-scale fusion reactor will require more tritium fuel than is currently available from global civilian-use inventories. For fusion to be viable, greater-than-replacement tritium breeding technologies will be essential. Before the cycle of net tritium gain can begin, however, the world needs sufficient tritium to complete R&D and successfully commission first-of-a-kind (FOAK) fusion reactors. The United States has the only proven and scalable tritium production supply chain, but it is largely reserved for nuclear weapons. Excess tritium production capacity should be leveraged to ensure the success of and U.S. leadership in fusion energy.

The Trump administration should reinforce U.S. investments and leadership in commercial fusion with game changing innovation in the provision of tritium fuel. The Congressional Fusion Energy Caucus has growing support in the House with 92 members and an emerging Senate counterpart chaired by Sen. Martin Heinrich. Energy security and independence are important areas of bipartisan cooperation, but strong leadership from the White House will be needed to set a bold, America-first agenda.

Challenge and Opportunity

Fusion energy R&D currently relies on limited reserves of tritium from non-scalable production streams. These reserves reduce by ~5% each year due to radioactive decay, which makes stockpiling difficult. One recent estimate suggests that global stocks of civilian-use tritium are just 25–30kg, while commissioning and startup of a single commercial fusion reactor may require up to 10kg. The largest source of civilian-use tritium is Canada, which produces ~2kg/yr as a byproduct of heavy water reactor operation, but most of that material is intended to fuel the International Thermonuclear Experimental Reactor (ITER) in the next decade. This tritium production is directly coupled to the power generation rate of its fleet of Canadian Deuterium Uranium (CANDU) reactors; therefore, the only way to increase the tritium production rate is to build more CANDU power reactors.

The National Nuclear Security Administration (NNSA) (an Office of the U.S. Department of Energy (DOE)) – in cooperation with the Tennessee Valley Authority (TVA) – will produce up-to ~4kg of tritium over the next fuel cycles (i.e., ~18-month cycles offset by 6 months) for the two Watts Bar nuclear (WBN) reactors. This would exceed the current, combined 2.8kg production goal, which could be further outstripped if the reactors were operated at their maximum licensed limit, producing ~4.7kg of tritium. All this tritium is designated for military use. However, the NNSA and DOE could leverage production capacities in excess of defense requirements to promote the deployment of FOAK reactors and support U.S. leadership in fusion energy. The DOE could build off the success of its current Milestone-Based Fusion Program by integrating the option for additional tritium availability to meet the commissioning demands of pilot and commercial fusion reactors. 

This program could be called “Gigatons-to-Gigawatts” (GtG), a name inspired by one of the most successful fissile material reduction programs in history Megatons-to-Megawatts. The increased scale signifies much higher energy densities contained in tritium vs. the uranium commonly used to fuel fission reactors. Fusion and fission reactor technologies also have very different nonproliferation implications. U.S. national security and nonproliferation goals would be furthered by a systematic transition from fission to fusion energy. Lowering reliance on dual-use nuclear fuel cycle technologies such as centrifuges for uranium enrichment would lower overall proliferation risks. Just as it did by promoting an open fuel cycle, the United States could leverage its technological leadership to promote the adoption of a more proliferation-resistant fusion infrastructure. 

However, it is important to note another key difference with Megatons-to-Megawatts: because GtG leverages near-term tritium production capacities in concert with reserves rather than repurposing stockpiled weapons-useable material for civilian use such a program could affect the U.S. nuclear deterrent posture as well. The National Nuclear Security Administration (NNSA) Strategic Integrated Roadmap highlights the goal to “Demonstrate enhanced tritium production capability” for 2025 which is coded as “Nuclear Deterrent.” The anticipated excess production quantities noted above would correspond with this goal. Starting from this demonstrated capability, a GtG program would extend this production capacity into a longer-term effort directed toward a fusion energy future. Furthermore, in support of the long-term goal of nuclear disarmament, GtG would also provide a ready-made framework for repurposing valuable tritium from decommissioned warheads.

One way the United States demonstrates the credibility of its nuclear deterrent is through the Stockpile Stewardship and Management Plan (SSMP). Allies and adversaries alike must believe that the United States has sufficient tritium capability to replenish this critical and slowly decaying resource. An enhanced tritium production capability also has a supporting role to play in reassuring U.S. policymakers that key material design requirements are being sustainably met and that future nuclear weapon tests will be unnecessary. Even though GtG would be programmatically dedicated to the peaceful use of tritium, the technological mechanisms used to reach this goal would nonetheless be compatible with and/or even complementary to the existing nuclear defense posture.   

Key facts highlighted in the 2024 Fusion Industry Association (FIA) global reports include: (i) tritium remains the key fuel source for most fusion technologies being developed; (ii) tritium self-sufficiency was seen as one of the major near-term challenges and by a slim margin the major challenge after 2030; and (iii) supply chain partners noted tritium was one of the top 3 constraints to scalability. The easiest reaction to achieve is deuterium–tritium (D–T) fusion. Other more technologically challenging approaches to fusion energy rely on different reactions such as deuterium–deuterium (D–D) and deuterium–Helium-3 (D–He-3) fusion. The Earth has a functionally limitless supply of deuterium; however, even though He-3 is radioactively stable, it slowly leaks from the atmosphere into space. Until humanity can mine the vast quantities of He-3 on the moon, one of the only terrestrial sources of this material is from the tritium decay process. A GtG program would directly support an increase in tritium supply and indirectly support long-term He-3 reserves since it can be stockpiled. Even if fusion with He-3 proves viable, it will be necessary to produce the tritium first.

Once commercial fusion reactors begin operation, breeding tritium to replace burned fuel is a major concern because there is no alternative supply sufficient to replace shortfalls from even modest inefficiency. Operating a 1 GW fusion reactor for a year may require more than 55kg of tritium. Tritium self-sufficiency is nonnegotiable for a functional fusion industry. If technological development falters as companies strive toward a sustainable tritium breeding cycle, they may find themselves in the awkward position of needing tritium more than additional funding.

Of the countries leading the way in private fusion ventures and public investment, the only not closely allied with the U.S. is China, which is also the country most capable of leveraging military tritium production for fusion R&D. In stark contrast with the United States, there is no public information on Chinese tritium production capacities or how much they currently possess. Since China is rapidly expanding their nuclear weapon stockpile, their material margins for repurposing tritium for peaceful-use material will be constrained. If a U.S. investment of tritium into fusion R&D accelerates the growth of domestic companies, then China may be forced to choose between advancing their nuclear weapons agenda and competing with the West for a fusion energy breakthrough.

The United States already has a significant lead in technological capabilities for future generations of fusion energy based on Inertial Confinement Fusion (ICF). The National Ignition Facility (NIF) at Lawrence Livermore National Labs (LLNL) first demonstrated fusion ignition from ICF using tritium in 2022. Largely heralded as a breakthrough for the future of nuclear energy, the facility and ICF tests also provide critical, experimental support for the SSMP. To better position the United States to capitalize on these long-term investments in science and technology, fusion energy leadership should not be ceded to other nations.

Plan of Action

Recommendation 1. Name a White House “Gigatons-to-Gigawatts” czar to coordinate a long-term tritium strategy and interagency cooperation harmonizing national security and fusion energy leadership goals.

A Senior Advisor on the National Security Team of the White House Office of Science and Technology Policy (OSTP) serving as the White House czar for GtG would (i) guide and lead efforts, (ii) coordinate interagency partners, and (iii) facilitate private/public stakeholder forums. Key interagency partners include:

• The Nuclear Weapons Council (NWC)
• DOE National Nuclear Security Administration (NNSA) Office of Tritium and Domestic Uranium Enrichment
• DOE NNSA Tritium Modernization Program (NA-19)
• DOE NNSA Office of Nuclear Material Integration (ONMI) (NA-532)
• DOE Office of Science
• The Office of Fusion Energy Sciences (FES) at DOE Office of Science
• DOE Advanced Research Projects Agency – Energy (ARPA-E)
• State Bureau of International Security and Nonproliferation (ISN)
• TVA Tritium Production Program
• Nuclear Regulatory Commission (NRC) Office of Nuclear Material Safety and Safeguards (NMSS)
• Savannah River National Lab (SRNL)
• Los Alamos National Lab (LANL)
• Pacific Northwest National Lab (PNNL)
• Idaho National Lab (INL) Safety and Tritium Applied Research (STAR)
• Environmental Protection Agency (EPA) Office of Radiation and Indoor Air (ORIA)
• Fusion Energy Sciences Advisory Committee (FESAC) 

Key private partners include:

• Savannah River Nuclear Solutions (SRNS) and the Savannah River Tritium Enterprise (SRTE) program
• Westinghouse Government Services (WGS) Columbia Fuel Fabrication Facility (CFFF)
• Fusion Industry Association (FIA)

A  central task of the GtG czar would be to coordinate with the NWC to review Presidential Policy Directive 9 (PPD-9) and associated/superseding planning documents related to the assessment of tritium demand requirements including (i) laboratory research, development, and surveillance and (ii) presidentially mandated tritium reserve. These two components of the tritium requirement could potentially be expanded to address GtG needs. If deemed appropriate, the President of the United States could be advised to expand the presidentially mandated reserve. Otherwise, the former requirement could be expanded based on optimal quantities to stand up a GtG program capability. A reference target would be the accumulation of ~10kg of tritium on projected timelines for commissioning full-scale FOAK fusion reactors.

The following recommendations could be coordinated by a GtG czar or done independently.

Recommendation 2. The Secretary of Energy should direct the Office of Science to evaluate the Milestone-Based Fusion Development Program for integrating GtG tritium production and supply targets with projected industry demands for commissioning fusion power plants.

The Milestone-Based Fusion Development Program has already provided awards of $46 million to 8 US companies. It is crucial to ensure that any tritium produced for a GtG program is not accumulated without a viable success path for FOAK fusion plant commissioning. Given the modest production capacities currently available at the WBN site, timelines of 5–10 years will be necessary to accumulate tritium. Each fuel cycle could allow for adjustments in production targets, but sufficient lead time will be required to anticipate and plan for necessary core changes and fuel-assembly production.

GtG tritium awards aligned with the Milestone-Based Fusion Development Program would also be more viable and attractive if costs were equitably shared between private awardees and the DOE. The U.S. Government produces tritium at WBN at a premium of ~$50,000/g whereas the market rate for tritium produced in Canada is closer to $30,000/g. A fusion company awarded tritium through the GtG program should be required to pay the prevailing market rate for tritium upon extraction at the Savannah River Site (SRS). This would allow a fusion company to benefit from increased tritium availability, while the DOE shoulders the cost differences of Tritium-Producing Burnable Absorber Rod (TPBAR) production methods. Additionally, this pay-as-you-go requirement will incentivize fusion energy companies to lay out realistic timeframes for FOAK reactor deployments.

