Launch the Next Nuclear Corps for a More Flexible Nuclear Regulatory Commission
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 10.3 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.
The Corps director should create positions informed by the expertise and insights from agency leaders who have a real-time understanding of industry activity and present staffing challenges. Positions should cover all career levels and cover competency areas that do not require in-depth internal training or security clearances. The Corps should fill new positions created for special roles in support of other staff or teams, such as special coordinators, specialists, and consultants.
The Corps is not a graduate-level fellowship or leadership development program. The Corps is specifically for short-term, rapid hiring based on emergent capacity needs that may be temporary based on the nature of the need or uncertainty in future demand.
The Corps structure includes flexibility for a limited number of renewals, but it is not intended to recruit for permanent positions. Supervisors and hiring managers could choose to coordinate with the OCHCO to recruit off-boarding Corps members to other employment opportunities.
The Corps director can identify talent through existing NRC recruiting channels, such as job fairs, universities, and professional associations, however, the Corps director should also establish new recruiting efforts through more competitive channels. Because the positions are temporary, the Corps can recruit from more competitive talent pools, such as talent seeking long term careers in private industry. Job seekers with long-term ambitions in the private nuclear sector and the NRC could both benefit from a one- or two-year period of service focused on a specific project.
Promoting Fusion Energy Leadership with U.S. Tritium Production Capacity
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.
A U.S. Government Accountability Office (GAO) report from 2000 provided unclassified approximations of total life-cycle cost ranged from ~$34,000 to $57,000 per gram of tritium. With several program delays and at least one major capital investment (i.e., a 500,000 gallon Tritiated Water Storage Tank (TWST) system) costing ~$20 million, the actual life-cycle costs are likely higher. The cost of tritium produced in Canada is closer to $30,000 per gram, but, as noted above, only fixed and limited amounts of tritium can be made available through this process.
This is unlikely. The SSMP projects tritium needs far enough into the future that demand changes could allow for adjustments to production levels over the span of 1–2 fuel cycles (i.e., one and a half to three years). Barring a catastrophic loss of military tritium reserves or a significant nuclear accident at Watts Bar, there is unlikely to be a tritium supply emergency requiring an immediate response.
Historical tritium production amounts and capacities at SRS remain restricted data. However, due to NRC regulatory requirements for commercial reactors, this information cannot be protected for tritium production at Watts Bar. Since tritium production transparency has been the norm since 2003, the United States may further demonstrate nuclear stockpile credibility by openly producing material in excess of current military requirements.
Unobligated fuel demand would slightly increase. Unobligated fuel requirements are largely a sunk cost. Regardless of how many TPBARs are being irradiated the entire core will be composed of unobligated fuel. However, increased tritium production (i.e., irradiating more TPBARs) would require additional fresh fuel bundles per fuel cycle. The 2024 SSMP currently projects meeting Watts Bar’s unobligated fuel needs through 2044.
This would possibly require new license amendments for each reactor, but if the amounts were below the previously analyzed conditions, then a new Environmental Impact Statement (EIS) would not be required. The current license for each reactor allows for the irradiation of up to 2,496 TPBARs per fuel cycle per reactor. The EIS analysis is bounded at a maximum of 6,000 TPBARs combined per fuel cycle. The average yield of each TPBAR is 0.95g of tritium.
Fusion industry leaders have demonstrated confidence that existing and future supplies of civilian-use tritium, while modest, are sufficient to fuel the necessary near-term R&D. In particular, the planned refurbishments to aging Canadian CANDU reactors and the additional delays at ITER have propped open the tritium window for several more years until tritium breeding blanket technologies can mature. However, tritium supply chain bottlenecks could constrain industry momentum and/or advantage states capable of backstopping any shortages.
U.S. Energy Security Compacts: Enhancing American Leadership and Influence with Global Energy Investment
This policy proposal was incubated at the Energy for Growth Hub and workshopped at FAS in May 2024.
Increasingly, U.S. national security priorities depend heavily on bolstering the energy security of key allies, including developing and emerging economies. But U.S. capacity to deliver this investment is hamstrung by critical gaps in approach, capability, and tools.
The new administration should work with Congress to give the Millennium Challenge Corporation (MCC) the mandate and capacity to lead the U.S. interagency in implementing ‘Energy Security Compacts’, bilateral packages of investment and support for allies whose energy security is closely tied to core U.S. priorities. This would require minor amendments to the Millennium Challenge Act of 2003 to add a fourth business line to MCC’s Compact operations and grant the agency authority to coordinate an interagency working group contributing complementary tools and resources.
This proposal presents an opportunity to deliver on global energy security, an issue with broad appeal and major national security benefits. This initiative would strengthen economic partnerships with allies overseas, who consistently rank energy security as a top priority; enhance U.S. influence and credibility in advancing global infrastructure; and expand growing markets for U.S. energy technology. This proposal is built on the foundations and successes of MCC, a signature achievement of the G.W. Bush administration, and is informed by lessons learned from other initiatives launched by previous presidents of both parties.
Challenge and Opportunity
More than ever before, U.S. national security depends on bolstering the energy security of key allies. Core examples include:
- Securing physical energy assets: In countries under immediate or potential military threat, the U.S. may seek to secure vulnerable critical energy infrastructure, restore energy services to local populations, and build a foundation for long-term restoration.
- Countering dependence on geostrategic competitors: U.S. allies’ reliance on geostrategic competitors for energy supply or technologies poses short- and long-term threats to national security. Russia is building large nuclear reactors in major economies including Turkey, Egypt, India, and Bangladesh; has signed agreements to supply nuclear technology to at least 40 countries; and has agreed to provide training and technical assistance to at least another 14. Targeted U.S. support, investment, and commercial diplomacy can head off such dependence by expanding competition.
- Driving economic growth and enduring diplomatic relationships: Many developing and emerging economies face severe challenges in providing reliable, affordable electricity to their populations. This hampers basic livelihoods; constrains economic activity, job creation, and internet access; and contributes to deteriorating economic conditions driving instability and unrest. Of all the constraints analyses conducted by MCC since its creation, roughly half identified energy as a country’s top economic constraint. As emerging economies grow, their economic stability has an expanding influence over global economic performance and security. In coming decades, they will require vast increases in reliable energy to grow their manufacturing and service industries and employ rapidly growing populations. U.S. investment can provide the foundation for market-driven growth and enduring diplomatic partnerships.
- Diversifying supply chains: Many crucial technologies depend on minerals sourced from developing economies without reliable electricity. For example, Zambia accounts for about 4% of global copper supply and would like to scale up production. But recurring droughts have shuttered the country’s major hydropower plant and led to electricity outages, making it difficult for mining operations to continue or grow. Scaling up the mining and processing of key minerals in developing economies will require investment in improving power supply.
