Impacts of Extreme Heat on Federal Healthcare Spending

Public health insurance programs, especially Medicaid, Medicare, and the Children’s Health Insurance Program (CHIP), are more likely to cover populations at increased risk from extreme heat, including low-income individuals, people with chronic illnesses, older adults, disabled adults, and children. When temperatures rise to extremes, these populations are more likely to need care for their heat-related or heat-exacerbated illnesses. Congress must prioritize addressing the heat-related financial impacts onthese programs. To boost the resilience of these programs to extreme heat, Congress should incentivize prevention by enabling states to facilitate health-related social needs (HRSN) pilots that can reduce heat-related illnesses, continue to support screenings for the social drivers of health, and implement preparedness and resilience requirements into the Conditions of Participation (CoPs) and Conditions for Coverage (CfCs) of relevant programs. 

Extreme Heat Increases Fiscal Impacts on Public Insurance Programs

Healthcare costs are a function of utilization, which has been rapidly rising since 2010. Extreme heat is driving up utilization as more Americans seek medical care for heat-related illnesses. Extreme heat events are estimated to be annually responsible for nearly 235,000 emergency department visits and more than 56,000 hospital admissions, adding approximately $1 billion to national healthcare costs. 

Heat-driven increases in healthcare utilization are especially notable for public insurance programs. One recent study found that there is a 10% increase in heat-related emergency department visits and a 7% increase in hospitalizations during heat wave days for low-income populations eligible for both Medicaid and Medicare. Further demonstrating the relationship between increased spending and extreme heat, the Congressional Budget Office found that for every 100,000 Medicare beneficiaries, extreme temperatures cause an additional 156 emergency department visits and $388,000 in spending per day on average. These higher utilization rates also drive increases in Medicaid transfer payments from the federal government to help states cover rising costs. For every 10 additional days of extreme heat above 90°F, annual Medicaid transfer payments increase by nearly 1%, equivalent to an $11.78 increase per capita. 

Additionally, Medicaid funds services for over 60% of nursing home residents. Yet Medicaid reimbursement rates often fail to cover the actual cost of care, leaving many facilities operating at a financial loss. This can make it difficult for both short-term and long-term care facilities to invest in and maintain the cooling infrastructure necessary to comply with existing requirements to maintain safe indoor temperatures. Further, many short-term and long-term care facilities do not have the emergency power back-ups that can keep the air conditioning on during extreme weather events and power outages, nor do they have emergency plans for occupant evacuation in case of dangerous indoor temperatures. This can and does subject residents to deadly indoor temperatures that can worsen their overall health outcomes.

The Impacts of the One Big Beautiful Bill Act

The One Big Beautiful Bill Act (H.R. 1) will have consequential impacts on federally-supported health insurance programs. The Congressional Budget Office projects that an estimated 10 million people could lose their healthcare coverage by 2034. Researchers have estimated that a loss of coverage could result in 50,000 preventable deaths. Further, health care facilities and hospitals will likely see funding losses as a result of Medicaid funding reductions. This will be especially burdensome to low-resourced hospitals, such as those serving rural areas, and result in reductions in available offerings for patients and even closure of facilities. States will need support navigating this new funding landscape while also identifying cost-effective measures and strategies to address the health-related impacts of extreme heat.

Advancing Solutions that Safeguard America’s Health from Extreme Heat

To address these impacts in this additionally challenged context, there are common-sense strategies to help people avoid extreme heat exposure. For example, access to safely cool indoor environments is one of the best preventative strategies for heat-related illness. In particular, Congress should create a demonstration pilot that provides eligible Medicare beneficiaries with cooling assistance and direct CMS to encourage Section 1115 demonstration waivers for HRSN related to extreme heat. Section 1115 waivers have enabled states to finance pilots for life-saving cooling devices and air filter distributions. These HRSN financing pilots have helped several states to work around the challenges of U.S. underinvestment in health and social services by providing a flexible vehicle to test methods of delivering and paying for healthcare services in Medicaid and CHIP. As Congress members explore these policies, they should consider the impact of H.R. 1’s new requirements for 1115 waiver’s proof of cost-neutrality.

To further support these efforts for heat interventions, Congress should direct CMS to continue Social Drivers of Health (SDOH) screenings as a part of Quality Reporting Programs and integrate questions about extreme heat exposure risks into the screening process. These screenings are critical for identifying the most vulnerable patients and directing them to the preventative services they need. This information will also be critical for identifying facilities that are treating high proportions of heat-vulnerable patients, which could then be sites for testing interventions like energy and housing assistance.

Congress should also direct the CMS to integrate heat preparedness and resilience requirements and metrics into the Conditions of Participation (CoPs) and Conditions for Coverage (CfCs), such as through the Emergency Preparedness Rule. This could include assessing the cooling capacity of a health care facility under extreme heat conditions, back-up power that is sufficient to maintain safe indoor temperatures, and policies for resident evacuation in the event of high indoor temperatures. For safety net facilities, such as rural hospitals and federally qualified health centers, Congress should consider allocating resources for technical assistance to assess these risks and the infrastructure upgrades.

Impacts of Extreme Heat on Agriculture

Agriculture, food, and related industries produce nearly 90% of the food consumed in the United States and contribute approximately $1.54 trillion to the national GDP. Given the agricultural sector’s importance to the national economy, food security, and public health, Congress must pay attention to the impacts of extreme heat. To boost the resilience of this sector, Congress should design strategic insurance solutions, enhance research and data, and protect farmworkers through on-farm adaptation measures.  

Extreme Heat Reduces Farm Productivity and Profitability

Extreme heat threatens agricultural productivity by increasing crop damage, causing livestock illness and mortality, and worsening water scarcity. Hotter conditions can damage crops through crop sunburn and heat stress, reducing annual yields for farms by as much as 40%. Animals raised for meat, milk, and eggs also experience increased risks of heat stress and heat-related mortality. For dairy production in particular, an estimated 1% of total annual yield is lost to heat stress alone. Further straining agricultural productivity, extreme heat accelerates water scarcity by increasing water evaporation rates. These higher evaporation rates force farmers to use even more water, drawing often from already stressed water sources. The compounding pressures posed by extreme heat can translate into significant economic losses: a study of Kansas commodity farms found that for every 1°C (1.8°F) increase in temperature, net farm incomes drop by 66%. Together, this means reduced revenue for farms and less food available for people.

Insurance solutions can help mitigate these financial impacts from extreme heat if employed responsibly. Multiple permanently authorized federal programs provide insurance or direct payments to help producers recover losses from extreme heat, including the Federal Crop Insurance Program, the Noninsured Crop Disaster Assistance Program, the Livestock Indemnity Program, and the Emergency Assistance for Livestock, Honey Bees, and Farm-Raised Fish Program. These programs need to ensure that producers are adequately covered against heat-related impacts and incentivize practices that reduce the risk of extreme heat related damages. This in turn will reduce the fiscal exposure of federal farm risk management programs. Congress should call on the United States Department of Agriculture (USDA) to research the feasibility of incentivizing heat resilience through federal crop insurance rates. Congress should also consider insurance premium subsidies for producers who adopt practices that enhance heat resilience for crops and livestock. 

Given the increasing stress of extreme heat on the water systems necessary to sustain agricultural production, National Oceanic and Atmospheric Administration (NOAA) should build on its Weather, Water, and Climate Strategy and collaborate with USDA on a national water security strategy that accounts for current and future hotter temperatures. To enhance system-wide drought resilience, Congress can also appropriate funds to leverage existing USDA programs to support on-farm adoption of shade systems, effective water management, cover crops, and soil regeneration practices. 