The Director of the Office of Science should also direct the FESAC to prepare a report on tritium demand scenarios that would apply to leading fusion technology development timelines and assess the necessary tritium breeding efficiencies needed to sustain fusion power plant operations. The FESAC should give special consideration to projecting possible mitigation and recovery strategies for tritium breeding shortfalls. The committee should also provide thresholds for FOAK fusion reactors’ short-term recoverability from tritium breeding shortfalls. Tritium quantities based on this FESAC report should be considered for future tritium hedges after these fusion reactors begin power operations.

Recommendation 3. The NNSA ONMI (NA-532) should coordinate an interagency review of the tritium supply chain infrastructure.

Raising tritium production targets beyond previously projected requirements would necessitate review from TPBAR assembly at Westinghouse’s CFFF, irradiation at TVA’s Watts Bar Reactors, and then extraction and processing through the SRTE program at SRS. Because this review naturally involves civilian reactors and the transport of nuclear materials the NRC should also be consulted to ensure regulatory compliance is maintained. This review will provide realistic bounding limits to the quantities of tritium and production timelines that could be designated for a GtG program. The outcome of this review will inform industry-facing efforts to better assess how additional tritium supplies could best support fusion energy R&D and pilot plant commissioning.

As part of this process, the NA-532 office should determine which existing tritium supply chain models are best suited for assessing commercial applications, including the LANL Tritium Supply and Demand Model and those developed internally by the NNSA. If no model is determined fit for purpose, then a new model should be developed to best capture the dynamics of commercial fusion R&D. In any case, existing models should form the basis for integrating military requirements and civilian markets to ensure a GtG program adequately accounts for both.

An added-value option for this recommendation would be to prepare an unclassified and publicly accessible version of the commercial tritium supply chain model. This would reinforce the transparency and public accountability already built into the production of tritium in the commercial power reactors at Watts Bar. Furthermore, such a resource would also help explain the rationale and intent behind the use of public funds to support fusion R&D and the commissioning of FOAK fusion reactors.

Recommendation 4. The Secretary of Energy should direct a review of DOE Technical Standards for addressing tritium-related radiological risks. 

While the general scientific consensus is that low-level tritium exposure poses negligible human health and ecosystem risks, there are several unknowns that should be better understood before the advent of fusion energy releases unprecedented quantities of tritium into the environment. This adequacy review should include at least [i] a comprehensive analysis of risks from Organically Bound Tritium (OBT) and [ii] more precisely quantifying and considering the potential for damaging mitochondrial DNA and fetuses. These efforts would help ensure the responsible, consent-based rollout of tritium-intensive technologies and allow for an informed public to better understand the magnitude of risks to be weighed against potential benefits.

Key DOE Technical Standards to include in this review:

• Derived Concentration Technical Standard (DOE-STD-1196-2022)
• Internal Dosimetry (DOE-STD-1121-2008 (Reaffirmed 2022))
• Nuclear Materials Control and Accountability (DOE-STD-1194-2019)

Recommendation 5. The Administrator of the Environmental Protection Agency (EPA) should direct the Office of Radiation and Indoor Air (ORIA) to assess the adequacy of radioactive dose calculations in the Federal Guidance Report on External Exposure to Radionuclides in Air, Water, and Soil (FGR 15) last issued in 2019.

This recommendation, along with recommendation 3 above, will provide sufficient lead time to address any uncertainties and unknowns regarding the radiological risks posed by tritium. As in this previous case, this adequacy review should include at least [i] a comprehensive analysis of risks from Organically Bound Tritium (OBT) and [ii] more precisely quantifying and considering the potential for damaging mitochondrial DNA and fetuses. FGR 15 currently calculates effective dose rates for “computational phantom” models of 6 different age groups, including newborns, that incorporate both male and female sex-specific tissues. However, effective dose rates and potential effects are not considered for developing fetuses. The uncertainty surrounding tritium’s radiological risks prompts an extensive precautionary approach to potential exposures for declared pregnant workers. However, the potential for higher levels of tritium exposure for pregnant members of the public should also be taken into consideration when assessing the radiological risks of fusion energy.

Conclusion

With a strategically calibrated GtG program, the United States could remain technology leaders in fusion energy and potentially reduce the rollout timeline of a multi-unit fleet by several years. In the context of state-level technological competition and a multi-polar nuclear security environment, years matter. A strategic GtG reserve will take years to plan and accumulate to ensure sufficient tritium is available at the right time.

The long-term utility of a GtG framework is not limited to the designation of new tritium production for peaceful use. Once nuclear-weapons states return to the negotiating table to reduce the number of nuclear weapons in the world, the United States would have a clear roadmap for repurposing the tritium from decommissioned weapons in support of fusion power. Previously, the United States held onto large reserves of this valuable and critical material for years while transitioning from military to civilian production. The years between 2025 and 2040 will provide more chances to put that material to productive use for fusion energy. Let us not waste this opportunity to ensure the U.S. remains at the vanguard of the fusion revolution.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

The United States should continue to pursue its commitment to reduce greenhouse gas emissions by 50–52% from 2005 levels by 2030 and achieve net-zero emissions by 2050. To reach these goals, the United States must rapidly increase renewable-energy production while simultaneously building the transmission capacity needed to carry power generated from new renewable sources. Such an investment requires transforming the American electricity grid at a never-before-seen speed and scale. For example, the 2024 DOE National Transmission Planning study estimates that the American transmission system will need to grow between 2.4 – 3.5 times its 2020 size by 2050 to achieve a 90% greenhouse gas emissions reduction from a 2005 baseline by 2035 and net-zero emissions in 2050. A promising way to achieve this ambitious transmission target is to create a national High Voltage Direct Current (HVDC) transmission network overlaid atop the existing alternating current (AC) grid. In addition to advancing America’s climate goals, such an effort would spur economic development in rural areas, improve the grid’s energy efficiency, and bolster grid stability and security. This memo proposes several policy options the Department of Energy (DOE) and Congress can pursue to incentivize private-sector efforts to construct a national HVDC transmission network while avoiding permitting issues that have doomed some previous HVDC projects.

Challenge and Opportunity

The current American electricity grid resembles the roadway system before the Eisenhower interstate system. Just as roads extended to most communities by the early 1950s, few areas are unelectrified today. However, the AC power lines that cross the United States today are tangled, congested, and ill-suited to quickly move large amounts of renewable power from energy-producing regions with lower demand (such as the Midwest and Southwest) directly to large population centers with high demand. Since HVDC transmission lines lose less power than AC lines at distances > 300 miles, HVDC technology is the best option to directly connect the renewable generation needed to achieve net-zero emissions by 2050 with consumers. 

There are few HVDC lines in the United States today. Those that do exist are scattered across the country and were not designed to facilitate renewable development. As a result, the United States is a long way from the integrated nationwide HVDC network needed to achieve net-zero emissions. Many recent attempts by the private sector to begin building long-distance HVDC transmission lines between renewable producing regions and consumers—such as Clean Line Energy’s proposal for an aboveground line that would have linked much of the Great Plains to the Southeast—have been unsuccessful due to a host of challenges. These challenges included negotiating leases with thousands of landowners with understandable concerns about how the project could alter their properties, negotiating with many local and state jurisdictions to secure project approval, and maintaining investor confidence throughout the complex and time-consuming permitting and leasing process. 
However, a new generation of private developers has proposed an innovative solution that bypasses these challenges: the construction of an underground nationwide HVDC network alongside existing rail corridors. Unlike aboveground transmission built through a mosaic of property owners’ holdings, this solution requires negotiation with only the seven major American rail companies. This approach also takes advantage of the proximity of these already-disturbed corridors to many areas with high renewable-energy potential (Figure 1), does not add visual pollution to the aboveground landscape, and would weatherproof grid infrastructure against natural disasters.

Figure 1

Areas with high potential for wind and solar generation in the Great Plains and Southwest overlap with existing rail routes. Clockwise from left to right, routes of all seven class 1 railways (Source: Federal Railway Administration), heat map of average annual wind speed 80 meters aboveground (an indicator of the potential for wind energy generation; Source: National Renewable Energy

Importantly, these benefits apply to co-location next to highways or existing transmission lines as well. While this memo focuses on rail co-location, co-location next to other infrastructure should be simultaneously pursued by first removing regulatory barriers as was recently enacted in Minnesota and promoting the efficiencies gained from all forms of infrastructure co-location to relevant stakeholders. 

In addition to the political considerations discussed above, several recent advances in HVDC technology have driven costs low enough to make HVDC installation cost-competitive with installing high voltage alternating current (HVAC) lines (see FAQ for more details). As a result, incentivizing HVDC makes sense from perspectives beyond addressing climate change. The U.S. electric grid must be modernized to address pressing challenges beyond climate, such as the need for improved grid reliability and stability. Because HVDC transmission, unlike AC transmission, can maintain consistent power, voltage, and frequency, constructing a HVDC transmission network is a promising way to support the large-scale incorporation of renewable sources into our nation’s energy mix while simultaneously bolstering grid stability and efficiency, and spurring economic growth in rural areas. 

A nationwide HVDC network would also increase grid stability by connecting the four large interconnections that make up the shared American and Canadian power grid (Figure 2). Currently, the two largest of these interconnections—the Eastern and Western interconnections—manage 700 and 250 GW of electricity respectively. Yet, these interconnections are connected by transfer stations with a capacity of only about 1 GW. A recent study led by NREL modeled the economics of building a nationwide HVDC macrogrid that would tie the Eastern and Western interconnections together. The study concluded that such an investment would have a net benefit-to-cost ratio of 1.36 due to the possible ability for a nationwide HVDC grid to (i) shuttle renewable energy across the country as different power sources begin and end generation capabilities each day, and (ii) respond more nimbly to power outages in regions affected by natural disasters.

Figure 2

The four interconnections comprising the American and Canadian electricity grid: the Western, Eastern, ERCOT (Texas), and Quebec interconnections. Colors within the Eastern interconnection represent the territories of non-profit entities established to promote and enhance grid reliability within the territories shown on the map. These grid-reliability non-profits should not be confused with independent system operators (ISOs). (Source: National Electricity Reliability Council (NERC)).