The U.S. needs a mechanism that enables quick, efficient, and effective investment and policy responses to the specific concerns facing key allies. Currently, U.S. capacity to deliver such support is hamstrung by key gaps in approach, capabilities, and tools. The most salient challenges include:
A project-by-project approach limits systemic impact: U.S. overseas investment agencies including the Development Finance Corporation (DFC), the U.S. Trade and Development Agency (USTDA), and the Export-Import Bank (EXIM) are built to advance individual commercial energy transactions across many different countries. This approach has value–but is insufficient in cases where the goal is to secure a particular country’s entire energy system by building strong, competitive markets. That will require approaching the energy sector as a complex and interconnected system, rather than a set of stand-alone transactions.
Diffusion of tools across the interagency hinders coordination. The U.S. has powerful tools to support energy security–including through direct investment, policy support, and technical and commercial assistance–but they are spread across at least nine different agencies. Optimizing deployment will require efficient coordination, incentives for collaboration; and less fragmented engagement with private partners.
Insufficient leverage to incentivize reforms weakens accountability. Ultimately, energy security depends heavily on decisions made by the partner country’s government. In many cases, governments need to make tough decisions and advance key reforms before the U.S. can help crowd in private capital. Many U.S. agencies provide technical assistance to strengthen policy and regulatory frameworks but lack concrete mechanisms to incentivize these reforms or make U.S. funding contingent on progress.
Limited tools supporting vital enabling public infrastructure blocks out private investment. The most challenging bottleneck to modernizing and strengthening a power sector is often not financing new power generation (which can easily attract private investment under the right conditions), but supporting critical enabling infrastructure including grid networks. In most emerging markets, these are public assets, wholly or partially state-owned. However, most U.S. energy finance tools are designed to support only private sector-led investments. This effectively limits their effectiveness to the generation sector, which already attracts far more capital than transmission or distribution.
To succeed, an energy security investment mechanism should:
- Enable investment highly tailored to the specific needs and priorities of partners;
- Provide support across the entire energy sector value chain, strengthening markets to enable greater direct investment by DFC and the private sector;
- Co-invest with partner countries in shared priorities, with strong accountability mechanisms.
Plan of Action
The new administration should work with Congress to give the Millennium Challenge Corporation the mandate to implement ‘Energy Security Compacts’ (ESCs) addressing the primary constraints to energy security in specific countries, and to coordinate the rest of the interagency in contributing relevant tools and resources. This proposal builds on and reflects key lessons learned from previous efforts by administrations of both parties.
Each Energy Security Compact would include the following:
- A process led by MCC and the National Security Council (NSC) to identify priority countries.
- An analysis jointly conducted by MCC and the partner country on the key constraints to energy security.
- Negotiation, led by MCC with support from NSC, of a multi-year Energy Security Compact, anchored by MCC support for a specific set of investments and reforms, and complemented by relevant contributions from the interagency. The Energy Security Compact would define agency-specific responsibilities and include clear objectives and measurable targets.
- Implementation of the Energy Security Compact, led by MCC and NSC. To manage this process, MCC and NSC would co-lead an Interagency Working Group comprising representatives from all relevant agencies.
- Results reporting, based on MCC’s top-ranked reporting process, to the National Security Council and Congress.
This would require the following congressional actions:
- Amend the Millennium Challenge Act of 2003: Grant MCC the expanded mandate to deploy Energy Security Compacts as a fourth business line. This should include language applying more flexible eligibility criteria to ESCs, and broadening the set of countries in which MCC can operate when implementing an ESC. Give MCC the mandate to co-lead an interagency working group with NSC.
- Plus up MCC Appropriation: ESCs can be launched as a pilot project in a few markets. But ultimately, the model’s success and impact will depend on MCC appropriations, including for direct investment and dedicated staff. MCC has a track record of outstanding transparency in evaluating its programs and reporting results.
- Strengthen DFC through reauthorization. The ultimate success of ESCs hinges on DFC’s ability to deploy more capital in the energy sector. DFC’s congressional authorization expires in September 2025, presenting an opportunity to enhance the agency’s reach and impact in energy security. Key recommendations for reauthorization include: 1) Addressing the equity scoring challenge; and 2) Raising DFC’s maximum contingent liability to $100 billion.
- Budget. The initiative could operate under various budget scenarios. The model is specifically designed to be scalable, based on the number of countries with which the U.S. wants to engage. It prioritizes efficiency by drawing on existing appropriations and authorities, by focusing U.S. resources on the highest priority countries and challenges, and by better coordinating the deployment of various U.S. tools.
This proposal draws heavily on the successes and struggles of initiatives from previous administrations of both parties. The most important lessons include:
- From MCC: The Compact model works. Multi-year Compact agreements are an effective way to ensure country buy-in, leadership, and accountability through the joint negotiation process and the establishment of clear goals and metrics. Compacts are also an effective mechanism to support hard infrastructure because they provide multi-year resources.
- From MCC: Investments should be based on rigorous analysis. MCC’s Constraints Analyses identify the most important constraints to economic growth in a given country. That same rigor should be applied to energy security, ensuring that U.S. investments target the highest impact projects, including those with the greatest positive impact on crowding in additional private sector capital.
- From Power Africa: Interagency coordination can work. Coordinating implementation across U.S. agencies is a chronic challenge. But it is essential to ESCs–and to successful energy investment more broadly. The ESC proposal draws on lessons learned from the Power Africa Coordinator’s Office. Specifically, joint-leadership with the NSC focuses effort and ensures alignment with broader strategic priorities. A mechanism to easily transfer funds from the Coordinator’s Office to other agencies incentivizes collaboration, and enables the U.S. to respond more quickly to unanticipated needs. And finally, staffing the office with individuals seconded from relevant agencies ensures that staff understand the available tools, how they can be deployed effectively, and how (and with whom) to work with to ensure success. Legislative language creating a Coordinator’s Office for ESCs can be modeled on language in the Electrify Africa Act of 2015, which created Power Africa’s interagency working group.
Conclusion
The new administration should work with Congress to empower the Millennium Challenge Corporation to lead the U.S. interagency in crafting ‘Energy Security Compacts’. This effort would provide the U.S. with the capability to coordinate direct investment in the energy security of a partner country and contribute to U.S. national priorities including diversifying energy supply chains, investing in the economic stability and performance of rapidly growing markets, and supporting allies with energy systems under direct threat.
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.