Finally, there are still notable knowledge gaps around extreme heat and its impacts on agriculture. These gaps include the long-term effects of higher temperatures on yields, farm input costs, and federal program spending. To address these information gaps and guide future research, Congress can direct the USDA Secretary to submit a report to Congress on the impacts of extreme heat on agriculture, farm input costs and losses, consumer prices, and the federal government’s spending (e.g.,  federal insurance and direct payment programs for losses of agricultural products and the provision of Supplemental Nutrition Assistance Program (SNAP) benefits).

Extreme Heat Lowers Agricultural Workers’ Productivity and Exposes Them to Health Risks

Higher temperatures and resulting heat stress are endangering farmer and farmworker safety and reducing their overall productivity, impacting bottom lines. Farmworkers are essential to the American food system, yet they are among the most vulnerable to extreme heat, facing a 35 times greater risk of dying from heat-related illnesses than workers in other sectors. This risk is intensifying as the sector increasingly relies on H‑2A farmworkers, who are hired to fill persistent domestic farm labor shortages. In many regions, over 25% of certified H‑2A farmworkers are required to work when local average temperatures exceed 90°F, and counties with the highest concentrations of H‑2A workers often coincide with the hottest parts of the country. After the work day, many of these workers return to substandard employer-provided housing that lacks essential cooling or ventilation, preventing effective recovery from daily heat exposure and exacerbating heat-related health risks. On top of the health risks, these conditions make people less effective on the job, which translates to economy-wide impacts: heat-related labor productivity losses across the U.S. economy currently exceeds $100 billion annually.

To address these risks, Congress should pass legislation requiring the Occupational Safety and Health Administration to finalize a federal heat standard that provides sufficient coverage for farming operations. In tandem with Occupational Safety and Health Administration (OSHA) finalizing the standard, USDA should be funded to provide technical assistance to agricultural employers for tailoring heat illness prevention plans and implementing cost-effective interventions that improve working conditions while maintaining productivity. This should include support for agricultural employers to integrate heat awareness into workforce training, resources for safety equipment and education, and support for the addition of shade structures. Doing so would ensure that agricultural workers across both large and small-scale farming operations have access to essential protections, like shade, clean water, and breaks, as well as sufficient capacity to comply. Current funding streams that could have an extreme heat infrastructure “plus-up” include the Environmental Quality Incentives Program and the Farm Service Agency’s microloans program.Lastly, Congress should also direct OSHA to continue implementing its National Emphasis Program on Heat, which enforces employers’ obligation to protect workers against heat illness or injury. OSHA should additionally review employers’ practices to ensure that H2A and other agricultural workers are protected from job or wage loss when extreme heat renders working conditions unsafe.

Impacts of Extreme Heat on Labor

Extreme heat is a major occupational hazard with far-reaching impacts on the national economy as well as worker health and safety. Extreme heat costs an estimated $100 billion per year in lost productivity, and causes an average of at least 3,389 heat-related injuries and 33 heat-related fatalities annually – numbers that are likely vast undercounts. To protect workers, Congress must mandate a federal heat standard, retain federal workers with expertise in heat stress management strategies, and establish Centers of Excellence to support research, training, and sector-specific mitigation strategies. Through investments in infrastructure for heat safety, Congress can save lives, protect the economy, and enhance resilience nationwide.

Heat-Related Risks are Heightened in Many Work Environments

Extreme heat puts workers of all types at risk: OSHA has documented hospitalizations and heat-related deaths in close to 275 industries. Some work environments present extreme heat risk, particularly those involving high exposures to the outdoors and limited access to cooling. With roughly one in three U.S. employees regularly working outdoors, a large share of the workforce is at elevated risk during summer months. Indoor workers also face high exposure, especially in kitchens, warehouses, manufacturing plants, and other poorly ventilated environments because heat and humidity easily build up in enclosed spaces without adequate air flow and climate-control. 

Business and Economic Impacts of High Heat Exposure in the Workplace 

On top of the $100 billion in direct annual losses, high temperatures are also linked to increased healthcare costs for employers and workers’ compensation claims, with claim frequencies rising by up to 10% during temperature extremes. Some industries are more exposed than others; for example, agriculture, construction, and utility companies face twice the risk of incurring increased healthcare claims due to extreme weather and other environmental conditions. This growing number of claims increases companies’ experience modification rates, which insurers use as a key factor for calculating higher future premiums. Higher premiums translate to greater insurance and overall operating costs, which is especially burdensome for small and low-margin businesses. Despite all these risks, many employers continue to underestimate the financial burden of extreme heat and other weather-related health impacts. 

Many Military Personnel and Federal Workers Face Above-Average Risks of Heat-Related Illness

Military personnel, federal law enforcement officers, border patrol officers, wildland firefighters, federal transportation workers like railroad inspectors, and postal employees are all in positions that require long, labor-intensive hours outdoors, raising the risk for heat-related illness. In 2024, heat-related illnesses were among the top five most reported medical events among U.S. active duty service members. Without consistent standards in place to protect these workers from extreme heat, military and other federal operations will continue to be vulnerable to disruption and reduced workforce capacity.

Advancing Solutions: Establish a Strong Federal Heat Standard and Sector-Specific Centers of Excellence for Heat Workplace Safety

To begin to address heat-related injuries and illnesses in workplaces, OSHA in 2022 established the National Emphasis Program (NEP) on Outdoor and Indoor Heat-Related Hazards, which remains in effect until April 2026. As of 2025, OSHA reports that this NEP has conducted nearly 7,000 inspections connected to heat risks, which lead to 60 heat citations and nearly 1,400 “hazard alert” letters being sent to employers.

However, in the absence of a federal mandate for effective heat safety practices, most workplaces rely on voluntary guidance that is not tailored to specific job conditions, backed by consistent data, or subject to enforcement. This puts both workers and businesses at risk. OSHA’s proposed Heat Injury and Illness Prevention rule would be a critical step forward to establishing common-sense baseline protections. According to the agency’s projections, compliance with this standard could prevent thousands of heat-related illnesses and deaths. The projected benefits from reduced fatalities, illness, and injury amount to $9.18 billion per year. Importantly, this action has broad public backing: 90% of American voters support the implementation of federal protections from extreme heat in the workplace. 

Congress should act swiftly to ensure OSHA finalizes and enforces a strong, evidence-based heat standard. To do this effectively, it is essential that funding for experts at the National Institute for Occupational Safety and Health (NIOSH) is retained in the FY26 budget request, as these critical workers develop criteria for recommended standards on occupational heat stress. These experts have been impacted by reductions in force at NIOSH, and as of July 2025 have not been brought back by the agency.

Some employers have raised concerns about the technical and financial feasibility of the proposed rule. To address these concerns, Congress should pair regulation with practical support by creating federally funded, sector-specific Centers of Excellence (CoEs)for Heat Workplace Safety. These Centers would develop and implement evidence-based solutions tailored to different work environments, such as agriculture and construction. The CoE approach includes comprehensive data collection at worksites that form the basis of occupational safety and health protocols best practices and policies to enhance productivity, prevent injury and illness, and ensure a return on investment. Once strategies are developed, CoEs implement them, track their impact, and work with workers, employers, and cross-sector partners to ensure long-term success.

By leveraging advanced technology, predictive analytics, and continuously updated industry standards, CoEs can help modernize OSHA regulations and make them more aligned with current workplace realities that go beyond simple compliance or post-injury responses.  Federal agencies and other industries with sizable workforces that receive government contracts are key places to develop best practices, technologies, and public-private partnerships for these interventions, all while reducing fiscal risk to the federal government.  

Fueling the Bioeconomy: Clean Energy Policies Driving Biotechnology Innovation

The transition to a clean energy future and diversified sources of energy requires a fundamental shift in how we produce and consume energy across all sectors of the U.S. economy. The transportation sector, a sector that heavily relies on fossil-based energy, stands out not only because it is the sector that releases the most carbon into the atmosphere, but also for its progress in adopting next-generation technologies when it comes to new technologies and fuel alternatives. 