Many private companies are already starting to realize an upgraded U.S. grid via new co-located HVDC transmission lines. For example, Minneapolis-based Direct Connect, with financial backing from American and international investors, has begun the permitting process for SOO Green, a buried HVDC line along a low-use railway that will link the Iowa countryside to the Chicago area. Direct Connect estimates that the SOO Green HVDC link will spur $1.5 billion of new renewable-energy development, create $2.2 billion of economic output in Iowa and Illinois, and create thousands of construction, operation, and maintenance jobs. Although geographically short, the line is also significant because it will join the Midwest (MISO) and PJM Independent System Operators (ISOs), two of the seven regional bodies that manage much of the United States’ grid. The combined territory of the MISO and PJM ISOs stretches from the wind-rich Great Plains to demand centers like Chicago and the Northeast corridor. Facilitating HVDC transmission in this project will allow renewable power to be efficiently funneled from regions that produce lots of energy to the regions that need it. 

The Champlain Hudson Power Express joining NY-ISO and the Quebec interconnection is another example demonstrating the promise of buried, co-located HVDC transmission. The project is projected to save New York homes and businesses $17.3 billion over 30 years through wholesale electricity costs by supplying Quebec hydropower to New York City. The line is currently permitted and under construction and when finished will stretch 339 miles underneath Lake Champlain & the Hudson River and underground through New York State to a converter in Astoria, New York City. The terrestrial portions will be built alongside existing railroad and highway right of ways. 

While these two projects and the handful of other buried and  co-located HVDC lines currently in permitting, permitted, or under construction are important projects, far more transmission needs to be built to meet the U.S.’ climate goals.  As a result, scaling underground co-located HVDC rapidly enough to achieve the transmission required for net-zero emissions in 2050 requires federal action to make these types of lines a more attractive proposition. The policy options outlined below would encourage other privately backed HVDC projects with the potential to boost rural economies while advancing climate action.

Plan of Action

The following policy recommendations would accelerate the development of a national HVDC network by stimulating privately funded construction of underground HVDC transmission lines located alongside existing rail corridors. Recommendations one and two are easily actionable rule changes that can be enacted by the Federal Energy Regulatory Commission (FERC) under existing authority. Recommendation three proposes that the DOE Grid Deployment Office should consider rail co-location in its NIETC designation process. Recommendation four is a more ambitious proposal for federal tax credits which would require Congressional action.

Recommendation 1. FERC should issue a new order that requires ISOs to review new renewable generation and new transmission projects on separate tracks to decrease permitting time delays.

New merchant transmission projects (transmission lines developed by private companies and not by rate-regulated utilities) such as SOO Green and the Champlain Hudson Power Express are often reviewed by ISOs in the same interconnection queue as new generation projects. Due to the high volume backlog of new, often speculative, renewable generation project proposals, transmission projects can wait for years before they are reviewed. This then creates a vicious cycle holding back the clean-energy sector: a delayed review of the transmission capabilities required by new renewable-generation projects ultimately chills the market for generation projects as well.

FERC recently reformed its regulations for interconnection requests (FERC Order 2023). FERC’s  expectation is that switching to a first-ready, first-served system, clustering projects together in groups to be approved en masse, and increasing both submission deposits and withdrawal penalties should prevent speculative submissions and reduce approval times. Order 2023’s removal of the reasonable effects standard (i.e. hardening deadlines for transmission providers to complete impact and interconnection studies) as well as allowing multiple generation projects to share interconnections should also reduce wait times. 

FERC Order 2023 is a laudable first step to address interconnection backlogs; however there is a chance that reality may not match FERC’s expectations. Therefore, FERC should continue to improve the regulatory regime in this area by issuing a new order that requires ISOs to review new renewable generation and new transmission projects on separate tracks. Such a rule would greatly decrease the permitting time for co-located HVDC transmission projects. 

Recommendation 2. FERC should encourage ISOs to re-examine older transmission interconnection rules that are appropriate for AC transmission regulation but do not take into account the benefits of HVDC. External capacity rules, which govern the ability to trade power across ISO boundaries, are a specific area in need of action because they can create barriers to building HVDC transmission across ISO boundaries. 

One granular example is described in SOO Green’s complaint to FERC about the PJM ISO (FERC Docket EL21-103).  Under current rules set by the PJM ISO, energy generated outside of the PJM service area can participate in PJM’s energy marketplace only if grid operators can directly dispatch that energy. This rule was established because grid operators cannot otherwise control the free flow of power through cross-ISO AC transmission, but it results in the exclusion of external, non-dispatchable renewable energy resources from PJM’s market.  However, HVDC lines offer the capacity to schedule current flow at pre-agreed upon times, allowing PJM to directly control transmission and negating the need to control energy dispatch. PJM should look for solutions to this issue from ISO New England and NYISO’s external capacity rules, which have enabled them to import external capacity through HVDC lines into their territories. 

FERC should encourage PJM ISO to revise its external capacity rules to enable less burdensome pathways to market participation for external resources connecting through HVDC transmission. PJM can look to ISO New England and NYISO as examples.

Recommendation 3. As the DOE proposes possible National Interest Electric Transmission Corridors (NIETCs), it should pursue co-location with rail, highways, and existing transmission whenever possible.

Previous attempts by Congress to establish greater federal power over transmission siting and permitting have revolved around the DOE’s authority to designate areas as NIETCs. NIETCs are regions that the DOE identifies as particularly prone to grid congestion or transmission-capacity constraints. Creation of NIETCs was authorized by the Federal Power Act (Sec. 216), which also grants FERC the authority to supersede states’ permitting and siting decisions if the rejected transmission project is in a NIETC and meets certain conditions (including benefits to consumers (even those in other states), enhancement of energy independence, or if the project is “consistent with the public interest”). This “backstop” authority was created by the Energy Policy Act of 2005, was recently reformed in 2021’s Infrastructure Investment and Jobs Act, and was further clarified by FERC Order 1977 through the creation of a landowner bill of rights. 

While a laudable attempt to spur transmission investment and respect landowners, the revised authority in its current form is unlikely to lead to the sudden acceleration of transmission siting and permitting necessary to achieve the United States’ climate goals. This is because NIETC designation, as well as any FERC action under Section 216, (i) trigger the development of environmental impact statements under the National Environmental Policy Act (NEPA), and (ii) may still engender strong political opposition by states and landowners whose properties would be part of proposed routes but would not receive any benefits from transmission investments.

The DOE recently released a list of proposed NIETCs, which if designated would be the first corridors in the country.  Some of the NIETCs were designed with co-location in mind, for example the NY – NE ISO link is located alongside roadways and mid-Atlantic routes are co-located with already existing transmission. However, rail co-location was not mentioned, yet the DOE’s proposed NIETCs overlap with the nation’s class 1 railways in many locations, especially in the Southwest and Midwest. In order to speed up the NEPA review process and reduce NIETC opposition, the DOE should i) consider discussing rail co-location in addition to highway and transmission infrastructure during the upcoming public engagement process, and ii) promote the possibility of co-location to transmission developers in all relevant NIETCs after they are officially designated.

Recommendation 4. Create federal tax credits to stimulate domestic manufacturing and construction of HVDC transmission, including HVDC lines along rail corridors.

Congress should create two federal investment tax credits (ITCs) to stimulate a market for American HVDC lines. One tax credit should be directed to American manufacturers of cross-linked polyethylene (XLPE) which serves as the material for the liner in HVDC cables. Since most producers are based in Asia, such an incentive would help ensure a reliable domestic supply of this essential material. The second tax credit should be directed to HVDC line developers who propose new regionally significant transmission projects that join ISOs or the three interconnections together. Since the United States’ grid grew in an ad-hoc, decentralized way, a Congressional tax credit of this type would further build on FERC’s recent order 1920, which requires transmission providers to think more big picture, long-term and strategically by developing a long-term regional transmission plan that covers at least the next 20 years. 

Such a tax credit was recently introduced into Congress. In 2023, Sen. Martin Heinrich (D-NM) proposed a 30% ITC for “regionally significant” transmission projects which was also introduced in a companion bill by Rep. Steven Horsford, (D-Nev). Their Grid Resiliency Tax Credit Act would provide a 10-year credit for projects that begin building before 2033. The bill is currently under discussion by the Senate Finance committee and should be amended to also include a tax credit for XLPE manufacturers. The expiration of parts of the Tax Cuts and Jobs Act in 2025 will focus attention on tax legislation in the next Congress and offer a legislative window for transmission construction and component manufacturing tax credits. In the potentially acrimonious debate about the future of tax policy, transmission tax credits could be a rare point of agreement and an opportunity for both parties to invest in American manufacturing and infrastructure growth.

Conclusion

A significant increase in transmission capacity is needed to meet the United States’ efforts to achieve net-zero emissions by 2050. Creating a nationwide HVDC transmission network would not only greatly aid the United States’ efforts to address climate change, it would also improve grid stability and provide sustained economic development in rural areas. Direct Connect’s SOO Green project and the Champlain Hudson Power Express are examples of innovative solutions to legitimate stakeholder concerns over environmental impacts and individual property rights – concerns that have plagued previous failed efforts to construct long-distance HVDC transmission. The federal government can stimulate private development of HVDC  infrastructure via rule changes to the transmission interconnection process by FERC, promoting rail co-location in the NIETC design and designation process, and by passing new HVDC transmission-specific tax credits.

This idea was originally published on May 5, 2022; we’ve re-published this updated version on November 12, 2024.

This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.

PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.

The next generation of nuclear energy deployment depends on the Nuclear Regulatory Commission’s (NRC) willingness to use flexible hiring authorities to shape its workforce. Many analysts and policymakers propose increasing nuclear power production to ensure energy security and overall emissions reduction, and the U.S. recently joined 20 other countries in a pledge to triple global nuclear energy capacity by 2050. Additional nuclear deployment at this scale requires commercializing advanced reactor concepts or reducing capital costs for proven reactor technologies, and these outcomes rely on the capacity of the NRC to efficiently license and oversee a larger civilian nuclear industry. The ADVANCE Act, which became law in July, 2024, empowers the agency to accelerate licensing processes, mandates a new mission statement that reflects the benefits of nuclear energy, and provides additional direction to existing hiring flexibilities authorized by the Atomic Energy Act (AEA) of 1954. To meet expected demand for licensing and oversight, the NRC should not hesitate to implement new hiring practices under this direction.