MCC’s model already includes multi-year Compacts targeting major constraints to economic growth. The agency already has the structure and skills to implement Energy Security Compacts in place, including a strong track record of successful investment across many energy sector compacts. MCC enjoys a strong bipartisan reputation and consistently ranks as the world’s most transparent bilateral development donor. Finally, MCC is unique among U.S. agencies in being able to put large-scale grant capital into public infrastructure, a crucial tool for energy sector support–particularly in emerging and developing economies. Co-leading the design and implementation of ESCs with the NSC will ensure that MCC’s technical skills and experience are balanced with NSC’s view on strategic and diplomatic goals.
This proposal supports existing proposed legislative changes to increase MCC’s impact by expanding the set of countries eligible for support. The Millennium Challenge Act of 2003 currently defines the candidate country pool in a way that MCC has determined prevents it from “considering numerous middle-income countries that face substantial threats to their economic development paths and ability to reduce poverty.” Expanding that country pool would increase the potential for impact. Secondly, the country selection process for ESCs should be amended to include strategic considerations and to enable participation by the NSC.
New Nuclear Requires New Hiring at the NRC
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.
Energy Justice for All: Keeping Disadvantaged Populations Cool in a Heating World
Extreme heat is the deadliest weather phenomenon in the United States — more lethal than hurricanes, floods, and tornadoes combined. And, as extreme temperatures rise, so do American household energy bills. An alarming 16% (20.9 million) of U.S. households are behind on their energy bills and at an increased risk of utility shut-offs.
Many households rely on electrical power systems like air conditioning (AC) to combat immediate heat effects, increasing energy demand and straining power transmission capabilities, non-reliability, and energy insecurity. Even as increasingly warmer winter months due to climate change reduce the need for heating, this indicates a future with increased energy demand for cooling. In the U.S., projected changes in cooling degree days — the metric to estimate how much cooling is needed to maintain a comfortable indoor air temperature — are expected to drive a 71% increase in household cooling demand by 2050, according to the latest annual energy outlook from the U.S. Energy Information Administration (EIA).
Increasingly excessive heat is, therefore, a financial burden for many people, particularly low-income households. This is especially the case as low-income households tend to live in less energy-efficient homes that are more expensive to cool. The inability to afford household energy needs — that is, energy insecurity — makes it a challenge to stay cool, comfortable, and healthy during periods of extreme heat. Thus, as the impacts of extreme heat and energy insecurity are not distributed evenly, it is increasingly essential for the federal government to consider equity and prioritize disadvantaged populations in its efforts to tackle these intertwined crises.
Extreme Heat Drives Energy Burdens and Utility Insecurities
Energy insecurity refers to an individual or household’s inability to adequately meet basic household energy needs, like cooling and heating. Extreme heat compounds existing energy insecurities by surging the need for AC and other electrical sources of cooling technology. Thus, as the demand for cooling during summer increases energy consumption, many households cannot afford to run their AC, leading to life-threatening living conditions. According to the latest EIA Residential Energy Consumption Survey (RECS), a striking one in five households reported reducing or forgoing necessities like food and medicine to pay an energy bill. Over 10% of households reported keeping their home at an unhealthy or unsafe temperature due to costs.
Additionally, while household access to AC has increased over the years, a significant one in eight U.S. homes on average are still lacking AC, with renters going without at a higher rate than homeowners. The lack of access to cooling may be particularly hazardous for low-income, renter, rural, or elderly households, especially for those with underlying health conditions and those living in heat islands—urban areas where temperatures are higher than surrounding rural and suburban areas.
Another critical issue is that at least three million U.S. utility customers have their power disconnected every year due to payment challenges, yet 31 states have no policy preventing energy shut-offs during excessive heat events. The states that do have policies vary widely in their cut-off points and protection policies. Across the board, low-income people are disproportionately facing disconnections and are often charged a “reconnect fee” or a deposit after a cutoff.
As of 2021, 29 states had seasonal protections and 23 had temperature-based disconnection protections that prohibit utility companies from disconnecting power. Still, research from the Indiana University Energy Justice Lab shows that these do not fully prohibit disconnections, often putting the onus on customers to demonstrate eligibility for an exemption, such as medical need. Further, while 46 states, along with Washington D.C., give customers the option to set up a payment plan as an alternative to disconnection, high interest rates may be costly, and income-based repayment is rarely an option.
These cut-off policies are all set at the state level, and there is still an ongoing need to identify best practices that save lives. Policymakers can use utility regulations to protect residents from the financial burden of extreme heat events. For example, Phoenix passed a policy that went into effect in 2022 and prevents both residential energy disconnections in summer months (through October 2024) and late fees incurred during this time for residents who owe less than $300. Also, some stakeholders in Massachusetts are considering “networked geothermal energy with microdistricts” — also known as geogrids — to build the physical capability to transfer cool air through a geothermal network. This could allow different energy users to trade hot and cool air, in order to move cool air from members who can pay for it to those who cannot.
Grid Insecurity
Extreme heat also poses a significant threat to national energy grid infrastructure by increasing the risk of power outages due to increased energy consumption. Nationwide, major power outages have increased tenfold since 1980, largely because of damages from extreme weather and aging grid infrastructure. Regions not accustomed to experiencing extreme heat and lacking the infrastructure to deal with it will now become particularly vulnerable. Disadvantaged neighborhoods in urban heat islands also face heightened risks as they more frequently lack the essential infrastructure needed to adapt to the changing climate. For example, grid infrastructure in California’s urban disadvantaged communities has been shown to be weaker and less ready to support electric appliances.
Similarly, rural communities face unique challenges in preparing for disasters that could lead to power loss. Geographic isolation, limited resources, and older infrastructure are all factors that make power outages more frequent and long-lasting in rural areas. These factors also affect the frequency of maintenance service and speed of repairs. In addition, rural areas often have less access to emergency services and cooling centers, making power outages during extreme heat events additionally hazardous. Power outages during extreme heat events increase the risks for heat-related illnesses such as fainting, heat exhaustion, and heatstroke. And, for rural homes that rely on well water, losing power can mean losing access to water, since well systems rely on electrical pumps to bring water into the home.
Further heightening the need for urgency to consider these especially vulnerable populations and regions, research has shown that the time to restore power after an outage is significantly longer for rural communities and in low-income communities of color. Power restoration time reflects which communities are prioritized and, as a result, which communities are neglected.