Over the past several years, the federal government has made concerted efforts to support clean energy innovation in transportation, both for on-road and off-road. Particularly, in hard-to-electrify transportation sub-sectors, there has been added focus such as through the Sustainable Aviation Fuel (SAF) Grand Challenge. These efforts have enabled a wave of biotechnology-driven solutions to move from research labs to commercial markets, such as LanzaJets alcohol-to-jet technology in producing SAF. From renewable fuels to bio-based feedstocks, biotechnologies are enabling the replacement of fossil-derived energy sources and contributing to a more sustainable, secure, and diversified energy system. 

SAF in particular has gained traction, enabled in part by public investment and interagency coordination, like the SAF Grand Challenge Roadmap. This increased federal attention demonstrated how strategic federal action, paired with demand signals from government, targeted incentives, and industry buy-in, can create the conditions needed to accelerate biotechnology adoption.

To better understand the factors driving this progress, FAS conducted a landscape analysis at the federal and regional level of biotechnology innovation within the clean energy sector, complemented by interviews with key stakeholders. Several policy mechanisms, public-private partnerships, and investment strategies were identified that were enablers of advanced SAF adoption and production and similar technologies. By identifying the enabling conditions that supported biotechnology’s uptake and commercialization, we aim to inform future efforts on how to accelerate other sectors that utilize biotechnologies and overall, strengthen the U.S. bioeconomy.

Key Findings & Recommendations

An analysis of the federal clean energy landscape reveals several critical insights that are vital for advancing the development and deployment of biotechnologies. Federal and regional strategies are central to driving innovation and facilitating the transition of biotechnologies from research to commercialization. The following key findings and actionable recommendations address the challenges and opportunities in accelerating this transition.

Federal Level Key Findings & Recommendations

The federal government plays a pivotal role in guiding market signals and investment toward national priorities. In the clean energy sector, decarbonizing aviation has emerged as a strategic objective, with SAF serving as a critical lever. Federal initiatives such as the SAF Grand Challenge, the SAF Roadmap, and the SAF Metrics Dashboard have helped to elevate SAF within national climate priorities and enabled greater interagency coordination. These mechanisms not only track progress but also communicate federal commitment. Still, despite these efforts, current SAF production remains far below target levels, with capacity largely concentrated in HEFA, a pathway with constrained feedstock availability and limited scalability. 

This production gap reflects deeper structural challenges, many of which parallel broader issues across the clean-energy biotech interface. One of the main challenges is the fragmented, short-duration policy incentives currently in use. Tax credits like 40B and 45Z, while important, lack the longevity and clarity required to unlock large-scale, long-term private investment. The absence of binding fuel mandates further undermines market certainty. These policy gaps limit the ability of the clean energy sector to serve as a sustained demand signal for emerging biotechnologies and slow the transition from pilot to commercial scale. 

Importantly, these challenges point to a broader opportunity: SAF as a test case for how the clean energy sector can serve as a driver of biotechnology uptake. Promising biotechnologies, such as alcohol-to-jet and power-to-liquid, are currently stalled by high capital costs, uncertain regulatory pathways, and a lack of coordinated federal support. Addressing these bottlenecks through aligned incentives, technology-neutral mandates, and harmonized accounting frameworks could not only accelerate SAF deployment but also establish a broader policy blueprint for scaling biotechnology across other clean energy applications.

To alleviate some of the challenges identified, the federal government should:

Extend & Clarify Incentives

While tax incentives such as the 45Z Clean Fuel Production Credit offer a promising framework to accelerate low-carbon fuel deployment, current design and implementation challenges limit their impact, particularly for emerging bio-based and synthetic fuels. To fully unlock the climate and market potential of these incentives, Congress and relevant agencies should take the following steps:

Scale Biotech Commercialization Support

The clean energy transition depends in part on the successful commercialization of enabling biotechnologies, ranging from advanced biofuels to bio-based carbon capture, SAF and biomanufacturing platforms that reduce industrial emissions. Recent or proposed funding cuts to clean energy programs risk stalling this progress and undermining U.S. competitiveness in the bioeconomy. 

To accelerate biotechnology deployment and bridge the gap between lab-scale innovation and commercial-scale production, Congress should take the following actions:

Design and Promote Next-Gen Biofuel Policies

To accelerate the deployment of low-carbon fuels and enable innovation in next-generation bioenergy technologies, Congress and relevant agencies should take the following actions:

Regional Level Key Findings & Recommendations

Regional strengths continue to serve as foundational drivers of clean energy innovation, with localized assets shaping the pace and direction of technology development. Federal designations, such as the Economic Development Administration (EDA) Tech Hub program (Tech Hub), have proven catalytic. These initiatives enable regions to unlock state-level co-investment, attract private capital, and align workforce training programs with local industry needs. Early signs suggest that the Tech Hub framework is helping to seed innovation ecosystems where they are most needed, but long-term impact will depend on sustained funding support and continued regional coordination. 

Workforce readiness and enabling infrastructure remain critical differentiators. Regions with deep and committed involvement from major research universities, national labs, or advanced manufacturing clusters are better positioned to scale innovation from prototype to deployment. Real-world testbeds provide environments for stress-testing technologies and accelerating regulatory and market readiness, reinforcing the importance of place-based strategies in federal innovation planning. 

At the same time, private investment in clean energy and enabling biotechnologies remains crucial to developing and scaling innovative technologies. High capital costs, regulatory uncertainty, and limited early-stage demand signals continue to inhibit market entry, especially in geographies with less mature innovation ecosystems. Addressing these barriers through coordinated federal procurement, long-term incentives, and regional capacity-building will be essential to supporting growth in regions with strong assets to develop industry clusters that could yield clean energy benefits. 

To accomplish this, the federal government and regional governments should: 

Strengthen Regional Workforce Pipelines

A skilled and regionally distributed workforce is essential to realizing the full economic and technological potential of clean energy investments, particularly as they intersect with the bioeconomy. While federal funding is accelerating deployment through initiatives such as the IRA and DOE programs, workforce gaps, especially outside major innovation hubs, pose barriers to implementation. Addressing these gaps through targeted education, training, and talent retention efforts will be critical to ensuring that clean energy projects deliver durable, regionally inclusive economic growth. To this end:

Strengthen Regional Infrastructure and Foster Cross-Sector Collaboration

Robust regional infrastructure and cross-sector collaboration are essential to accelerating the deployment of clean energy technologies that leverage advancements in biotechnology and manufacturing. Strategic investments in shared facilities, modernized logistics, and coordinated innovation ecosystems will strengthen supply chain resilience and improve technology transfer across sectors. Facilitating access to R&D infrastructure, particularly for small and mid-sized enterprises, will ensure that innovation is not limited to large firms or major metropolitan areas. To support these outcomes: 

Attract and De-Risk Private Capital

Attracting and de-risking private capital is critical for scaling clean energy and biotechnology innovations. By offering targeted financial mechanisms and leveraging federal visibility, governments can reduce the financial uncertainties that often deter private investment. Effective strategies, such as state-backed loan guarantees and co-investment models, can help bridge funding gaps while strategic partnerships with philanthropic and venture capital entities can unlock additional resources for emerging technologies. To this end: 

Cross-Cutting Key Findings

The successful deployment of federal clean energy and biotechnology initiatives, such as the SAF Grand Challenge, relies heavily on the capacity of regional ecosystems and the private sector to absorb and implement national goals. Many regions, particularly those outside established innovation hubs, lack the infrastructure, resources, and technical expertise to effectively utilize federal funding. As a result, the impact of national policies is often limited, and the full potential of federal investments goes unrealized in certain areas.