The potential of the ADVANCE Act’s provisions should be understood in context of NRC’s existing authorities, practices, and history. NRC is exempt from the federal competitive hiring system for most positions. When Congress created the NRC in 1974 as a partial replacement of the Atomic Energy Commission (AEC), it maintained AEA provisions that allowed the AEC to hire without regard to civil service laws. Most NRC positions are in the Excepted Service, a category of positions across the federal workforce exempt from competitive hiring, which is particularly useful for highly-skilled positions that are impracticable to assess using traditional federal examining methods. The AEA allows NRC to hire staff to the Excepted Service provided salaries do not exceed grade 18 of the General Schedule (GS) (GS-16-18 were replaced with the Senior Executive Service in 1978) for scientific and technical positions and provided salaries for other positions follow the General Schedule when the occupation is comparable. Other agencies can hire to the Excepted Service in limited circumstances such as for candidates that are veterans or for specific occupations defined by the Office of Personnel Management (OPM).

Non-Competitive Hiring In Practice

Based on a review of NRC policies, procedures, and reports, NRC underuses its non-competitive hiring authorities provided under the AEA. Management Directives (or MDs, NRC’s internal policy documents) repeatedly state that NRC is exempt from competitive hiring under the AEA while outlining procedures that mirror government-wide practices derived from other laws and regulations such as the Senior Executive Service, Administrative Judges, experts and consultants, advisory committee members, and veterans, which are common flexible hiring pathways available to other agencies. MD 10.1 outlines NRC’s independent competitive merit system that generally follows OPM’s general schedule qualification standards. MD 10.13 on NRC’s non-competitive hiring practices under AEA authority is limited to part-time roles and student programs. While the policy includes a disclaimer that it covers only the most common uses, it does not include guidance on applying non-competitive hiring to other use cases. 

The NRC has also been slow to reconcile its unique flexible hiring authorities with OPM Direct Hire Authority (DHA), a separate expedited process to hire to the Competitive Service. As far back as 2007, NRC hiring managers and human resources reported in Government Accountability Office interviews that DHA was highly desired and the agency was exploring how to obtain the authority. OPM denied NRC’s request for DHA the year before because it determined that it does not apply to NRC’s already-excepted positions under the AEA. NRC decided to replicate its own version of DHA that follows OPM’s restrictions for hiring of certain occupational categories. While this increased flexibility for hiring managers, a 2023 OIG audit found confusion among staff, managers, and directors about which laws and internal policies applied to DHA.

Making Sense of the ADVANCE Act

As NRC updates guidance on its version of DHA for hiring managers, the ADVANCE Act provides NRC with more direction for hiring to the Excepted Service. The law creates new categories of hires for positions that fill critical needs related to licensing, regulatory oversight, or matters related to NRC efficiency if the chair and the Executive Director for Operations (EDO) agree on the need. It specifies that the hires should be diverse in career level and have salaries commensurate with experience, with a maximum matching level III of the Executive Schedule. Additional limitations on the number of hires fall into two categories. The first category limits use of the authority to 210 hires at any time. The second category limits use of the authority to an additional 20 hires each fiscal year which are limited to a term of four years. The total number of staff serving at one time under the second category could reach 80 appointments if the authority is used to the maximum over four consecutive years. If NRC maximizes hiring in both categories each year for at least 4 years, the total number of staff serving at one time could reach 290, which is almost 7% of the current total NRC workforce. Several analyses and press releases mischaracterized or overlooked the specifics of these provisions, reporting the total number of 120 for the number of appointments in the first category, which could be a typo of 210 or a figure derived from a prior draft version of the bill. Appropriations are provided in NRC’s normal process of budget recovery through fees charged to license applicants.

The Regulatory Workforce for the Next Generation of Nuclear Power Plants

The capacity of the NRC to license new nuclear power plants and provide oversight to a larger number of operating reactors impacts the viability of nuclear power as part of the U.S.’s abundant and reliable energy system. For decades, the AEA has provided NRC staff with unique flexibility to shape a workforce to regulate the civilian nuclear energy and protect people and the environment. Under recent direction and specificity from Congress, the EDO should not hesitate to hire staff in new, specialized positions across the agency that are dedicated to implementing updates to licensing and oversight as mandated by the ADVANCE Act. In parallel, the EDO should work with the Office of Human Resources to promote NRC’s version of DHA to hiring managers more widely to solve long-standing hiring challenges for hard-to-recruit positions. Effective use of NRC’s broad hiring flexibilities are critical to realizing the next generation of nuclear energy deployment.

The Inflation Reduction Act (IRA) is the largest climate investment in history. FAS scientists offer policy ideas to maximize the impacts of this investment on U.S. competitiveness, energy security, resilience, and more.

Washington, D.C. – August 16, 2024 – The Federation of American Scientists (FAS), the non-partisan, nonprofit science think tank dedicated to using evidence-based science for the public good, is celebrating the two-year anniversary of the signing of the Inflation Reduction Act (IRA) by sharing policy ideas to drive continued successful implementation of this landmark legislation.

The IRA is a United States federal law which aims to reduce the federal government budget deficit, lower prescription drug prices, and invest in domestic energy production while promoting clean energy. It was passed by the 117th United States Congress and it was signed into law by President Biden on August 16, 2022. The IRA has catalyzed $265 billion in new clean energy investments and created hundreds of thousands of jobs in the United States, putting us on a path to achieving climate goals while boosting the economy. 

“In just two years, the Inflation Reduction Act has driven down costs of energy and transportation for everyday Americans while reining in catastrophic climate change” says Hannah Safford, Associate Director of Climate and Environment. “This legislation proves that when we invest in a better future, everyone wins.”

“The IRA enables the country to move toward ambitious climate goals. We already see the effects with new policy proposal ideas that could supercharge pursuit of these goals,” says Kelly Fleming, Associate Director of Clean Energy. “The Department of Energy finds that with the Inflation Reduction Act and Bipartisan Infrastructure Law, we can double the share of clean electricity generation to 80% in 2030.”

FAS, one of the country’s oldest science policy organizations, works with scientists and technologists to propose policy-ready ideas to address current and emerging threats, including climate change and energy insecurity.  

On today’s two-year anniversary of the IRA, FAS is highlighting policy proposals that build on the IRA’s successes to date and suggest opportunities for continued impact. Examples include:

Geothermal 

Geothermal technologies became eligible for tax credits under IRA.

Breaking Ground on Next-Generation Geothermal Energy The Department of Energy (DOE) could take a number of different approaches to accelerating progress in next-generation geothermal energy, from leasing agency land for project development to providing milestone payments for the costly drilling phases of development.

Low-Carbon Cement 

The IRA provides $4.5B to support government procurement of low-carbon  versions of this cornerstone material.

Laying the Foundation for the Low-Carbon Cement and Concrete Industry Cement and concrete production is one of the hardest industries to decarbonize. Using its Other Transactions Authority, DOE could design a demand-support program involving double-sided auctions, contracts for difference, or price and volume. 

Critical Minerals and Energy Manufacturing

Supply chains necessary for battery technologies are being built out in the U.S. thanks to IRA incentives. The new Manufacturing and Energy Supply Chain Office (MESC) has implemented and unveiled programs to retool existing facilities for EV manufacturing, and rehire existing work, and provide tax incentives for clean energy manufacturing facilities with funding provided in the IRA. The office supports the development and deployment of a domestic clean energy supply chain, including for critical minerals needed for batteries and other advanced technologies.

Critical Thinking on Critical Minerals: How the U.S. Government Can Support the Development of Domestic Production Capacity for the Battery Supply Chain Batteries for electric vehicles, in particular, will require the U.S. to consume an order of magnitude more lithium, nickel, cobalt, and graphite than it currently consumes.

Nature Based Solutions

Billions of dollars have been invested into nature based solutions, including $1 billion in urban forestry, that will make communities more resilient to climate change.

A National Framework For Sustainable Urban Forestry To Combat Extreme Heat. To realize the full benefits of the federal government’s investment in urban forestry, there will need to be a coordinated, equity-focused, and economically validated federal plan to guide the development and maintenance of urban forestry that will allow the full utilization of this critical resource.

Submit Your Science and Technology Policy Ideas

The IRA is one lever to make real-world change; good ideas can come from anyone, including you.

FAS is soliciting federal policy ideas to present to the next U.S. presidential administration through the Day One 2025 project, which closes soon. Interested parties can submit science and technology related policy ideas year-round at FAS’s Day One website page.

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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 dramatic progress, 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 work on behalf of a safer, more equitable, and more peaceful world. More information at fas.org.

The Foundation for Energy Security and Innovation is now a reality: an affiliated but autonomous non-profit organization authorized by Congress to support the mission of the U.S. Department of Energy and to accelerate the commercialization of energy technologies. FESI’s establishment was a vital first step, but its value depends on what happens next. In order to maximize FESI’s impact, the board and staff should think big from the start, identify unique high-leverage opportunities to complement DOE’s work, and systematically build the capacity to realize them. This memo suggests that:

1. FESI should align with DOE’s energy mission,
2. FESI should serve as catalyst and incubator of initiatives that advance this mission, especially initiatives that drive public-private technology partnerships, and
3. FESI should develop lean and highly-networked operational capabilities that enable it to perform these functions well.

Three appendices to this memo provide background information on FESI’s genesis, excerpt its authorizing legislation, and link to other federal agency-affiliated foundations and resources about them.

Thinking Big: FESI’s Core Mission

DOE is responsible for managing the nation’s nuclear stockpile, cleaning up the legacy of past nuclear weapons development, and advancing basic scientific research as well as transforming the nation’s energy system. Although FESI’s authorizing legislation allows it to support DOE in carrying out the Department’s entire mission [Partnerships for Energy Security and Innovation Act Section b(3)(A)], the detailed description of FESI’s purposes [Sections b(1)(B)(ii), b(3)(B)] and the qualifications specified for its board members [Section b(2)(B)] signal that Congress viewed the energy mission as FESI’s primary focus. This conclusion is also supported by the hearing testimony gathered by the House Science Committee.

“Catalyz[ing] the timely, material, and efficient transformation of the nation’s energy system and secur[ing] U.S. leadership in energy technologies,” the two pillars of DOE’s energy mission, are extremely challenging responsibilities. The energy system makes up about 6% of the U.S. economy, or about $4000 per person per year, and its importance outweighs this financial value. This system keeps Americans warm in the winter and cool in the summer, gets us to our jobs and schools, and allows us to work, learn, and enjoy life. The system’s transformation to cleaner and more secure resources must not interrupt the affordable and reliable provision of these and many other vital services.

In addition to posing daunting system management challenges, the incipient energy transition is testing America’s global technological leadership. The United States now leads the world in oil and natural gas production, thanks in part to breakthroughs enabled by DOE. But the risks imposed by the use of conventional energy resources have risen. Other nations, notably China and Russia, have taken aggressive actions to establish leadership positions in new energy technologies, such as advanced nuclear power, solar panels, and lithium-ion batteries. DOE is tasked with reclaiming these fields.