Equity Considerations For Different Housing Types
Extreme heat and energy security cannot be addressed without considering equity, as the impacts are not distributed evenly, especially by race, income, and housing type. One example of this intersection: Black renters have faced disproportionate burdens of extreme heat and energy security, as wealth is deeply correlated with race and homeownership in the U.S. In 2021, the EPA reported that Black people are 40% more likely than non-Black people to live in areas with the highest projected increase in mortality rates due to extreme temperatures. Simultaneously, a 2020 analysis by the Brookings Institute found that Black renters had greater energy insecurity than white renters, Black homeowners, and white homeowners. Beyond the cost burden of staying cool, this energy security puts lives at greater risk of heat-related illness and death and hinders economic mobility.
This paradigm reflects historic, discriminatory housing policies like redlining. Such policies segregated neighborhoods, induced lower homeownership rates, and ensured underinvestment in low-income communities of color—all of these factors play a significant part in making Black residents more vulnerable to the effects of extreme heat. Further compounding this, a 2020 study of more than 100 cities across the U.S. found that 94% of formerly redlined areas are hotter than non-redlined areas; in the summer, this difference can be as high as 12.6℉.
Nationwide, households living in manufactured homes also face disproportionate risks and impacts, with about 25% having incomes at or below the federal poverty level. At the same time, manufactured homes consume 70% more per square foot on energy than site-built homes, while using 35% less energy due to their smaller size. Notably, about 70% of all manufactured homes are located in rural areas, which on average have higher median energy burdens than metropolitan areas.
Further, older manufactured housing units are often in inadequate condition and do not meet building codes established after 1976. However, research has shown that the vulnerability of households living in manufactured housing units to extreme temperatures is only partially related to whether they have AC systems installed. Other key factors that residents report to drive vulnerability include AC units that do not work efficiently, are located in less-used parts of the house, or are ineffective in maintaining comfortable temperatures. These factors hamper manufactured housing residents’ ability to control their home’s thermal environment — thereby driving thermal insecurity.
Manufactured housing households facing challenges with resource access (such as exclusions from assistance programs and lack of credit access), physical health and mental limitations, care burdens, and documentation status may be at disproportionate risk. These households deal with multiple, intersecting vulnerabilities and often must engage in trade-off behavior to meet their most immediate needs, sacrificing their ability to address unsafe temperatures at home. They often take adapting to the increasingly extreme climate into their own hands, using various ways to cope with thermal insecurity, such as installing dual-pane windows, adding insulation, planting shade trees, using supplemental mobile AC units, and even leaving home to visit local air-conditioned malls.
These overlapping paradigms showcase the intrinsic interconnectedness among climate justice, climate justice, energy justice, and housing justice. Essentially, housing equity cannot be pursued without energy justice and climate justice, as the conditions for realizing each of these concepts entail the conditions for the others. Realizing these conditions will require substantial investment and funding for climate programs to include heat governance, housing resilience, and poverty alleviation policies.
Policy Considerations
Energy Burdens and Utility Insecurity
Update the Low Income Home Energy Assistance Program (LIHEAP)
The Low Income Home Energy Assistance Program (LIHEAP) exists to relieve energy burdens, yet was designed primarily for heating assistance. Thus, the LIHEAP formulas advantage states with historically cooler climates. To put this in perspective, some states with the highest heat risk — such as Missouri, Nevada, North Carolina, and Utah — offer no cooling assistance funds from LIHEAP. Despite their warm climates, Arizona, Arkansas, Florida, and Hawai’i all limit LIHEAP cooling assistance per household to less than half the available heating assistance benefit. And, since most states use their LIHEAP budgets for heating first, very little remains for cooling assistance — in some cases, cooling assistance is not offered at all. As a result, from 2001 to 2019, only 5% of national energy assistance went to cooling.
For vulnerable households, the lack of cooling assistance is compounded by a lack of disconnection protections from extreme heat. Thus, with advanced forecasts, LIHEAP should also be deployed both to restore disconnected electric service and to make payments on energy bills, which may surge even higher with the increase in demand response pricing due to more extreme temperatures. The distribution of LIHEAP funds to the most vulnerable households should also be maximized. As most states do not have firm guidelines on which households to distribute LIHEAP funds to and use a modified “first-come, first-served” approach, a small number of questions specific to heat risk could be added to LIHEAP applications and used to generate a household heat vulnerability score.
Further, the LIHEAP program is massively oversubscribed, and can only service a portion of in-need families. To adapt to a hotter nation and world at large, the annual budgets for LIHEAP must increase and the allocation formulas will need to be made more “cooling”-aware and equitable for hot-weather states. The FY25 presidential budget keeps LIHEAP’s funding levels at $4.1 billion, while also proposing expanding eligible activities that will draw on available resources. Analysis from the National Energy Assistance Directors Association found that this funding level could cut off up to 1.5 million families from the program and remove program benefits like cooling.
Reform the Public Utility Regulatory Policies Act of 1978 (PURPA)
While PURPA prohibits electric utilities from shutting off home electricity for overdue bills when doing so would be dangerous for someone’s health, it does not have explicit protections for extreme temperatures. The federal government could consider reforms to PURPA that require utilities to have moratoriums on energy shut-offs during extreme heat seasons.
Housing Improvements
Expand Weatherization Assistance Programs
Weatherization aims to make homes more energy efficient and comfortable in various climates through actions, such as attic and wall insulation, air sealing, or adding weather stripping to doors and windows. More than half of cities have a weatherization program. The Department of Energy (DOE) Weatherization Assistance Program (WAP) funding is available for states and other entities to retrofit older homes for improved energy efficiency to power cooling technologies like AC. However, similar to LIHEAP, WAP primarily focuses on support for heating-related repairs rather than cooling. For all residential property types, weatherization audits, through WAP and LIHEAP, can be expanded to consider heat resilience and cooling efficiency of the property and then identify upgrades such as more efficient AC, building envelope improvements, cool roofs, cool walls, shade, and other infrastructure.
Further, weatherization can be complicated when trying to help the most vulnerable populations. As some of the houses are in such poor condition that they do not qualify for weatherization, there is a need for nationwide access to pre-weatherization assistance programs. These programs address severe conditions in a home that would cause a home to be deferred from the federal WAP because the conditions would make the weatherization measures unsafe or ineffective. Pre-weatherization assistance programs are typically run by the State WAP Office or administered in partnership with another state office.
Additionally, as the Infrastructure Investment and Jobs Act (IJA) allocated roughly $3.5 billion to WAP, states should utilize this funding to target energy-insecure neighborhoods with high rates of rental properties. Doing so will help states prioritize decreasing energy insecurity and its associated safety risks for some of the most vulnerable households.