Federal programs often take a one-size-fits-all approach, overlooking regional variability in feedstocks, industrial bases and cost structures. Programs like tax credits and life cycle analysis models can unintentionally disadvantage regions with different economic contexts, creating disparities in access to federal incentives. This lack of regional customization prevents certain areas from fully benefiting from national clean energy and biotech initiatives. 

The diffusion of innovation in clean energy and biotechnology remains concentrated in a few key regions, leaving others underutilized. Despite robust federal R&D investments, commercialization and scaling of innovations are primarily concentrated in regions with established infrastructure, hindering the broader geographic spread of these technologies. In addition, workforce development efforts across federal and regional programs are fragmented, creating misalignments in talent pipelines and further limiting the ability of local industries to leverage available resources effectively. The absence of a unified system for tracking key metrics, such as SAF production and emissions reductions, makes it difficult to coordinate efforts or assess progress consistently across regions. To address this, the federal and regional governments should:

Create a Federal–Regional Clean Energy Deployment Compact

A Federal-Regional Clean Energy Deployment Compact is critical for aligning federal clean energy initiatives with the unique capabilities and needs of regional ecosystems. By establishing formal mechanisms, such as intergovernmental councils and regional liaisons, federal programs can be more effectively tailored to local conditions. These mechanisms will ensure two-way communication between federal agencies and regional stakeholders, fostering a collaborative approach that adapts to evolving technological, economic, and environmental conditions. In addition, treating regional tech hubs and initiatives as testbeds for new policy tools, such as performance-based incentives or carbon standards, will allow for innovative solutions to be tested locally before scaling them nationally, ensuring that policies are effective and contextually relevant across diverse regions. To this end:

Build a National Innovation-to-Deployment Pipeline

Creating a seamless innovation-to-deployment pipeline is essential for scaling clean energy technologies and ensuring that regional ecosystems can fully participate in national clean energy transitions. By linking DOE national labs, Tech Hubs, and regional consortia into a coordinated network, the U.S. can support the full life cycle of innovation, from early-stage R&D to commercialization and deployment, across diverse geographies. Additionally, co-developing curricula and training programs between federal agencies, regional tech hubs, and industry partners will ensure that talent pipelines are closely aligned with the evolving needs of the clean energy sector, providing the skilled workforce necessary to implement and scale innovations effectively. To accomplish this the:

Develop a Shared Metrics and Monitoring Platform

A centralized dashboard for tracking key metrics related to clean energy and biotechnology initiatives is crucial for guiding investment and policy decisions. By integrating federal and regional data can provide a comprehensive, real-time view of progress across the country. This shared platform would enable better coordination among federal, state, and local agencies, ensuring that resources are allocated efficiently and that policy decisions are informed by accurate, up-to-date data. Moreover, a unified system would allow for more effective tracking of regional performance, enabling tailored solutions and based on localized needs and challenges. To this end:

The clean energy sector, and specifically SAF, highlights both the promise and the persistent challenges of scaling biotechnologies, reflecting broader issues, such as fragmented regulation, limited commercialization support, and misaligned incentives that hinder the deployment of advanced biotechnologies. Overcoming these systemic barriers requires coordinated, long-term policies including performance-based incentives, and procurement mechanisms that reduce investment risk and free up capital. SAF should be seen not as a standalone initiative but as a model for integrating biotechnology into industrial and energy strategy, supported by a robust innovation pipeline, expanded infrastructure, and shared metrics to guide progress. With sustained federal leadership and strategic alignment, the bioeconomy can become a key pillar of a low-carbon, resilient energy future.

It’s Summer, America’s Heating Up, and We’re Even More Unprepared

Summer officially kicked off this past weekend with the onset of a sweltering heat wave. As we hit publish on this piece, tens of millions of Americans across the central and eastern United States are experiencing sweltering temperatures that make it dangerous to work, play, or just hang out outdoors.

The good news is that even when the mercury climbs, heat illness, injury, and death are preventable. The bad news is that over the past five months, the Trump administration has dismantled essential preventative capabilities.

At the beginning of this year, more than 70 organizations rallied around a common-sense Heat Policy Agenda to tackle this growing whole-of-nation crisis. Since then, we’ve seen some encouraging progress. The new Congressional Extreme Heat Caucus presents an avenue for bipartisan progress on securing resources and legislative wins. Recommendations from the Heat Policy Agenda have already been echoed in multiple introduced bills. Four states, California, Arizona, New Jersey, and New York, now have whole-of-government heat action plans, and there are several States with plans in development. More locally, mayors are banding together to identify heat preparedness, management, and resilience solutions. FAS highlighted examples of how leaders and communities across the country are beating the heat in a Congressional briefing just last week.

But these steps in the right direction are being forestalled by the Trump Administration’s leap backwards on heat. The Heat Policy Agenda emphasized the importance of a clear, sustained federal governance structure for heat, named authorities and dedicated resourcing for federal agencies responsible for extreme heat management, and funding and technical assistance to subnational governments to build their heat readiness. The Trump Administration has not only failed to advance these goals – it has taken actions that clearly work against them.

The result? It’s summer, America’s heating up, and we’re deeply unprepared.

The heat wave making headlines today is just the latest example of how extreme heat is a growing problem for all 50 states. In just the past month, the Pacific Northwest smashed early-summer temperature records, there were days when parts of Texas were the hottest places on Earth, and Alaska – yes, Alaska – issued its first-ever heat advisory. Extreme heat is deadlier than hurricanes, floods, and tornadoes combined, and is exacerbating a mental-health crisis as well. By FAS’ estimates, extreme heat costs the nation more than $162 billion annually, costs that have made extreme heat a growing concern to private markets.

To build a common understanding of the state of federal heat infrastructure, we analyzed the status of heat-critical programs and agencies through public media, government reports, and conversations with stakeholders. All known impacts are confirmed via publicly available sources. We highlight five areas where federal capacity has been impacted:

This work provides answers to many of the questions our team has been asked over the last few months about what heat work continues at the federal level. With this grounding, we close with some options and opportunities for subnational governments to consider heading into Summer 2025.

What is the Current State of Federal Capacity on Extreme Heat?

Loss of leadership and governance infrastructure

At the time of publication, all but one of the co-chairs for the National Integrated Heat Health Information System’s (NIHHIS) Interagency Working Group (IWG) have either taken an early retirement offer or have been impacted by reductions in force. The co-chairs represented NIHHIS, the National Weather Service (NWS), Health and Human Services (HHS), and the Federal Emergency Management Agency (FEMA). The National Heat Strategy, a whole-of-government vision for heat governance crafted by 28 agencies through the NIHHIS IWG, was also taken offline. A set of agency-by-agency tasks for Strategy implementation (to build short-term readiness for upcoming heat seasons, as well as to strengthen long-term preparedness) was in development as of early 2025, but this work has stalled. There was also a goal to formalize NIHHIS via legislation, given that its existence is not mandated by law – relevant legislation has been introduced but its path forward is unclear. Staff remain at NIHHIS and are continuing the work to manage the heat.gov website, craft heat resources and information, and disseminate public communications like Heat Beat Newsletter and Heat Safety Week. Their positions could be eliminated if proposed budget cuts to the National Oceanic and Atmospheric Administration (NOAA) are approved by Congress.