DOE’s ambitious energy mission would benefit more from FESI’s support than would DOE’s other responsibilities. The energy system, unlike the nuclear stockpile or cleanup, and to a far greater extent than basic science, lies outside federal control. To transform it and secure global leadership in key technologies, DOE will have to collaborate closely with the private sector, philanthropy, and non-profits. Strengthening such collaboration, particularly to accelerate commercialization of energy technologies, is precisely the purpose specified for FESI by Congress. [Sections b(1)(B)(ii); b(3)(B)(i)]

FESI’s alignment with DOE’s energy mission should be resilient to changes in Congress and the administration. Its authorizing legislation was sponsored by members of both parties across three Congresses and won overwhelming majorities when voted on as a freestanding bill. By law, a majority of its board members must have experience in the energy sector, research, or  technology commercialization [Section b(2)(B)(iii)(III)] FESI will have difficulty building strong collaborations and thus achieving its congressional mandate unless it is seen as a long-term partner with a clear and stable mission.

Filter, Catalyst, and Incubator: FESI’s Core Functions

DOE brings many assets to its mission of energy system transformation and global technological leadership. It invests over $9 billion per year in energy research, development, and demonstration, far more than any other entity in the world. Its network of 17 national laboratories and thousands of academic collaborators converts those funds into a vast store of knowledge and opportunities for real-world impact. It possesses financial and regulatory tools that allow it to shape energy markets to varying degrees.

FESI’s responsibility – and opportunity – is to help DOE use these assets to more effectively advance its energy mission. More effective public-private partnerships to accelerate technology commercialization, including such dimensions as technology maturation, new product development, and regional economic development [Sections b(3)(B)(ii), (iii), and (v)] will be an enduring priority. But the specific use-cases and projects that FESI invests in will change as the global energy landscape does. Indeed, the dynamic nature of that landscape, along with structural constraints on DOE, is a key justification for FESI’s creation. FESI must develop processes that enable it to quickly identify and act on points of leverage that enhance the impact of DOE’s assets in a rapidly-changing system.

These processes should perform three vital functions, all of which will benefit from collaboration between FESI and the national laboratory-affiliated foundations [Section b(4)(G)].  The first is to serve as a filter that helps DOE gather and sift valuable insights about the global energy landscape that the department’s leadership might otherwise miss. Information flows in a large bureaucracy like DOE are inevitably shaped by its organizational structure. The structure of DOE’s energy-focused units and the national labs is in many respects a legacy of the times in which they were established and does not map well to today’s energy system. In addition, DOE’s immense scale means that the voices of newer and less powerful players in the system, such as start-up companies and community groups, may be drowned out. Some voices of the grassroots internal to DOE and the labs may also be hard to discern at the leadership level. The Secretary of Energy’s Advisory Board helps to fill these gaps, but it is constrained by the Federal Advisory Committee Act and other laws and regulations. FESI’s flexibility, bipartisan character, and non-governmental status, bolstered by a strong relationship with the lab foundations, will allow it to recognize DOE’s blind spots, whether internal or external. 

FESI should draw on this new or neglected information to perform the second function: catalyzing actionable opportunities that advance DOE’s energy mission. It can develop these opportunities (jointly, as appropriate, with one or more lab foundations) by convening a broad range of stakeholders in formats that DOE cannot effectively utilize and at a pace that DOE cannot match. For example, a group of firms in an emerging clean energy industry may identify a shared technological need that international competitors are pursuing aggressively. FESI could support these firms to articulate their need, identify DOE-affiliated assets that could address it, and rapidly assemble a public-private partnership that aligns the two. Such a partnership might have a regional focus and engage state and local governments and regionally-focused philanthropy as well. If FESI’s information filter were to pick up unrecognized obstacles to effective community engagement or lack of attention to end-user priorities, it could assemble cross-sectoral partnerships appropriate to those opportunities. The catalyst function could be particularly important for crisis response, when speed and agility are essential, and DOE’s formal processes are likely to slow the agency down. 

FESI’s third core function should be to incubate and ultimately spin out the initiatives that it has catalyzed. The process of assembling each initiative will require FESI to provide basic administrative support, like internal communication and coordination. FESI should frequently go several steps further by raising seed funding for each initiative, particularly from non-governmental sources, and serving as its external champion. FESI should not, however, become the permanent home of mature partnerships. The managerial demands imposed by carrying out this function risk undermining the filter and catalyst functions. Spinning out the successes will permit FESI’s leadership to hunt more effectively for new opportunities. The destination for the spinoffs might be new or expanded programs within DOE, an existing non-profit like an industry consortium or community foundation, or a new organization.

Lean and Intensely Networked: FESI’s Operational Capabilities

FESI’s high ambition, dynamic functions, and unique institutional position determine the capabilities it will need to operate effectively. Above all, it must be plugged intensively into a broad network that spans the energy industry; DOE and the national labs; states, communities, and Congress; and philanthropy. FESI will only be able to spot what DOE could do better by having a savvy understanding of what DOE is already doing and what its potential partners want to be doing. FESI must be able to gather and interpret this information continuously at a modest cost, which puts a premium on networking. 

FESI board members must be vital nodes of its network. FESI’s authorizing statute specifies that the board represent “a broad cross-section of stakeholders.” The members will hold positions that provide insights and contacts of value to FESI and should be selected to build and maintain the network’s breadth. The board’s ex officio representatives from DOE will provide complementary perspectives and connections inside the Department. FESI’s staff will only have the knowledge and resources required to do their jobs well if the entire board is active and engaged (but not micro-managing the staff).

FESI’s staff should be led by an executive director who is responsible for its day-to-day operations [Section b(5)(A)] and has high credibility throughout the energy system and with both political parties. Staff members should bring sector-spanning networks to the organization that leverage those of the board. Even more important, the staff must possess the entrepreneurial skills, and technological and market knowledge, to recognize and act on promising opportunities. Prior experience in business, social, or public entrepreneurship – building new companies, non-profit organizations, and government programs – is likely to be particularly valuable to FESI.

Running lean should be a value for a FESI and will likely be a necessity as well. The value lies in taking initiative and moving quickly. The necessity arises from the likely limits on federal appropriations for operations, which are  authorized at $3 million annually [Section b(11)] and may not rise to that level. To be sure, FESI must raise resources from non-federal sources – indeed, that will be one of its core challenges. But those resources are likely to be much easier to raise if they are devoted to projects rather than operations. 

Finally, FESI will need to mitigate risks to its reputation that might arise from real and perceived conflicts of interest of the board and staff as well as from the images and interests of its potential partners. A pristine reputation will be vital to maintaining the confidence of DOE, Congress, and external stakeholders. FESI should seek to reduce the cost in money and time of rigorous vetting and disclosure, but ultimately this investment is an essential one that must be borne.

Appendix 1. A Brief Prehistory of FESI

• The immediate genesis of FESI’s authorizing legislation was idea #22 in this 2016 ITIF report. 
• ITIF and its partners socialized the concept beginning in the 115^th Congress, including at this 2018 event, which featured Reps. Fleischmann (current chair of the House Energy & Water Development appropriations subcommittee) and Lujan (now Senator from New Mexico)
• During the same Congress, Rep. Lujan and Sen. Coons authored the first bills to authorize a DOE-affiliated foundation, which were co-sponsored on a bipartisan basis, a pattern that was sustained through the concept’s ultimate passage.
• Jetta Wong took the lead role along with me in driving the foundation initiative for ITIF during the 116^th Congress (2019-2020). That work included two stakeholder workshops and extensive interview and documentary research, leading to our 2020 “Mind the Gap” report, which provides our fullest vision for the foundation’s potential role in innovation and commercialization. 
• In July 2020, Jetta testified on the foundation before the House Science Committee along with Jennifer States (Maritime Blue), Farah Benahmed (Breakthrough Energy), Emily Reichert (Greentown Labs), and Lee Cheatham (PNNL)
• Our work led to an appropriations report that required DOE to sponsor a study by the National Academy of Public Administration, which was issued in January 2021. This report has a good round-up of other agency foundations, as does the 2019 CRS report on the topic
• The Partnerships for Energy Security and Innovation Act, sponsored by Rep. Stansbury and Sen. Coons in the 117^th Congress, won an 83-14 vote in the Senate in 2021, passed the House in early 2022, and was ultimately incorporated into the August 2022 CHIPS and Science Act. The Act passed just after Jetta joined the administration; I partnered with Kerry Duggan of SustainabiliD for the next phase of work. Our August 2022 blog post provides a good synopsis of the effort up to the bill’s passage.
• With SustainabiliD and later with the Federation of American Scientists and with support from Schmidt Futures and Breakthrough Energy, the “Friends of FESI” focused on sustaining support for FESI and generating project ideas.
  • Jetta joined the panel on FESI at the 2023 ARPA-E summit, where DOE held its first public events on FESI, and we participated in the workshop that DOE organized there.
  • We responded to DOE’s RFI on FESI, along with several other NGOs. We also focused on FESI in a response to to DOE’s RFI on place-based innovation.
  • We developed a set of broad use-cases and held two workshops, one on geothermal energy and the other on “fast track” commercialization.
  • We worked with supporters and allies to secure FESI’s appropriation

Appendix 2. Other Federal Agency-Affiliated and National Laboratory Foundations

Numerous federal agencies have Congressionally authorized non-governmental foundations that work with them to advance their missions. The National Park Foundation (NPF) is the oldest, dating back to 1935. Anyone who wants to support a particular national park, or the system as a whole, can do so through a contribution to NPF. Similarly, donors who care about public health can give to the CDC Foundation (CDC Foundation) or the Foundation for NIH (FNIH). A 2021 report by the National Academy of Public Administration (NAPA), which recommended establishing a foundation for DOE, reviews a wide range of agency-related foundations, as does the 2020 ITIF “Mind the Gap” report and a 2019 CRS report.

As the NAPA report describes, all of these foundations leverage federal investment with private contributions to complement and supplement their agency affiliate, while guarding against potential conflict of interest. Yet, more remarkable than this commonality among is the foundations’ diversity. Each seeks to complement and supplement its partner agency, but because each agency has a different mission, structure, and functions, each affiliated foundation is unique.

FESI will likely have much in common with the FNIH. Like NIH, DOE is a major research funder that advances a critical national mission. Like NIH, DOE must rely on the private sector to turn advances made possible by the R&D it funds into technologies that make a difference on the ground. FNIH’s contributions to fighting the pandemic illustrate how having a flexible non-profit partner for an agency can advance the agency’s mission in a moment of need. Its Pandemic Response Fund and Accelerating COVID-19 Therapeutic Interventions and Vaccines (ACTIV) partnership with NIH, private firms, other federal agencies, and allied governments, aids the search for treatments and vaccines and prepares the nation to defend against future pandemics.