Increase Research on Federal Protections for Vulnerable Housing Types
There is a need for a nationwide policy for secure access to cooling. While the Department of Housing and Urban Development (HUD) does not regulate manufactured home parks, it does finance the parks through Section 207 mortgages. HUD could stipulate park owners must guarantee resident safety. This agency could also update the Manufactured Home Construction and Safety Standards to allow for AC and other cooling regulations in local building codes to apply to manufactured homes, as they do for other forms of housing, as well as require homes perform to a certain level of cooling under high heat conditions. Additionally, to support lower-cost retrofit methods for manufactured homes and other vulnerable housing types, new approaches to financing, permitting, and incentivizing building retrofits should be developed, per the Biden-Harris Administration’s Climate Resilience Game Changers Assessment. HUD’s Green and Resilient Retrofit Program, which provides climate resilience funding to affordable housing properties, can serve as a model.
Further, as home heat-risk remains under-studied and under-addressed by hazard mitigation planning, and policy processes, there needs to be better measures of home thermal security. Without better data, homes will continue to be overlooked in state and federal climate and adaptation efforts.
Grid Resilience and Energy Access
Prioritize access to affordable, resilient energy alternatives for energy-insecure individuals
The most long-term investment in reducing energy insecurity and climate vulnerability is ensuring the most energy insecure populations have access to alternative, renewable energy sources, such as wind and solar. This is a core focus of the DOE Energy Futures Grant (EFG) program, which provides $27 million in financial assistance and technical assistance to local- and state-led partnership efforts for increasing access to affordable clean energy. EFG is a Justice 40 program, and required to ensure 40% of the overall benefits of its federal investments flow to disadvantaged communities. Programs like EFG can serve as a model for federal efforts to reduce energy cost burdens, while simultaneously reducing dependence on nonrenewable energy sources like oil and natural gas.
Accelerate Energy-Efficient Infrastructure
Efficient AC technologies, such as air source heat pumps, can help make cooling more affordable. Therefore, resilient cooling strategies, like high-energy efficiency cooling systems, demand/response systems, and passive cooling interventions, need federal policy actions to rapidly scale for a warming world. For example, cool roofs, walls, and surfaces can keep buildings cool and less reliant on mechanical cooling, but are often not considered a part of weatherization audits and upgrades. District cooling, such as through networked geothermal, can keep entire neighborhoods cool while relying on little electricity. However, this is still in the demonstration project phase in the U.S. Initiatives like the DOE Affordable Home Energy Shot can bring new resilient cooling technologies into reach for millions of Americans, but only if it is given sufficient financial resources. The Environmental Protection Agency’s Energy Star program can further incentivize low-power and resilient cooling technologies if rebates are designed that take advantage of these technologies.
Geothermal is having a moment. Here’s how the Foundation for Energy Security and Innovation can make sure it lasts.
Geothermal energy is having a moment. The Department of Energy has made it a cornerstone of their post-BIL/IRA work – announcing an Enhanced Geothermal Earthshot last year and funding for a new consortium this year, along with additional funding for the Frontier Observatory for Research in Geothermal Energy (FORGE), Utah’s field lab.
It’s not just government – companies hit major milestones in commercial applications of geothermal this year. Fervo Energy launched a first-of-its-kind next-generation geothermal plant, using technology it developed this year. Project Innerspace, a geothermal development organization, recently announced a partnership with Google to begin large-scale mapping and subsurface data collection, a project that would increase understanding of and access to geothermal resources. Geothermal Rising recently hosted their annual conference, which saw record numbers of attendees.
But despite the excitement in these circles, the uptake of geothermal energy broadly is still relatively low, with only 0.4% of electricity generated in the U.S. coming from geothermal.
There are multiple reasons for this – that despite its appeal as a clean, firm, baseload energy source, geothermal has not exploded like its supporters believe it can and should. It has high upfront costs, is somewhat location dependent, and with the exception of former oil and gas professionals, lacks a dedicated workforce. But there are a range of actors in the public and private sector who are already trying to overcome these barriers and take geothermal to the next level with new and creative ideas.
One such idea is to use DOE’s newly authorized Foundation for Energy Security and Innovation (FESI) to convene philanthropy, industry, and government on these issues. At a recent FAS-hosted workshop, three major, viable use cases for how FESI can drive expansion of geothermal energy rose to the surface as the result of this cross-sector discussion. The foundation could potentially oversee: the development of an open-source database for data related to geothermal development; agreements for cost sharing geothermal pilot wells; or permitting support in the form of technical resource teams staffed with geothermal experts.
Unlocking Geothermal Energy
DOE’s Foundation for Energy Security and Innovation (FESI) was authorized by the CHIPS and Science Act and is still in the process of being stood up. But once in action, FESI could provide an opportunity for collaboration between philanthropy, industry, and government that could accelerate geothermal.
As part of our efforts to support DOE in standing up its new foundation with the Friends of FESI initiative, FAS is identifying potential use cases for FESI – structured projects that the foundation could take on as it begins work. The projects must forward DOE’s mission in some way, with particular focus on clean energy technology commercialization. We have already received a wide range of ideas for how FESI can act as a central hub for collaboration on specific clean energy technologies; how it can support innovative procurement and talent models for government; or how it can help ensure an equitable clean energy transition.
In early October, FAS had the opportunity to host a workshop as part of the 2023 Geothermal Rising Conference. The workshop invited conference attendees from nonprofits, companies, and government agencies of all levels to come together to brainstorm potential projects that could forward geothermal development. The workshop centered on four major ideas, and then invited attendees to break out into small groups, rotating after a period of time to ensure attendees could discuss each idea.
The workshop was successful, adding depth to existing ideas. The three main ideas that came out of the workshop – an open source geothermal database, cost sharing pilot wells, and permitting support – are explored in more detail below.
Open-source database for subsurface characterization
One of the major barriers to expanded geothermal development is a lack of data for use in exploration. Given the high upfront costs of geothermal wells, developers need to have a detailed understanding of subsurface conditions of a particular area to assess the area’s suitability for development and reduce their risk of investing in a dead end. Useful data can include bottom hole temperatures, thermal gradient, rock type, and porosity, but can also include less obvious data – information on existing water wells or transmission capacity in a particular area.
These data exist, but with caveats: they might be proprietary and available for a high cost, or they might be available at the state level and constrained by the available technical capacity in those offices. Data management standards and availability also vary by state. The Geothermal Data Repository and the US Geological Survey manage databases as well, but utility of and access to these data sources is limited.
With backing from industry and philanthropic sources, and in collaboration with DOE, FESI could support collection, standardization, and management of these data sources. A great place to begin would be making accessible existing public datasets. Having access to this data would lower the barrier to entry for geothermal start-ups, expand the types of geothermal development that exist, and remove some of the pressure that state and federal agencies feel around data management.