Staffing reductions and actualized or proposed changes to FEMA and HHS, the federal disaster management agencies implicated in addressing extreme heat, are likely to be consequential in relation to extreme heat this summer. Internal reports have found that FEMA is not ready for responding to even well-recognized disasters like hurricanes, increasing the risk for a mismanaged response to an unprecedented heat disaster. The loss of key leaders at FEMA has also put a pause to efforts to integrate extreme heat within agency functions, such as efforts to make extreme heat an eligible disaster. FEMA is also proposing changes that will make it more difficult to receive federal disaster assistance. The Administration for Strategic Preparedness and Response (ASPR), HHS’ response arm, has been folded into the Centers for Disease Control and Prevention (CDC), which has been refocused to focus solely on infectious diseases. There is still little public information for what this merger means for HHS’ implementation of the Public Health Service Act, which requires an all-hazards approach to public health emergency management. Prior to January 2025, HHS was determining how it could use the Public Health Emergency authority to respond to extreme heat.

Loss of key personnel and their expertise

Many key agencies involved in NIHHIS, and extreme heat management more broadly, have been impacted by reductions in force and early retirements, including NOAA, FEMA, HHS, the Department of Housing and Urban Development (HUD), the Environmental Protection Agency (EPA), the U.S. Forest Service (USFS), and the Department of Energy (DOE). Some key agencies, like FEMA, have lost or will lose almost 2,000 staff. As more statutory responsibilities are put on fewer workers, efforts to advance “beyond scope” activities, like taking action on extreme heat, will likely be on the back burner.

Downsizing at HHS has been acutely devastating to extreme heat work. In January, the Office of Climate Change and Health Equity (OCCHE) was eliminated, putting a pause on HHS-wide coordination on extreme heat and the new Extreme Heat Working Group. In April, the entire staff of the Climate and Health program at CDC, the Low Income Home Energy Assistance Program (LIHEAP), and all of the staff at the National Institute for Occupational Safety and Health (NIOSH) working on extreme heat, received reduction in force notices. While it appears that staff are returning to the CDC’s National Center for Environmental Health, they have lost months of time that could have been spent on preparedness, tool development, and technical assistance to local and state public health departments. Sustained funding for extreme heat programs at HHS is under threat, the FY2026 budget for HHS formally eliminates the CDC’s Climate and Health Program, all NIOSH efforts on extreme heat, and LIHEAP.

Risks to data, forecasts, and information availability, though some key tools remain online

Staff reductions at NWS have compromised local forecasts and warnings, and some offices can no longer staff around-the-clock surveillance. Staff reductions have also compromised weather balloon launches, which collect key temperature data for making heat forecasts. Remaining staff at the NWS are handling an increased workload at one of the busiest times of the year for weather forecasting. Reductions in force, while now reversed, have impacted real-time heat-health surveillance at the CDC, where daily heat-related illness counts have been on pause since May 21, 2025 and the site is not currently being maintained as of the date of this publication.

Some tools remain online and available to use this summer, including NWS/CDC’s HeatRisk (a 7-day forecast of health-informed heat risks) and the National Highway Traffic Safety Administration’s Heat-Related EMS Activation Surveillance Dashboard (which shows the number of heat-related EMS activations, time to patient, percent transported to medical facilities, and deaths). Most of the staff that built HeatRisk have been impacted by reductions in force. The return of staff to the CDC’s Climate and Health program is a bright spot, and could bode well for the tool’s ongoing operations and maintenance for Summer 2025.

Proposed cuts in the FY26 budget will continue to compromise heat forecasting and data. The budget proposes cutting budgets for upkeep of NOAA satellites crucial to tracking extreme weather events like extreme heat; cutting budgets for the National Aeronautics and Space Administration’s LandSat program, which is used widely by researchers and private sector companies to analyze surface temperatures and understand heat’s risks; and fully defunding the National Environmental Public Health Tracking Network, which funds local and state public health departments to collect heat-health illness and death data and federal staff to analyze it.

Rollbacks in key funding sources and programs for preparedness, risk mitigation and resilience

As of May 2025, both NIHHIS Centers of Excellence – the Center for Heat Resilient Communities and the Center for Collaborative Heat Monitoring – received stop work orders and total pauses in federal funding. These Centers were set to work with 26 communities across the country to either collect vital data on local heat patterns and potential risks or shape local governance to comprehensively address the threat of extreme heat. These communities represented a cross-cut of the United States, from urban to coastal to rural to agricultural to tribal. Both Center’s leadership plans to continue the work with the selected communities in a reduced capacity, and continue to work towards aspirational goals like a universal heat action plan. Future research, coordination, and technical assistance at NOAA on extreme heat is under fire with the proposed total elimination of NOAA Research in the FY26 budget.

At FEMA, a key source of funding for local heat resilience projects, the Building Resilience Infrastructure and Communities (BRIC) program, has been cancelled. BRIC was the only FEMA Resilience grant that explicitly called out extreme heat in its Notice of Funding Opportunity, and funded $13 million in projects to mitigate the impacts of extreme heat. Many states have also faced difficulties in getting paid by FEMA for grants that support their emergency management divisions, and the FY26 budget proposes cuts to these grant programs. The cancellation of Americorps further reduces capacity for disaster response. FEMA is also dropping its support for improving building codes that mitigate disaster risk as well as removing requirements for subnational governments to plan for climate change. 

At HHS, a lack of staff at CDC has stalled payments from key programs to prepare communities for extreme heat, the Building Resilience Against Climate Effects (BRACE) grant program and the Public Health Preparedness and Response program. BRACE is critical federal funding for state and local climate and health offices. In states like North Carolina, the BRACE program funds live-saving efforts like heat-health alerts. Both of these programs are proposed to be totally eliminated in the FY26 budget. The Hospital Preparedness Program (HPP) is also slated for elimination, despite being the sole source of federal funding for health care system readiness. HPP funds coalitions of health systems and public health departments, which have quickly responded to heat disasters like the 2021 Pacific Northwest Heat Domes and established comprehensive plans for future emergencies. The National Institutes of Health’s Climate and Health Initiative was eliminated and multiple grants paused in March 2025. Research on extreme weather and health may proceed, according to new agency guidelines, yet overall cuts to the NIH will impact capacity to fund new studies and new research avenues. The National Institute of Environmental Health Sciences, which funds research on environmental health, faces a 36% reduction in its budget, from $994 million to $646 million.

Access to cool spaces is key to preventing heat-illness and death. Yet cuts, regulatory rollbacks, and program eliminations across the federal government are preventing progress towards ensuring every American can afford their energy bills. At DOE, rollbacks in energy efficiency standards for cooling equipment and the ending of the EnergyStar program will impact the costs of cooling for consumers. Thankfully, DOE’s Home Energy Rebates survived the initial funding freezes and the funding has been deployed to states to support home upgrades like heat pumps, insulation, air sealing, and mechanical ventilation. At HUD, the Green and Resilient Retrofits Program has been paused as of March 2025, which was set to fund important upgrades to affordable housing units that would have decreased the costs of cooling for vulnerable residents. At EPA, widespread pauses and cancellations in Inflation Reduction Act programs have put projects to provide more affordable cooling solutions on pause. At the U.S. Department of Agriculture, all grantees for the Rural Energy for America Program, which funds projects that provide reliable and affordable energy in rural communities, have been asked to resubmit their grants to receive allocated funding. These delays put rural community members at risk of extreme heat this summer, where they face particular risks due to their unique health and sociodemographic vulnerabilities. Finally, while the remaining $400 million in LIHEAP funding was released for this year, it faces elimination in FY26 appropriations. If this money is lost, people will very likely die and utilities will not be able to cover the costs of unpaid bills and delay improvements to the grid infrastructure to increase reliability.

Uncertain progress towards heat policy goals

Momentum towards establishing a federal heat stress rule as quickly as possible has stalled. The regulatory process for the Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings is proceeding, with hearings that began June 16 and are scheduled to continue until July 3. It remains to be seen how the Occupational Safety and Health Administration (OSHA) will proceed with the existing rule as written. OSHA’s National Emphasis Program (NEP) for Heat will continue until April 6, 2026. This program focuses on identifying and addressing heat-related injuries and illnesses in workplaces, and educating employers on how they can reduce these impacts on the job. To date, NEP has conducted nearly 7,000 inspections connected to heat risks, which lead to 60 heat citations and nearly 1,400 “hazard alert” letters being sent to employers.