The Foundation for Food and Agriculture Research, which is affiliated with the U.S. Department of Agriculture, is another potential source of inspiration and learning for FESI. One notable innovation made by FFAR is its use of prizes and challenges, along with more traditional competitive, cost-shared grants. To ensure technologies can scale, FFAR brings industry experts into its project design and administration. In a review of the FFAR’s progress, the Boston Consulting Group (BGC) found that FFAR’s “Congressional funding allows it to bring partners to the table and serve as an independent, neutral third party.” 

Links to agency-affiliated foundations not linked above:

• Foundation for America’s Public Lands (Interior/Bureau of Land Management)
• Henry M. Jackson Foundation for the Advancement of Military Medicine (DOD)
• National Association of Veterans’ Research and Education Foundations (VA)
• National Fish and Wildlife Foundation (Interior/Fish and Wildlife Service and NOAA)
• National Forest Foundation (Interior/US Forest Service)
• Reagan-Udall Foundation for the FDA (Food and Drug Administration)

Appendix 3. Selected Provisions of FESI’s Authorizing Statute¹

Partnerships for Energy Security and Innovation (42 USC 19281)

CHIPS AND SCIENCE ACT SEC. 10691. FOUNDATION FOR ENERGY SECURITY AND INNOVATION

(b)(1)(B) MISSION.—The mission of the Foundation shall be—

(i) to support the mission of the Department; and

(ii) to advance collaboration with energy researchers, institutions of higher education, industry, and nonprofit and philanthropic organizations to accelerate the commercialization of energy technologies.

(b)(2)(B)(iii)(II) REPRESENTATION.—The appointed members of the Board shall reflect a broad cross-section of stakeholders from academia, National Laboratories, industry, nonprofit organizations, State or local governments, the investment community, and the philanthropic community.

(III) EXPERIENCE.—The Secretary shall ensure that a majority of the appointed members of the

Board— (aa)(AA) has experience in the energy sector; (BB) has research experience in the

energy field; or (CC) has experience in technology commercialization or foundation operations;

and (bb) to the extent practicable, represents diverse regions, sectors, and communities.

(b)(3) PURPOSES.—The purposes of the Foundation are—

(A) to support the Department in carrying out the mission of the Department to ensure the security and prosperity of the United States by addressing energy and environmental challenges through transformative science and technology solutions; and

(B) to increase private and philanthropic sector investments that support efforts to create, characterize, develop, test, validate, and deploy or commercialize innovative technologies that address crosscutting national energy challenges, including those affecting minority, rural, and other

underserved communities, by methods that include—

(i) fostering collaboration and partnerships with researchers from the Federal Government, State 

governments, institutions of higher education, including historically Black colleges or universities,

Tribal Colleges or Universities, and minority-serving institutions, federally funded research and development centers, industry, and nonprofit organizations for the research, development, or commercialization of transformative energy and associated technologies;

(ii) strengthening and sharing best practices relating to regional economic development through scientific and energy innovation, including in partnership with an Individual Laboratory-Associated Foundation;

(iii) promoting new product development that supports job creation;

(iv) administering prize competitions—

(I) to accelerate private sector competition and investment; and

(II) that complement the use of prize authority by the Department;

(v) supporting programs that advance technology maturation, especially where there may be gaps in Federal or private funding in advancing a technology to deployment or commercialization from the prototype stage to a commercial stage;

(vi) supporting efforts to broaden participation in energy technology development among individuals from historically underrepresented groups or regions; and

(vii) facilitating access to Department facilities, equipment, and expertise to assist in tackling national challenges.

(b)(4)(G) INDIVIDUAL AND FEDERAL LABORATORY-ASSOCIATED FOUNDATIONS.—

(ii) SUPPORT.—The Foundation shall provide support to and collaborate with covered foundations.

(iv) AFFILIATIONS.—Nothing in this subparagraph requires—

(I) an existing Individual Laboratory-Associated Foundation to modify current practices or

affiliate with the Foundation

(b)(5)(I) INTEGRITY.—

(i) IN GENERAL.—To ensure integrity in the operations of the Foundation, the Board shall develop and enforce procedures relating to standards of conduct, financial disclosure statements, conflicts of interest (including recusal and waiver rules), audits, and any other matters determined appropriate by the Board.

(b)(6) DEPARTMENT COLLABORATION.—

(A) NATIONAL LABORATORIES.—The Secretary shall collaborate with the Foundation to develop a process to ensure collaboration and coordination between the Department, the Foundation, and National Laboratories

The Department of Energy (DOE) announced recently that it will finance the restart of a nuclear power plant through a new program to revitalize energy infrastructure and reduce greenhouse gas emissions. Restarting the Palisades Nuclear Power Plant, which was shut down in 2022, will be the first restarted nuclear power plant in U.S. history, bringing back much needed clean firm energy supply to Michigan, Illinois, and Indiana. DOE estimates that the addition of this clean capacity will prevent yearly emissions equivalent to that emitted by nearly one million gas-powered cars. The plant owners also shared intentions to use existing infrastructure to build two small modular reactors, a newer type of reactor technology that can be deployed more flexibly than existing commercial light-water reactors. DOE’s announcement is a significant step in addressing emerging energy needs and reducing emissions, but more is needed to ensure a successful plant restart and to expand clean energy capacity broadly.

Nuclear power was commercialized in the U.S. in the 1950s, and electricity generated by this technology accounts today for about 19% of the country’s electricity supply. Nuclear is a baseload power source, also called clean firm power, that complements generation from intermittent sources such as wind and solar energy. But in many cases, nuclear energy struggles to compete economically with other energy sources. The original decision to close the Palisades was primarily financial. Consumers Energy, the utility that purchased energy from the plant, intended to replace the nuclear energy with natural gas, which is ample and inexpensive. The dynamic is not unique—utilities are using more fossil fuels as the grid attempts to respond to a rapid increase in demand. But commercial light-water reactors, like those at the Palisades, are the most mature clean technology option to meet near-term energy needs while reducing emissions. The federal government should shape the market for nuclear power, or risk more plants shutting down—and making ambitious emissions reductions goals likely impossible to meet. 

The conditional commitment from the DOE Loan Programs Office (LPO) to finance the Palisades restart ensures nuclear power is cost-competitive, and this particular type of loan is an important tool for DOE to develop and deploy more clean energy technologies. Since the loans are conditional on the companies meeting agreed-upon commitments, the arrangement allows DOE to closely monitor progress and halt funding if the project does not meet expectations. The LPO, established by Congress in 2005 to invest in critical energy and infrastructure projects, has found much success, especially with an increase in funding from the recent Inflation Reduction Act (IRA). Since the IRA passed in 2022, LPO has issued over $16 billion in conditional commitments and disbursed over $30 billion. The office’s approaches to lending seem to work well—for FY2023, they reported actual losses of only 3.1% of total funds disbursed. Other examples of recent conditional commitments include a real-time methane emissions monitoring network and a solar energy storage microgrid, reflecting investments across key clean energy technologies. But the Palisades commitment is unique as it is the first issued through DOE’s Energy Infrastructure Reinvestment program, which has $250 billion available to fund clean energy projects that revitalize or replace existing infrastructure. The $1.5 billion loan to Palisades will help fund refurbishment, upgrades, and testing to operate the plant for an estimated 25 years. Since the initial appropriations for this program expire in September of 2026, the DOE should act quickly to finance similar projects that revitalize existing infrastructure.

Outside of loans, the federal government can do more to support the restart and ensure other nuclear plants continue generating clean baseload energy for as long as safely possible. Next, the Nuclear Regulatory Commission (NRC) will need to amend the license of a plant it already classified in a state of decommissioning. The NRC formed the Palisades Restart Panel (PRP) to advise on the reviews required for this new regulatory situation. Although the primary objective of the PRP is to advise on the Palisades, NRC gave the panel the option to provide general recommendations if other licensees pursue a restart. Twenty other nuclear power reactor sites are in decommissioning status. To provide clarity to the nuclear industry on options for these sites, the panel should take advantage of this opportunity to advise generally on a process for restarts. The DOE should also signal whether it intends to make further investments in this area. This first-of-kind project could demonstrate that restarting plants is a fast and economical way to increase clean firm generating capacity.

Federal policymakers, agencies, and the private sector should consider additional options for expanding nuclear capacity at this moment when nuclear power is viewed favorably by most of the public and partisan division is low. For example, utilities could form consortiums to build multiple reactors of the same design, reducing risk and cost with the construction of each new reactor. The DOE could mass-acquire NRC permits on behalf of developers, or use the Foundation for Energy Security and Innovation (FESI) to accelerate licensing through stakeholder and community engagement. Congress could also consider categorical exclusions under the National Environmental Policy Act for actions that use existing energy infrastructure and have a net positive benefit to the environment, such as building nuclear power plants on former coal plant sites. The LPO has nearly $412 billion in loan authority to advance clean energy. It should continue to negotiate and award conditional commitments for more clean energy projects across the country, working closely with applicants and recipients to ensure adequate progress and effective use of taxpayer dollars. Other federal policymakers should keep momentum on DOE’s commitment to Palisades with further actions to keep nuclear power on the grid.

The United States is committed to the ambitious goal of reaching net-zero emissions globally by 2050, requiring rapid deployment of clean energy domestically and across the world. Reducing emissions while meeting energy demand requires firm power sources that produce energy at any time and in adverse weather conditions, unlike solar or wind energy. Advanced nuclear reactors, the newest generation of nuclear power plants, are firm energy sources that offer potential increases in efficiency and safety compared to traditional nuclear plants. Adding more nuclear power plants will help the United States meet energy demand while reducing emissions. Further, building advanced nuclear plants on the sites of former coal plants could create benefits for struggling coal communities and result in significant cost savings for project developers. Realizing these benefits for our environment, coal communities, and utilities requires coordinating and expanding existing efforts. The Foundation for Energy Security and Innovation (FESI), the US Department of Energy (DOE), and Congress should each take actions to align and strengthen advanced nuclear initiatives and engagement with coal communities in the project development process.