Cost sharing pilot wells
After exploration, the next stage in a geothermal energy source’s life is development of a well. This is a difficult stage to reach for companies: there’s high risk, high investment cost, and a lack of early equity financing. In short, it’s tough for companies to scale up, even if they have the expertise and technology. This is also true across different types of geothermal – just as much in traditional hydrothermal as in superhot or enhanced geothermal.
One way FESI could decrease the upfront costs of pilot wells is by fostering and supporting cost-share agreements between DOE, companies, and philanthropy. There is a precedent for this at DOE – from loan programs in the 1970s to the Geothermal Resource Exploration and Definition (GRED) programs in the 2000s. Cost-share agreements are good candidates for any type of flexible financial mechanism, like the Other Transactions Authority, but FESI could provide a neutral arena for funding and operation of such an agreement.
Cost share agreements could take different forms: FESI could oversee insurance schemes for drillers, offtake agreements, or centers of excellence for training workforces. The foundation would allow government and companies to pool resources in order to share the risk of increasing the number of active geothermal projects.
Interagency talent support for permitting
Another barrier to geothermal development (as well as to other clean energy technologies) is the slow process of permitting, filled with pitfalls. While legislative permitting reform is desperately needed, there are barriers that can be addressed in other ways. One of these is by infusing new talent: clean energy permitting applications require staff to assess and adjudicate them. Those staff need encyclopedic knowledge of various state, local, tribal, and federal permitting laws and an understanding of the clean energy technology in question. The federal government doesn’t have enough people to process applications at the speed the clean energy transition needs.
FESI could offer a solution. With philanthropic and private support, the foundation could enable fellowships or training programs to support increased geothermal (or other technological) expertise in government. This could take the form of ‘technical resource teams,’ or experts who can be deployed to agencies handling geothermal project permitting applications and use their subject matter knowledge to move applications more quickly through the pipeline.
The Bottom Line
These ideas represent a sample in just one technology area of what’s possible for FESI. In the weeks to come, the Friends of FESI team will work to develop these ideas further and also start to gauge interest from philanthropies in supporting them in the future. If you’re interested in contributing to or potentially funding these ideas, please reach out to our team at fesifriends@fas.org. If you have other ideas for what FESI could work on or just want to keep up with FESI, sign up for our email newsletter here.
Geopolitical and Cyber Risks to Oil and Gas
Whether an oil and gas company is working in the United States or is spread throughout the world, it will face geopolitical and cyber risks which could affect global energy security.
Geopolitical Risk
There are numerous geopolitical risks for any oil and gas company. Even if a company just works in the United States, it needs to know what is happening in countries all over the world, especially those countries that are large oil and gas producers. Because oil markets are so tightly connected globally, major political events in oil exporting states could seriously affect the price and even availability of oil. An attack on an oil platform in Nigeria, a terrorist event in Iraq, the closing down of port facilities in Libya and many other examples come to mind. Consider the potential effects of a major attack on the Ab Qaiq facility in Saudi Arabia. If this facility is damaged or destroyed on a large scale by rockets or bombs, the world oil market could be out 6-7 million barrels of oil a day- out of the 90-92 millions of barrels a day the world needs. World spare oil production capacity is about 2.3 million barrels a day. It could take some time to get this online. The spare production can be ramped up, but not immediately. Given that the grand majority of excess capacity in the world is located in Saudi Arabia and that this excess capacity could be significantly cut back with damage to Ab Qaiq, the situation is even riskier.
Another major risk nearby is transits through the Straits of Hormuz. About 16-17 million barrels a day goes out of the Straits. Any attempts to close the Straits (even unsuccessful ones) could have significant effects on the prices of various grades of oil. Even with the seemingly warming in relations between the U.S. and Iran, it is still possible that things could take a turn for the worse in the Gulf region. If the present negotiations with Iran break down, tensions could rise to even higher levels than before negotiations began. This could bring discussions of the military option more public. If there is a major conflict involving Gulf countries, the United States and its allies, then all bets are off on where oil prices may go. There could be many scenarios: from oil prices increasing $100 over the pre-conflict base price to well over $200 over the pre-conflict base price.
In many other parts of the world, geopolitical risks going “kinetic” can affect oil markets. Syria is a potential whirlpool of trouble for the entire Middle East. Egypt and Libya are far from stable. Algeria could be heading into some rough times. The Sudan’s will remain problematic and potentially quite violent for some time to come. The East China Sea and South China Sea disputes are not resolved. The Central Sahara could be a source and locale for troubles for some time to come.
Terrorist events can happen anywhere. Google Earth allows terrorists and others to get very close looks at major oil and gas facilities, transport choke points and more. Also, there are not that many tankers plying the vast seas and oceans of the world. Some of the most important routes are between the Gulf region and East Asia and Europe. Others travel from West Africa to Europe, and less so to the United States than before its shale oil revolution. The Mediterranean has many important tanker shipping routes. The Red Sea is a crucial route for both ships going north and south. Over 50 percent of oil trade happens on maritime routes. Many of these tankers cross through vital chokepoints like the Strait of Malacca, the Strait of Hormuz, The Bab al Mandab, The Suez Canal, The Turkish Straits, The Danish Straits, The Panama Canal, and various harbor and river routes where risks may be higher r at sea. Even whilst at sea, ships are at risk as shown by pirate attacks and hijackings off of East Africa, West Africa and previously off of Indonesia. There are about 1,996 crude oil tankers. However, only 623 of these are of the Ultra Large Crude Carrier (ULCC) or Very Large Crude Carrier (VLCC) variety that are the most important for transporting crude oil economically over long distances from the Gulf region to places like China (the biggest importer of oil), the United States, Japan, South Korea, and Europe. VLCCs can carry about 2 million barrels of oil while ULCCs can carry up to 2.3 or, rarely, 2.5 million barrels of oil. Normally these massive ships carry crude oil, but sometimes carry many different types of crude oil. Smaller petroleum tankers may carry both crude and refined products depending on their trade routes and the state of the markets at any times. There are about 493 Suez Max tankers, which can hold about 1 million barrels of oil and refined products and about 408 Afrimax vessels, which hold about 500,000 to 800,000 barrels of crude or refined products. Additionally, there are 417 Panamax vessels, which can carry 300,000 to 500,000 barrels of oil or refined products.