How Can Subnational Governments Ready for this Upcoming Heat Season?

Downscaled federal capacity comes at a time when many states are facing budget shortfalls compounded by federal funding cuts and rescissions. The American Rescue Plan Act, the COVID-19 stimulus package, has been a crucial source of revenue for many local and state governments that enabled expansion in services, like extreme heat response. That funding must be spent by December 2026, and many subnational governments are facing funding cliffs of millions of dollars that could result in the elimination of these programs. While there is a growing attention to heat, it is still often deprioritized in favor of work on hazards that damage property.

Even in this environment, local and state governments can still make progress on addressing extreme heat’s impacts and saving lives. Subnational governments can:

FAS stands ready to support leaders and communities in implementing smart, evidence-based strategies to build heat readiness – and to help interested parties understand more about the impacts of the Trump administration’s actions on federal heat capabilities. Contact Grace Wickerson (gwickerson@fas.org) with inquiries.

Impacts of Extreme Heat on Rural Communities

46 million rural Americans face mounting risks from temperature extremes that threaten workforce productivity, raise business operational costs, and strain critical public services. Though extreme heat is often portrayed in research and the media as an urban issue, almost every state in the contiguous U.S. has rural communities with above-average rates of vulnerability to extreme heat. To protect rural America, Congress must address extreme heat’s impacts by repairing rural health systems, strengthening the preparedness of rural businesses, and hardening rural energy infrastructure.

Extreme heat exacerbates rural communities’ unique health vulnerabilities

On average, Americans living in rural areas are twice as likely as those in urban areas to have pre-existing health conditions, like heart disease, diabetes, and asthma, that make them more sensitive to heat-related illness and death. Further compounding the risk, rural places also have larger populations of underinsured and uninsured people than urban areas, with 1 in 6 people lacking insurance. 

Limited healthcare infrastructure in rural places worsens these vulnerabilities. Rural areas have higher shortages of healthcare professionals who provide primary care, mental health, and dental services than urban areas. Over the last decade, 100 rural hospitals have closed, and hundreds more are vulnerable to closure. Finally, many rural communities do not have public health departments, and those that do are underfunded and understaffed. Because public health systems and healthcare professionals are the first responders to extreme heat, rural residents are severely underprepared. 

Congress should provide flexible resources and technical assistance to rural hospitals to prepare for emerging threats like extreme heat. Additionally, Congress should continue to enable the U.S. Department of Agriculture and the Department of Health and Human Services to provide loans or grant assistance to help rural residents retain access to health services and improve the financial position of rural hospitals and clinics. And because Medicaid expansion correlates with better rural hospital financial performance and fewer closures, Congress should invest in Medicaid to protect rural healthcare access.

Extreme heat puts rural businesses and workers at risk

Rural economic health relies on the outdoors (e.g., recreation tourism) and outdoor labor (e.g., agriculture and oil and gas extraction). Extreme heat in many of these places makes it dangerous to be outside, which impacts worker productivity and local business revenues. Indoor workers in facilities like manufacturing plants, food processing, and warehouses also face heat-related safety threats due to the presence of heat-producing machines and poorly ventilated buildings with limited cooling. These facilities are rapidly growing components of rural economies, as these sectors employ almost 1 in 5 rural workers. 

Simple protections like water, rest, shade, and cooling can improve productivity and generate returns on investments. But small-to-medium rural enterprises need support to adopt affordable cooling systems, shade and passive cooling infrastructure, and worker safety measures that reduce heat-related disruptions. Congress should help rural businesses reduce heat’s risks by appropriating funding to support workplace heat risk reduction and practical training on worker protections. Additionally, Congress should require OSHA to finalize a federal workplace heat standard.

Extreme heat threatens rural energy security

When a power outage happens during a severe extreme heat event, the chance of heat-related illness and death increases exponentially. Extreme heat strains power infrastructure, increasing the risk of power outages. This risk is particularly acute for rural communities, which have limited resources, older infrastructure, and significantly longer waits to restore power after an outage.

Weatherized housing and indoor infrastructure are one of the key protective factors against extreme heat, especially during outages. Yet rural areas often have a higher proportion of older, substandard homes. Manufactured and mobile homes, for example, compose 15% of the rural housing stock and are the one of the most at-risk housing types for extreme heat exposure. When the power is on, rural residents spend 40% more of their income on their energy bills than their urban counterparts. Rural residents in manufactured housing spend an alarming 75% more. Energy debt can force people to choose between paying for life-saving energy or food and key medications, compounding poverty and health outcomes. 

To drive the energy independence and economic resilience of rural America, Congress should support investments in energy-efficient and resilient cooling technologies, weatherized homes, localized energy solutions like microgrids, and grid-enhancing technologies.

Economic Impacts of Extreme Heat: Energy

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

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

Challenge & Opportunity: Grid Security

Extreme Heat Reduces Energy Generation and Transmission Efficiency

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

Rising Demand and Grid Load Increase the Threat of Power Outages

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

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

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

Advancing Solutions for Energy Systems and Grid Security

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

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

Challenge & Opportunity: Increasing Household and Business Energy Costs

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

Advancing Solutions for Businesses, Households, and Vital Facilities

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

The Federation of American Scientists: Who We Are

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

Consider FAS a resource for… 

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

Senior Manager, Climate and Health
Grace Wickerson
Medical Innovation,
Emerging Technologies
read more
Senior Associate, Climate, Health, and Environment
Autumn Burton
Environmental Health,
Resilient Communities,
Extreme Weather,
Inclusive Innovation & Technology
read more
Associate Director, Climate and Environment
Hannah Safford
read more

Winning the Next Phase of the Chip War

Last year the Federation of American Scientists (FAS), Jordan Schneider (of ChinaTalk), Chris Miller (author of Chip War) and Noah Smith (of Noahpinion) hosted a call for ideas to address the U.S. chip shortage and Chinese competition. A handful of ideas were selected based on the feasibility of the idea and its and bipartisan nature. This memo is one of them.

Summary

  1. Danger Ahead: Until now, the U.S. semiconductor policy agenda focused on getting an edge over China in the production of advanced semiconductors. But now a potentially even more  substantial challenge looms. Possible Chinese dominance in so-called ‘legacy’ chips  essential for modern economic life could grant it unacceptable leverage over the United  States. This challenge will require tools far more disruptive than ever before considered by policymakers for the chip competition. 
  2. The Foot on America’s Economic Neck: Collecting offensive economic leverage lies at the  heart of Chinese leader Xi Jinping’s strategy. Chinese dominance in legacy chips could  enable Beijing’s bullying of the United States it has thus far reserved for U.S. allies. China’s  growing leverage over Washington may embolden Beijing to think it could attack Taiwan with  relative impunity. 
  3. Familiar Semiconductor Policy Tools Won’t Work Alone: China increasingly has access to  the tech it needs for its legacy ambitions (via stockpiling and indigenization), damaging  possible expanded export controls. And unfair Chinese trade practices could reduce the  benefits of subsidies, as it has for solar and critical minerals. 
  4. Learning to Love Trade Protection: Only when the U.S. market cannot access Chinese  chips will they have sufficient incentive to manufacture chips in third countries. Washington could either turn to tariffs or outright bans on Chinese chips. Washington has several options  to block China’s chips – AD/CVD, 337, ‘ICTS’, 5949, and 232. But the most powerful tool would be Section 301 of the Trade Act of 1974. 
  5. The Keys to Success: Trade measures will have to target Chinese chips contained within  other products, not just the chips themselves. The U.S. government’s clarity into global  supply chains will have to grow dramatically. Allied participation and knowledge-sharing  might be needed. The United States can ease enforcement of a chips trade war by  incentivizing private industry to share the burden of detecting violations of U.S. law.  