Challenge and Opportunity

Reducing carbon emissions while meeting energy demand will require the continued use of firm power sources. Coal power, once a major source of firm energy for the United States, has declined since 2009, due to federal and state commitments to clean energy and competition with other clean energy sources. Power generated from coal plants is expected to drop to half of current levels by 2050 as upwards of 100 plants retire. The DOE found that sites of retiring coal plants are promising candidates for advanced nuclear plants, considering the similarities in site requirements, the ability to reuse existing infrastructure, and the overlap in workforce needs. Advanced nuclear reactors are the next generation of nuclear technology that includes both small modular reactors (SMRs), which function similar to traditional light-water reactors except on a smaller site, and non-light-water reactors, which are also physically smaller but use different methods to control reactor temperature. However, the DOE’s study and additional analysis from the Bipartisan Policy Center also identified significant challenges to constructing new nuclear power plants, including the risk of cost overrun, licensing timeline uncertainties, and opposition from communities around plant sites. Congress took steps to promote advanced nuclear power in the Inflation Reduction Act and the CHIPS and Science Act, but more coordination is needed. To commercialize advanced nuclear to support our decarbonization goals, the DOE estimates that utilities must commit to deploying at least five advanced nuclear reactors of the same design by 2025. There are currently no agreements to do so. 

The Case for Coal to Nuclear

Coal-dependent communities and the estimated 37,000 people working in coal power plants could benefit from the construction of advanced nuclear reactors. Benefits include the potential addition of more than 650 jobs, about 15% higher pay on average, and the ability for some of the existing workforce to transition without additional experience, training, or certification. Jobs in nuclear energy also experience fewer fatal accidents, minor injuries, and harmful exposures than jobs in coal plants. Advanced nuclear energy could revitalize coal communities, which have suffered labor shocks and population decline since the 1980s. By embracing advanced nuclear power, these communities can reap economic benefits and create a pathway toward a sustainable and prosperous future. For instance, in one case study by the DOE, replacing a 924 MWe coal plant with nuclear increased regional economic activity by $275 million. Before benefits are realized, project developers must partner with local communities and other stakeholders to align interests and gain public support so that they may secure agreements for coal-to-nuclear transition projects.

Communities living near existing nuclear plants tend to view nuclear power more favorably than those who do not, but gaining acceptance to construct new plants in communities less familiar with nuclear energy is challenging. Past efforts using a top-down approach were met with resistance and created a legacy of mistrust between communities and the nuclear industry. Stakeholders can slow or stop nuclear construction through lawsuits and lengthy studies under the National Environmental Policy Act (NEPA), and 12 states have restrictions or total bans on new nuclear construction. Absent changes to the licensing and regulatory process, project developers must mitigate this risk through a process of meaningful stakeholder and community engagement. A just transition from coal to nuclear energy production requires developers to listen and respond to local communities’ concerns and needs through the process of planning, siting, licensing, design, construction, and eventual decommissioning. Project developers need guidance and collective learning to update the siting process with more earnest practices of engagement with the public and stakeholders. Coal communities also need support in transitioning a workforce for nuclear reactor operations.

Strengthen and Align Existing Efforts

Nuclear energy companies, utilities, the DOE, and researchers are already exploring community engagement and considering labor transitions for advanced nuclear power plants. NuScale Power, TerraPower, and X-energy are leading in both the technical development of advanced nuclear and in considerations of community benefits and stakeholder management. The Utah Associated Municipal Power Systems (UAMPS), which is hosting NuScale’s demonstration SMR, spent decades engaging with communities across 49 utilities over seven states before signing an agreement with NuScale. Their carbon-free power project involved over 200 public meetings, resulting in several member utilities choosing to pursue SMRs. Universities are collaborating with the Idaho National Laboratory to analyze energy markets using a multidisciplinary framework that considers community values, resources, capabilities, and infrastructure. Coordinated efforts by researchers near the TerraPower Natrium demonstration site investigate how local communities view the cost, benefits, procedures, and justice elements of the project. 

The DOE also works to improve stakeholder and community engagement across multiple offices and initiatives. Most notably, the Office of Nuclear Energy is using a consent-based siting process, developed with extensive public input, to select sites for interim storage and disposal of spent nuclear fuel. The office distributed $26 million to universities, nonprofits, and private partners to facilitate engagement with communities considering the costs and benefits of hosting a spent fuel site. DOE requires all recipients of funds from the Infrastructure Investment and Jobs Act and the Inflation Reduction Act, including companies hosting advanced nuclear demonstration projects, to submit community benefits plans outlining community and labor organization engagement. The DOE’s new Commercial Liftoff Reports for advanced nuclear and other clean energy technologies are detailed and actionable policy documents strengthened by the inclusion of critical societal considerations.

Through the CHIPS and Science Act, Congress established or expanded DOE programs that promote both the development of advanced nuclear on sites of former coal plants and the research of public engagement for nuclear energy. The Nuclear Energy University Program (NEUP) has funded technical nuclear energy research at universities since 2009. The CHIPS Act expanded the program to include research that supports community engagement, participation, and confidence in nuclear energy. The Act also established, but did not fund, a new advanced nuclear technology development program that prioritizes projects at sites of retiring coal plants and those that include elements of workforce development. An expansion of an existing nuclear energy training program was cut from the final CHIPS Act, but the expansion is proposed again in the Nuclear Fuel Security Act of 2023.

More coordination is required among DOE, the nuclear industry, and utilities. Congress should also take action to fund initiatives authorized by recent legislation that enable the coal-to-nuclear transition.

Plan of Action

Recommendations for Federal Agencies

Recommendation 1. A sizable coordinating body, such as the Foundation for Energy Security and Innovation (FESI) or the Appalachian Regional Commission (ARC), should support the project developer’s efforts to include community engagement in the siting, planning, design, and construction process of advanced nuclear power plants. 

FESI is a new foundation to help the DOE commercialize energy technology by supporting and coordinating stakeholder groups. ARC is a partnership between the federal government and Appalachian states that supports economic development through grantmaking and conducting research on issues related to the region’s challenges. FESI and ARC are coordinating bodies that can connect disparate efforts by developers, academic experts, and the DOE through various enabling and connecting initiatives. Efforts should leverage existing resources on consent-based siting processes developed by the DOE. While these processes are specific to siting spent nuclear fuel storage facilities, the roadmap and sequencing elements can be replicated for other goals. Stage 1 of the DOE’s planning and capacity-building process focuses on building relationships with communities and stakeholders and engaging in mutual learning about the topic. FESI or ARC can establish programs and activities to support planning and capacity building by utilities and the nuclear industry.

FESI could pursue activities such as: 

• Hosting a community of practice for public engagement staff at utilities and nuclear energy companies, experts in public engagement methods design, and the Department of Energy
• Conducting activities such as stakeholder analysis, community interest surveys, and engagement to determine community needs and concerns, across all coal communities
• Providing technical assistance on community engagement methods and strategies to utilities and nuclear energy companies

ARC could conduct studies such as stakeholder analysis and community interest surveys to determine community needs and concerns across Appalachian coal communities.

Recommendation 2. The DOE should continue expanding the Nuclear Energy University Program (NEUP) to fund programs that support nontechnical nuclear research in the social sciences or law that can support community engagement, participation, and confidence in nuclear energy systems, including the navigation of the licensing required for advanced reactor deployment.

Evolving processes to include effective community engagement will require new knowledge in the social sciences and shifting the culture of nuclear education and training. Since 2009, the DOE Office of Nuclear Energy has supported nuclear energy research and equipment upgrades at U.S. colleges and universities through the NEUP. Except for a few recent examples, including the University of Wyoming project cited above, most projects funded were scientific or technical. Congress recognized the importance of supporting research in nontechnical areas by authorizing the expansion of NEUP to include nontechnical nuclear research in the CHIPS and Science Act. DOE should not wait for additional appropriations to expand this program. Further, NEUP should encourage awardees to participate in communities of practice hosted by FESI or other bodies.

Recommendation 3. The DOE Office of Energy Jobs and the Department of Labor (DOL) should collaborate on the creation and dissemination of training standards focused on the nuclear plant jobs for which extensive training, licensing, or experience is required for former coal plant workers.

Sites of former coal plants are promising candidates for advanced nuclear reactors because most job roles are directly transferable. However, an estimated 23% of nuclear plant jobs—operators, senior managers, and some technicians—require extensive licensing from the Nuclear Regulatory Commission (NRC) and direct experience in nuclear roles. It is possible that an experienced coal plant operator and an entry-level nuclear hire would require the same training path to become an NRC-licensed nuclear plant operator. 

Supporting the clean energy workforce transition fits within existing priorities for the DOE’s Office of Energy Jobs and the DOL, as expressed in the memorandum of understanding signed on June 21, 2022. Section V.C. asserts the departments share joint responsibility for “supporting the creation and expansion of high-quality and equitable workforce development programs that connect new, incumbent, and displaced workers with quality energy infrastructure and supply chain jobs.” Job transition pathways and specific training needs will become apparent through additional studies by interested parties and lessons from programs such as the Advanced Reactor Demonstration Program and the Clean Energy Demonstration Program on Current and Former Mine Land. The departments should capture and synthesize this knowledge into standards from which industry and utilities can design targeted job transition programs.

Recommendations for Congress

Recommendation 4. Congress should fully appropriate key provisions of the CHIPS and Science Act to support coal communities’ transition to nuclear energy.

• Appropriate $800 million over FY2024 to FY2027 to establish the DOE Advanced Nuclear Technologies Federal Research, Development, and Demonstration Program: The CHIPS and Science Act established this program to promote the development of advanced nuclear reactors and prioritizes projects at sites of retiring coal power plants and those that include workforce development programs. These critical workforce training programs need direct funding.

• Appropriate an additional $15 million from FY2024 to FY2025 to the NEUP: The CHIPS and Science Act authorizes an additional $15 million from FY 2023 to FY 2025 to the NEUP within the Office of Nuclear Energy, increasing the annual total amount from $30 million to $45 million. Since CHIPS included an authorization to expand the program to include nontechnical nuclear research, the expansion should come with increased funding.

Recommendation 5. Congress should expand the Nuclear Energy Graduate Traineeship Subprogram to include workforce development through community colleges, trade schools, apprenticeships, and pre-apprenticeships.

The current Traineeship Subprogram supports workforce development and advanced training through universities only. Expanding this direct funding for job training through community colleges, trade schools, and apprenticeships will support utilities’ and industries’ efforts to transition the coal workforce into advanced nuclear jobs.

Recommendation 6. Congress should amend Section 45U, the Nuclear Production Tax Credit for existing nuclear plants, to require apprenticeship requirements similar to those for future advanced nuclear plants covered under Section 45Y, the Clean Energy Production Tax Credit.