This may seem like a lot of ships to some. However, especially in tight markets, the pressure is immense to keep these ships at sea and to keep them on time. Moreover, there are lots of logistical complexities in trying to keep the crude moving at the right times and to the right places. If anything disturbs this complex economic and logistical ballet of behemoths, then the economic effects could be considerable. If the oil does not arrive on time then refinery production and deliveries of refined products to markets could be disturbed. Most countries have crude and product reserves to handle short term disruptions that may result from tanker losses. If the tanker losses are large or other disruptions occur in the supply chains of crude via ships, then those reserves could be worn down. It takes well over a year to build one of these tankers.
If the market for tankers is soft and some available tankers are moored in port, (such as when close to 500 hundred ships and dozens of tankers were moored off Singapore a few years ago), then the chances are better of getting the shipping logistics back to normal faster. However, problems could still arise in getting ships needed in Houston or Ras Tanura from Singapore. The travel times of these massive ships add considerable costs and disruptions.
When disruptions occur, some crude cargos can change direction and can be sold and resold, depending on the sorts of contracts that are in effect, along the way. Sometimes the disruptions are from political events, such as revolutions, insurrections, civil instability, and natural events like hurricanes and tsunamis. For example, when the tsunami hit Japan on March 11, 2011, many cargos were delayed or reconfigured. However, these sorts of events are different from terrorists blowing up a series of ships, as the psychology is different.
There is a certain amount of flexibility built into crude tanker transport markets, but a larger question is what would happen if many of them were taken out in various parts of the world. Would such a “black swan event” cause great disruptions? This is most likely. The follow on question would be how the tanker and other connected markets would react to this to help resolve the logistical attacks and how this might affect tanker insurance and lease rates.
Given that the crude and other products feed into other supply chains and markets, there could be cascades of disruptions in many parts of the world from a significant attack on even one large VLCC. Attacks on more ships would become increasingly more complex and costly in their effects.
If even one ship is sunk with a missile, the effects on oil markets and the world economy could far outweigh the mere few hundred millions of dollars in value the tanker and its cargo may represent. Ports, pipelines, refineries, tankers and other parts of the oil, transport and other infrastructures could be affected.
The destruction of an oil facility in a sensitive area that may be worth a few billion dollars could have a negative economic impact globally in the hundreds of billions, if not more. Attacks on the Houston Ship Channel, the Louisiana Offshore Oil Port, Ras Tanura in Saudi Arabia, the Jubail Complex in Saudi Arabia, Kharg or Lavan Island in Saudi Arabia could have considerable impacts economically and even militarily.
The impacts of attacks on these facilities would be stronger when oil and tanker markets are tight, and when the world or salient regional economies are growing quickly. An attack on a major tanker route out of Saudi Arabia heading to China or Japan will have a lot less effect on tanker and oil markets when there are excess tankers at anchor, and when there is excess capacity in oil production to make up in a relatively short time than when both tanker and oil markets are tight and there is little excess capacity. The less elastic the markets, the more effect any attacks will have. If a terrorist group wanted to have the most impact on the world economy it would likely attack in times of high growth in various important economies and when there is little excess oil capacity and no spare tankers. Often these three markets are tied together. When the global economy is growing quickly oil markets are under stress. When oil markets are under stress then tanker markets are stressed.
Looking to the future, some countries could be facing political turmoil such as Russia, Saudi Arabia, Iran, and Venezuela. This turmoil is not deterministic, but it is also not completely out of the bounds of probability. Depending on the type of turmoil, damage, and loss of production and export capacity, these events could have significant effects on world oil markets.
If such turmoil is going to happen, it is better for the world oil markets and the world economy that these happen during times of greater excess production and export capacity than the losses in oil production and export capacity from the turmoil. The worst of all possible combinations would be the loss of production and export capacity during very tight market times in a country where most of the excess capacity is found, which is in Saudi Arabia. If the world economy is growing quickly all around, then the effects of such turmoil will be far greater than if the world economy is in a slow growth period.
There are also regional aspects; during the 2011 Libyan Revolution, Europe’s economy was starting to dig itself out of a deep recession that had affected most European countries. Most of Libya’s oil that was cut off for a while was supposed to go to European countries, especially Italy, Spain, and France. Libyan oil production was about 1.7 million barrels a day until the civil war/ revolution began in February 2011. About 1.5 million barrels a day was exported. After the beginning of the conflict, production dropped to about 200,000 barrels a day, and did not recover until the post-civil war “recovery” that began about 8 months later. In the period between the start of the civil war/ revolution and the start of the ramp up, oil production dropped to 100,000 barrels a day and then on down to about zero barrels a day. Very little was exported during the times of the conflict. The fact that many European economies were growing slowly, or in some cases not growing at all, helped alleviate the potential effects of the cutting off of oil shipped from Libya. About 85 percent of Libya’s oil exports before the conflict went to Europe. The countries that relied considerably on Libyan were Italy, Austria, Ireland, Switzerland, Spain, Austria, and France. However, most of these were in slow-growth phases due to the ongoing recession and growing financial crises in their countries. The tanker markets were also soft and there was significant excess capacity of oil production in Saudi Arabia. The Saudis tried to backfill some orders for Libyan crude, but some of these did not work out well due to the heavier, sourer nature of the available Saudi crude compared to the usually light, sweet crude out of Libya. Switzerland is different from the other European countries as its “consumption” of Libyan oil was mostly for trading the oil in hedge funds and the big commodity firms in Geneva. The rest of these countries needed it for their overall economic needs.
Libyan crude production increased to about 1.4-1.5 million barrels a day until further problems occurred in mid-2013 with strikes at the ports and some energy facilities. Production is now down to 200,000 barrels per day. The effects on prices has been a lot less this time than during the civil war due to new, more flexible trading arrangements and better planning for such contingencies out of Libya, but also because the European economy and tanker markets remain weak.
Many Americans may think that they are relatively immune from geopolitical turmoil in oil disruptions because of the shale oil and gas revolution in the United States and Canada. However, there is potential for the increase in trade of oil with Canada which will result in greater access to oil and gas. But, this will not buffer the United States from the vagaries of oil prices caused by geopolitical events. This is mainly due to oil being a globally traded commodity.
Unlike the oil industry, the natural gas industry is not fully globally integrated, but it looks to be heading that way. As more countries invest in both conventional and unconventional reserves production, the development of LNG (Liquefied Natural Gas) export and import facilities, and expansions of major international pipeline networks, the world natural gas market will have some great changes. Some of these may include the convergence of prices of natural gas globally. Recent prices of natural gas (FOB – Freight on Board, where the buyer pays for transport costs) in China were about $15 per MMBTU (Million British Thermal Units), a common measurement of natural gas amounts. In Japan they were in the $16-17 ranger per MMTBTU. In many parts of Western Europe LNG (FOB) prices were about $9-11 per MMBTU. Natural gas in the United States recently has sold for about $3 per MMBTU. Qatar could sell at cost for much lower, as it sells to the United States for about $3 MMBTU similar LNG that it sells to China and Japan for much higher prices. With the convergence of prices, the lower cost countries will likely be the survivors. Others may have to drop out if they have to export the LNG at a loss, unless the country subsidizes these exports, which would be problematic under the World Trade Organization (WTO) agreements.