The Generational Leap in U.S. Chip Policy 

For five years, U.S. concerns over China’s semiconductor sector focused on its cutting-edge chip  production. The bipartisan instinct has been to mix restrictions on Chinese access to Western  technology and to fund manufacturing of advanced chips at home. It began with the Trump  administration’s sanctions against Chinese chip giants Fujian Jinhua, Huawei, and SMIC. The Biden administration’s October 2022 export controls on China’s advanced chipmakers and the CHIPS and Science Act crowned a new era of technology competition focused on the absolute bleeding edge.  

Fast forward to July 2024: Washington entered the next phase of the chip war.  

Biden administration concerns about legacy chips emerged subtly last summer from one-off statements from Commerce Secretary Gina Raimondo. Before long Team Biden began to formally investigate the issue in an industry survey. Then in May the administration doubled existing tariffs on Chinese-made chips from 25% to 50%. 

Congress is equally concerned. The bipartisan China Committee endorsed tariffs on Chinese legacy chips in its December 2023 economic report and in a January 2024 letter to the administration. China’s growing position in the production of mature-node chips took center stage in a Committee hearing in June 2024, where Committee Chair John Moolenaar called for “a reliable domestic supply of semiconductors outside the reach of the CCP”. 

This apparently sudden shift reflects the growth of the stakes in the U.S.-China chip competition over the past year: 

Despite the scale of the challenge, Washington has not yet decided on its strategy to take on the  problem. The best approach to the legacy challenge will be one that can prevent U.S. reliance on  Chinese-made chips to ensure China cannot capture decisive leverage over the U.S. economy.  Doing so will require using trade measures to reject Chinese chips from the U.S. altogether.  

Dominance Means Leverage 

China’s fast-rising position in the legacy chip industry threatens U.S. national security because it  would grant Beijing extraordinary strategic leverage over the United States. That would encourage Chinese economic coercion and even a war over Taiwan.  

2.1. Xi’s Plan for ‘Offensive Leverage’: Geoeconomics lies at the heart of Chinese leader Xi  Jinping’s international strategy. The strategy is to exploit foreign dependence on Chinese critical  supply chains to accomplish Beijing’s objectives abroad. 

Xi himself laid the foundation of this vision in a pair of speeches in 2020 in which he called for  economic “deterrence” over the rest of the world. He called for an economic “gravitational field”  to “benefit the formation of new advantages for participating in international competition and  cooperation”. China would achieve this by heightening “the dependent relationships of international  industrial chains on our country, to form a powerful countermeasure and deterrence capability  against external parties who artificially cut off supply”, according to Xi. 

The Chinese Communist Party’s 2021 Five-Year Plan enshrined these principles in Party jargon,  calling for a “powerful domestic market and strong-trading country” to “form a powerful gravitational  field for global production factors and resources”. This is often called the “dual circulation” strategy by outside observers. It could more usefully be  called “offensive leverage”. 

2.2. Beijing’s Bullying Could Come for Washington: Since Xi Jinping rose to power in 2012, China  has repeatedly demonstrated these geoeconomic principles by flashing its economic strength to accomplish strategic objectives. 

The list of examples of Chinese economic coercion is long. In 2010, China limited Japanese  purchases of rare-earth minerals over a Senkaku Islands dispute. Norwegian salmon rotted that  same year on Chinese docks in retaliation for dissident Liu Xiaobo winning the Nobel Peace Prize. In  2012, Philippine bananas also rotted over the Scarborough Shoal dispute. In 2016, Beijing conveyed its displeasure toward Seoul for agreeing to host U.S. missile defense systems by squeezing South  Korean auto sales in China and slashing Chinese tourism in the country. 

This bullying has not slowed since Xi unveiled his economic thinking in 2020. That year, China  embargoed Australian wine, barley, wheat, coal, fish, and other products after Canberra passed  laws to reduce foreign influence and called for an investigation into the origins of Covid-19.In 2021, China blocked imports of Lithuanian goods over the state opening a “Taiwanese Representative  Office”. In just the past month, Beijing has threatened French luxury brands, German car makers, and Spanish pork producers in retaliation for EU duties on Chinese electric vehicles. 

Washington faces less blatant coercion compared to its allies. True, China has targeted U.S. firms  such Micron over the past few years. But the scale and ambition of this bullying has never  approached what China has applied to the likes of Australia and Lithuania. This may be because  Beijing does not believe it yet maintains necessary leverage over Washington to brandish its  economic blade as it does toward smaller economies.  

China’s growing position in the legacy semiconductor market could change that. How would  Beijing’s behavior change if sales of the Ford F-150 relied on Beijing’s willingness to sell its semiconductors?  

2.3. Reliance Endangers Taiwan: Western European reliance on Russian energy was one factor (among many) that encouraged Vladimir Putin to believe he could invade Ukraine with relative impunity. Likewise, deepening U.S. dependence on China for strategic supply chains could make it  far more difficult to challenge Beijing on sensitive geopolitical issues.  

The United States already relies on China for other key inputs to its economy: generic  pharmaceuticals, critical minerals, solar panels, and printed circuit boards, among others. U.S.  reliance on Chinese-made legacy chips – the product at the heart of modern economic life – could be the crown jewel of Chinese geoeconomics. American economic reliance on China could embolden Xi Jinping to think he could attack Taiwan with tolerable penalty.  

The Case for Blocking China’s Chips 

Familiar semiconductor policy approaches – export controls and subsidies – are inadequate alone to prevent reliance on Chinese-made legacy chips. Washington and its allies will instead have to turn  to the old-fashioned, disruptive tools of trade defense in the face of a challenge of this scale.  

3.1. It’s Too Late for Export Controls: The crux of current U.S. semiconductor policy toward China  is to contain the growth of Chinese advanced chip production by limiting its access to exquisite  machine tools produced by the United States and its allies (often called the ‘restrict’ agenda). Without those tools, China will be unable to build the cutting-edge chips that enable AI and  advanced weapons.  

Why not do the same for legacy chips? Washington and its allies could grow its existing rules so that China could not purchase machines capable of manufacturing legacy chips from Western producers. 

The issue is that China increasingly already has the tools it needs for its legacy chip production, in two ways: 

Export controls may have worked for the legacy challenge five or ten years ago. It’s unlikely to work alone today. 

3.2. Chinese Trade Practices Undermine Subsidies: The second pillar of Washington  semiconductor strategy for the past couple of years has been what’s often called the ‘promote’  agenda. The United States is deploying $39 billion in subsidies through the 2022 CHIPS and Science  Act to incentivize new chip factories at home. The strategy has helped galvanize $447 billion in  private investment across 25 states, 37 new chip fabs, and expansions at 21 other fabs. The United  States is now projected to make 30% of all advanced logic chips by 2032. But the CHIPS and Science Act  focuses on advanced chips, not legacy ones. Only a quarter of CHIPS funding ($10 billion) is planned to be spent on legacy-chip production.

Why not pass a Chips Act for legacy chips? California Representative Ro Khanna has called for doing  so: “a Chips Act 2.0 and 3.0 to better focus on legacy chips for our cars, refrigerators, and dryers”.  Indeed, subsidies may be a key tool to spur additional domestic legacy chip  production.  

But subsidies alone are unlikely to rise to the challenge. China’s “brute force” economic strategy  might render a legacy ‘promote’ agenda stillborn.  Beijing’s approach is to eliminate foreign  competitors with low prices by flooding international markets with state-sponsored artificially high  supply. China could flood the market with cheap chips to deter private Western investment into new chip production despite generous subsidies. The result could be billions of taxpayer dollars spent  with insufficient new chip capacity to show for it. 