Starting in 2025, new nuclear power plant projects will be eligible for the New Clean Energy Production and Investment Tax Credits if they meet certain apprenticeship requirements. However, plants established before 2025 will not be eligible for these incentives. Congress should add apprenticeship requirements to the Nuclear Production Tax Credit so that activities at existing plants strengthen the total nuclear workforce. Credits should be awarded with priority to companies implementing apprenticeship programs designed for former coal industry workers.

Conclusion

The ambitious goal of reaching net-zero emissions globally requires the rapid deployment of clean energy technologies, in particular firm clean energy such as advanced nuclear power. Since the 1980s, communities around coal power plants have suffered from industry shifts and will continue to accumulate disadvantages without support. Coal-to-nuclear transition projects advance the nation’s decarbonization efforts while creating benefits for developers and revitalizing coal communities. Utilities, the nuclear industry, the DOE, and researchers are advancing community engagement practices and methods, but more effort is required to share best practices and ensure coordination in these emerging practices. FESI or other large coordinating bodies should fill this gap by hosting communities of practice, producing knowledge on community values and attitudes, or providing technical assistance. DOE should continue to promote community engagement research and help articulate workforce development needs. Congress should fully fund initiatives authorized by recent legislation to promote the coal to nuclear transition. Action now will ensure that our clean firm power needs are met and that coal communities benefit from the clean energy transition.

Recent crises, such as the pandemic and the Russia-Ukraine war, have led to volatile fossil fuel prices and raised national concerns about energy security. The growing frequency of blackouts across the country due to extreme weather points to an increasingly vulnerable and aging electric grid. Grid capacity right now is incapable of supporting the rapid deployment of renewable energy projects that can generate clean, reliable, domestic energy. Further, as global competition rises, the United States finds itself overly reliant on foreign manufacturing and supply chains for these very technologies we want to deploy.

In order to improve energy security, affordability, and reliability for everyday Americans, the 118th Congress should act decisively to strengthen our energy infrastructure while leveraging emerging energy technology for the energy system of the future. Below are some recommendations for action.

Transmission Lines. The current U.S. electrical grid is an aging piece of infrastructure with sluggish growth and increasing vulnerability to threats from extreme weather and foreign attacks. The 118th Congress should implement policies to revitalize domestic manufacturing and construction, strengthen national energy security and reliability, and generate new jobs and economic growth. The $83 billion worth of planned transmission projects that the ISO/RTO Board has approved or recommended is projected to add $42 billion to U.S. GDP, create more than 400,000 well-paying jobs, and boost direct local spending by nearly $40 billion. However, the rate of construction for new transmission lines must substantially increase to fully harness the new energy economy and achieve ambitious emissions reductions.

High voltage direct current (HVDC) transmission lines are particularly important for connecting renewable energy producing regions with low demand, such as the Southwest and Midwest, to high demand regions. At these distances greater than 300 miles, HVDC transmission lines transmit power with fewer losses than AC lines. HVDC lines can also avoid some of the challenges to AC transmission line development because they can be buried underground, eliminating resident concerns of visual pollution and avoiding vulnerability to extreme weather. Further, if HVDC lines are built along existing rail corridors, their construction only requires negotiation with the seven major American rail companies rather than a myriad of private landowners and federal land management agencies. Congress took an important first step to advancing HVDC technology by directing DOE to develop an HVDC moonshot initiative on cost reduction, as part of the FY 2023 omnibus bill. Now, the 118th Congress can further support this goal by working with the Federal Energy Regulatory Commission (FERC) to eliminate regulatory obstacles preventing the private sector from building more of these lines along existing corridors. Congress should also create federal tax credits to stimulate domestic manufacturing and construction of HVDC transmission, as well as transmission line construction in general. 

Manufacturing. To spur domestic manufacturing capabilities and regain competitive advantages in clean energy technologies, the 118th Congress should fund a new manufacturing-focused branch of DOE’s highly effective State Energy Program (SEP). Congress can double down on this action by scaling investments in domestic capacity to manufacture key industrial products, such as low-carbon cement and steel.

Workforce. Our nation needs a workforce equipped with the skills to build a robust energy economy. To that end, Congress could provide the Department of Energy (DOE) with $30 million annually to establish an Energy Extension System (EES). Modeled after the USDA’s Cooperative Extension System (CES), and in partnership with the DOE’s National Labs, the EES would provide technical assistance to help institutions and individuals across the country take full advantage of emerging opportunities in the energy economy, including carbon capture and storage (CCS), installation and maintenance of electric vehicle (EV) charging infrastructure, geothermal power, and more. 

Permitting Reform. In order to improve government efficiency, reduce costs, and enable the construction of new infrastructure for the clean energy transition, the 118th Congress should pass legislation on permitting reform to improve National Environmental Policy Act (NEPA) compliance timelines. These reforms should include:

• Shortening the statute of limitations on litigation under NEPA to 6 months or less in order to be more consistent with state-level policies;
• Requiring that any public-interest group bringing a case against a NEPA decision to have submitted input during public comment periods;
• Clarifying the duties of federal, state, tribal and local governments when conducting environmental reviews and communicating information to project applicants and the public;
• Clarifying vague statutes, such as the requirement that agencies consider “all reasonable alternatives”;
• Clarifying the appropriate admissibility or substitutability of documents that may reduce burdens on executive staff; and
• Permitting fast-track approval to site zero-emission fueling stations (see next section), in consultation with local utility regulators.

Zero-Emission Fueling Stations. Zero-emission vehicles powered by electric batteries and hydrogen fuel cells are the future of American auto manufacturing. The 118th Congress should pass key legislation to provide the federal government and states with the authorities and resources necessary to build a nationwide network of zero-emission fueling stations, so these new vehicles can refuel anywhere in the country. This includes:

• Amending Title 23 in the United States Code so that the federal government and states can apply gas tax dollars towards funding zero-emission fueling stations;
• Directing the Department of Transportation to use “Jason’s Law” surveys to identify medium- and heavy-duty vehicle parking locations that should be used for zero-emission fueling stations; and
• Authorizing pilot programs and public-private partnerships to develop “best practices” and techniques with key stakeholders for building out a commercially viable nationwide network of zero-emission fueling stations.

Electricity Markets. Power grids are being transformed from simple, fixed energy sources and points of demand to complex webs that feature distributed energy storage, demand response, and power quality factors. “Qualifying facilities” are a special class of small power production facilities and cogeneration facilities created by the Power Utility Regulatory Policy Act (PURPA) of 1978 with the right to sell energy or capacity to a utility and purchase services from utilities while being relieved of certain regulatory burdens. The definition of “qualifying facilities” should be expanded beyond power generation facilities to include households and businesses that provide grid services (e.g., feeding power back to the grid during times of peak energy demand). This would ensure that utilities properly compensate customers if they supply these services, thus allowing individual Americans to participate in electricity markets and spurring the adoption of novel clean-energy technologies.

Geothermal Energy. The Earth’s crust holds more than enough untapped geothermal energy to meet U.S.energy needs. Yet, only 0.4% of U.S. electricity is generated by geothermal energy. There’s a major opportunity to leverage this emerging domestic source for U.S. consumers. Congress should support the Geothermal Earthshot and drive innovation by: 

• Establishing a $2 billion risk mitigation fund for geothermal energy development within the DOE’s Office of Energy Efficiency and Renewable Energy, modeled off of successful programs in Iceland, Costa Rica, and Kenya;
• Establishing a $450 million USDA Rural Development grant program to transition industrial cooling and heating systems in the agricultural sector to geothermal energy
• Expanding the authority of the Leaking Underground Storage Tank (LUST) Trust Fund within the EPA to include the conversion of existing and abandoned oil and gas fields into geothermal wells; and
• Provide $15 million for a national geothermal team within the Bureau of Land Management to develop training materials, standard operating procedures, and provide technical support to district offices to ensure timely review of geothermal power and cooling/heating projects on federal lands.

A policy memo on Empowering the Geothermal Earthshot is forthcoming from FAS.

Appropriations Recommendations

• CHIPS and Science: Research and Development in the Office of Science at the Department of EnergyA number of line items for basic science research at the Department of Energy (DOE) were authorized as part of the CHIPS and Science Act – including materials, physical, chemical, and others. These research programs are central to building a new wave of clean energy technologies and ensuring domestic energy security for decades to come. Subsections of this part of the bill include authorizations for research on nuclear energy, energy storage, carbon sequestration, and other technologies. We recommend that the Office of Science, and especially items in Section 10102 of the CHIPS and Science Act covering Basic Energy Sciences, be funded in alignment with the amounts authorized. 

• CHIPS and Science: Funding for the Office of Technology Transitions and prize authorized programs Two additional line items in the CHIPS and Science Act that were authorized but are not yet funded are sections 10713 and 10714. Both authorize prize programs housed in the Office of Technology Transitions (OTT) at the Department of Energy–programs that, if funded, could support innovation and commercialization of clean energy technology. Section 10713 authorizes an awards program for clean energy startup incubators, and section 10714 authorizes a new clean energy technology prize competition for universities. Congress should appropriate the authorized funds for these programs.In addition, Congress should appropriate funds authorized in section 10715 of the CHIPS and Science Act. This section authorizes $3 million per year through FY 2027 for coordination capacity at OTT, including to develop metrics for the impact of OTT programs and to engage more effectively with the clean energy ecosystem. Additional capacity for OTT is critical to the office’s success, and to the development of clean energy technologies more broadly.

• IIJA: Funding for the Critical Minerals Mining and Recycling Grant Program in the DOECritical minerals are crucial for clean energy and semiconductor technologies. The U.S. lacks a sufficient domestic supply of critical minerals and is currently overly reliant on foreign critical minerals, which have volatile prices and are often controlled by adversarial countries. The Infrastructure Investment and Jobs Act (IIJA) authorized $100 million from FY 2022 to FY 2024 for the DOE Critical Minerals Mining and Recycling Grant Program to fund pilot projects that process, recycle, or develop critical minerals. This program is not limited to critical minerals for lithium-ion battery production, and has the potential to impact critical minerals used in a variety of clean energy and semiconductor technologies. Congress should appropriate the authorized funds for this program, since it fills the pre-commercialization funding gap for scaling these technologies that is not met by other programs in the IIJA.
• FY 2024: Research and Development in the DOE’s Office of Energy Efficiency and Renewable Energy (EERE) and the Advanced Research Project Agency for Energy (ARPA-E)
  These two offices are key investors in clean energy technologies at different stages of research and commercialization and provide a direct way for the government to scale up American-made energy technologies. To accelerate the energy transition, Congress should provide robust increases for these offices, and at least meet EERE and ARPA-E’s FY 2024 budget requests, such that they can scale up their proven ability of identifying and supporting promising candidates for energy innovation.