Those countries that develop their LNG export facilities the fastest will capture more of the most important markets (such as Japan, South Korea, and especially the potentially gigantic market in China), than those countries that doddle along in their decisions to export or not. The future of global gas markets is more of a very competitive and very expensive 4D chess game played by very powerful people, rather than just some engineering or economics exercise as some look at it.
As the now regional and segmented natural gas markets develop into global integrated markets, they will become more efficient and regional prices will start to converge toward a global price, much like oil. As the global natural gas markets develop, there will be more spot markets developed and less need for long term contracts in many instances. For decades, oil and gas prices were linked. As a global natural gas market develops, and especially with the further spread of the shale gas revolution, fewer and fewer natural gas contracts will be linked to oil prices. However, this integration of the natural gas industry globally also brings the risk of terrorist or political driven turmoil at or near LNG ports, LNG ships, and even in the market trading centers in places far removed from the United States. The more globally integrated the natural gas markets are, the more likely reverberations to prices will occur globally, rather than just locally. It is sort of like dropping a large rock in a pond with many barriers compared to dropping a large rock in a pond without many barriers in it. The waves will have more extensive effects without the barriers.
At the moment, the United States has a special domestic market that is fairly immune from outside events, as one would expect that they would happen in Canada, the United States’ major natural gas trading partner. This will change over time as U.S. natural gas markets get more connected with the world. The United States have some buffers during difficult gas shocks globally due to massive shale gas reserves. However, it could take a long time for these reserves to surge into the domestic markets to make up for the price increases.
Large profits can be made in exporting natural gas to places like China, Japan, South Korea, and Western Europe where gas prices are much higher. Over time those price differentials will decline because more LNG and piped gas will be flowing to the more profitable markets, hence putting pressure on prices. Global gas prices will tend to converge, but not entirely given different extraction, production, liquefaction and gasification prices.
With greater integration there are also new risks to consider. Some of these include potential attacks on major LNG facilities as natural gas becomes a more vital part of the world economy and some countries. There are also increased risks that as the global markets get more integrated in natural gas, events distant from the United States could affect prices in the United States much like what happens now with oil markets.
There are great profits to be made from exporting the potentially massive amounts of natural gas (mostly shale gas), from the United States into these newly developing world markets. (The greatest profits can be made in the first years of the development of these markets prior to the lowering of prices in Asia, Europe and higher priced areas as the markets get integrated.)
However, nothing is ever certain and some planning and emergency regulations may be required to help potential shocks from entering U.S. markets. Complete immunity is not possible when a market is globalized, but with proper consideration risks might be mitigated. A very large natural gas strategic reserve system might be best built and filled when the natural gas is cheap for times when it may be less accessible (likely for the short run given how quickly shale gas pads and production can be set up).
Cyber Risks
According to Europol there have been many cyber-raids in 2012 on logistics and computer networks connected to container ships by criminal gangs to obtain the illegal drugs they had hidden in the holds of the ship. The gang truck drivers were able to find the containers, get the security codes, and were able to get the drugs off the ship without being caught. This could be the start of far more serious cyber-attacks on shipping and maritime logistical networks. The oil and gas industry is information intensive and it is hard to get around that. Computer systems, the internet, and other cyber-based devices and operations are key elements to the operations of the industry. For example, Saudi Aramco and many other oil companies in the Middle East region have been cyber-attacked in recent years.
In addition, cyber-attacks have both financial and real effects, including distortions in the prices of oil and gas. Hacking into the derivatives and futures markets could wreak serious havoc on the industry. Real effects could include attacks on SCADA (Supervisory Control and Data Acquisition) systems that control oil and gas pipelines. SCADA is also used in refinery operations. If a container ship can be hacked, how far off is it when an LNG or oil tanker is taken over or hacked? Tanker traffic is often controlled and monitored via computer systems and the internet. Clever cyber warriors and others are likely trying to crack these systems (or potentially have even cracked them at times), but the industry would rather not discuss such events. It may be entirely possible to use something like STUXNET on affected SCADA systems to send the wrong signals to those trying to monitor the complex logistics of the shipping. A ship may be seen on the company’s monitor being one place, whereas it might be somewhere else. That is anyone’s guess, but I suggest that is not impossible. The new pirates attacking tankers may be cyber-pirates sending in malicious code, not just the barefoot Somalis and others tossing hook anchors on to the stern of the tanker and climbing up.
Cyber risk can also have considerable effects on the overall supply chains for the oil and gas industry. To get an oil rig, a refinery, a series of pipelines up and running takes a massive administrative supply chain effort that could involve sometimes hundreds if not thousands of subcontractors and suppliers that have to get things done in a specific order and on time. Anyone who has built a house or even had a kitchen remodeled knows how important it is to get the carpenters, electricians, masons, and roofers to be on schedule and in the right order. Now consider the complexity of getting all the right people, equipment and information on schedule and in the right order in the build out of a complex oil rig in 10,000 feet of water 150 miles at sea with millions of dollars (and maybe lives) at risk due to any scheduling mistakes.
A cyber-attack on major refineries and pipeline systems could bring costs that may seem unthinkable at the moment. However, this could just be a matter of time if the industry does not constantly update its protective systems and understanding of the risks. The industry remains constantly vigilant as hackers and cyber-warriors like the SEA (Syrian Electronic Army) are always looking for opportunities to attack. Constant vigilance will not be enough if one of these attackers gets “lucky” and gets through. The sophistication of cyber warriors and hackers is not static, nor should the sophistication of the oil and gas industry to counter these threats be static.
Note: All opinions expressed are those of the author alone. Sources supplied upon request.
Paul Sullivan is the Adjunct Senior Fellow for Future Global Resources Threats at the Federation of American Scientists and a Professor of Economics at the Eisenhower School at the National Defense University. He is also an Adjunct Professor of Security Studies at Georgetown University and a columnist for newspapers in Turkey and Mongolia.
Dr. Sullivan is an expert on resource security issues, with a special focus on the nexus of energy, water, food and land. He is also an expert on issues related to the economics, politics, and militaries in the Middle East and North Africa.