Two recent examples demonstrate how Chinese industrial policy practices can undermine  Washington ‘promote’ policy: 

One Pentagon-funded Idaho mine, the only cobalt mine in the United States, was planned to open last year. It’s instead been mothballed since over low cobalt prices – down by almost two-thirds in two years.The  owner of that mine, Australian firm Jervois, told investors in March it would lay off 30% of its senior corporate management over “adverse cobalt market conditions caused by Chinese  overproduction and its impact on pricing”.

The warning signs in the legacy chip sector are already flashing. Chinese semiconductors were “20  to more than 30%” cheaper than their international counterparts in 2022 and 2023, according to the  Silverado Policy Accelerator.This price advantage will likely only widen with time. 

3.3. Don’t Compete with China on Price: The challenge facing U.S. policymakers is that Chinese  industrial policy is designed to make it impossible for Western firms to offer prices competitive  against Chinese players. The solution is to deny Chinese chips access to Western markets.  

The logic is simple yet unfamiliar for some following semiconductor policy. Only if the U.S. market is denied to Chinese chips will those producing for the United States be forced to source chips outside  of China, and only then will the construction of scaled chipmaking capacity in third countries  become economic.  

How It Would Work 

Preventing U.S. reliance on Chinese chips would be more complicated than simply raising the tariff  on Chinese-made chips imported into the U.S. market. For it to work, Washington would need to  target goods that contain Chinese chips, not just the imports of the chips themselves. It also may need allied cooperation.  

4.1. Target Chips as Components, not the Chips Themselves: Semiconductors are  overwhelmingly an intermediate good, not a final product of the sort Washington typically tariffs or blocks at the border. U.S. policy will have to reflect that complexity.  

The Biden administration in May doubled U.S. tariffs on imported Chinese chips from 25% to 50%,  citing China’s “rapid capacity expansion that risks driving out investment by market-driven firms”. The original 25% tariff, imposed by the Trump administration in 2018, reduced direct imports of  Chinese chips by around 72%, according to the U.S. International Trade Commission. But direct  imports represent only a portion – likely a minority portion – of the Chinese-made chips that  otherwise enter the United States as components within other devices. 

The original 2018 tariffs had no effect on Chinese chips arriving as components of other goods – and  neither will the new Biden tariffs, which double the rate of the 2018 tariffs without changing their design. Closing this loophole would require the administration to do just that.  

One way of doing so would be to apply a “component tariff”, effectively increasing the import cost of  the final good (whatever it is) because it contains a chip or chips made in China. The China Committee called for this in January 2024. Another way would be to deny outright products containing Chinese chips entry into the United States. Both options could work, assuming a component tariff is  high enough to overcome any possible Chinese price advantage (e.g., 200% or higher).  

Some experts have expressed doubt that it is even possible as a policy matter to target Chinese chips  because they are intermediate goods. But this view is erroneous. In fact, various laws allow  Washington to tariff or outright exclude from the U.S. market any product made with Chinese  semiconductors. (See Section 5). 

4.2. Bring the Allies Along: A strategy to prevent U.S. reliance on Chinese chips would have higher  odds of success if U.S. allies join, most importantly Europe and Japan. The risk is that without allies,  international chip players would continue to design their microelectronics with Chinese chips, leaving the United States out of the best the market has to offer. A more optimistic assessment would be that the U.S. consumer market is so large that unilateral Washington action would be  enough to force leading market players to design their products without Chinese chips. 

Either way, allied signals are positive. The EU said about legacy chips last  April that it was “gathering  information on this issue”, and that it would coordinate with the United States to “collect and share  non-confidential information” about Chinese “non-market policies and practices”.The bloc’s new  duties on Chinese automakers indicate it could be open to similar measures toward chips. Japan  has taken fewer concrete steps than Europe, but Tokyo’s Minister for Economy, Trade and Industry Ken Saito told reporters that participants took “great interest” in legacy chips at the first Japan Korea-U.S. Commerce and Industry Ministerial Meeting on 28 June 2024. 

Washington’s Toolkit 

The United States has multiple policy tools that could be used to prevent U.S. reliance on Chinese made semiconductors. Th following summarizes these tools, in roughly ascending order of magnitude.  

5.1. Countervailing Duties: This form of tax can be placed by the Commerce Department on foreign goods that it finds to be subsidised and that the U.S. International Trade Commission (ITC) finds  materially injure a U.S. domestic industry. After an investigation prompted either by a petition from U.S. industry or initiated by Commerce itself, Commerce can impose “CVDs” on the goods in  question. 

Two challenges, however: First, it can sometimes be difficult to prove that Chinese state subsidies  have boosted specific goods. Second, chips imported as components of other goods aren’t a natural  fit for CVD investigations, so some policy creativity would likely be required. 

5.2. Anti-Dumping Duties: This alternative tax is like its sister duty in how it comes about and who  investigates it, but in this case it seeks to counter imports that have been “dumped” at artificially low prices in the U.S. market. 

As with CVDs, however, some policy creativity may be required to use anti-dumping duties for chips  imported as components of other goods. Further, it can be challenging to establish a baseline “fair”  price against which to measure the price of any Chinese goods in the U.S. market. Former senior Commerce official Nazak Nikakhtar noted: “It is nearly impossible to find a surrogate  country that has not been adversely affected by the PRC’s predatory pricing. . . . Virtually all  benchmark prices in trade cases are now understated and inadequate for measuring [dumping] by the PRC.” 

5.3. Section 337: This provision (from the Tariff Act of 1930) allows the U.S. ITC to investigate  imported goods for alleged links to intellectual-property theft and a range of other unfair trade  practices. Relief can take the form of exclusion orders, cease-and-desist orders, or sequestration of goods.  

But the 337’s bureaucratic process might be too burdensome. The ITC is an independent agency not subject to direction by the White House. In 2018, the Commission on the Theft of American  Intellectual Property, led by ex-ambassador and ex-governor Jon Huntsman, recommended speeding up the ITC’s 337 process.

5.4. Section 5949: With relatively little fanfare, Congress in late 2022 enacted a measure that will  curb some Chinese legacy-chip sales in the U.S. market – but only some, and slowly. Via Section  5949 of the annual defence bill, Congress prohibited the U.S. federal government and its contractors  from procuring semiconductors for “critical” uses from three Chinese firms (SMIC, YMTC, CXMT),  beginning in four years. This provision could be expanded in multiple ways that would block Chinese chips from large swathes of the U.S. market. Policymakers could shorten the phase-in period, blacklist additional companies (beside SMIC, YMTC and CXMT), or force U.S. government  contractors not to buy proscribed Chinese chips even for their own private use.

The federal government does not, however, have the authority to force state governments to adopt similar rules. This approach would also allow any company that does not contract with the federal  government to purchase Chinese chips.  

5.5. ‘ICTS’: The Commerce Department’s “Information and Communications Technology and  Services” (ICTS) regime is probably capable of restricting the import of goods containing Chinese made chips. The regime, first outlined in the final days of the Trump administration and embraced by  the Biden administration, has broad authorities to restrict transactions (from limits on cross-border  data flows to import bans) across theoretically the entire digital economy: critical infrastructure,  network infrastructure, data hosting, surveillance and monitoring tech, communications software, and emerging technology.The ICTS office’s current investigation on Chinese ‘Connected Vehicles’, will restrict Chinese-controlled critical components from being used in cars on U.S. roads. The  president might similarly be able to use ICTS to restrict the import of products containing Chinese made semiconductors.  

Taking on Chinese legacy chips, however, would not fit the ICTS Office neatly:

5.6. Section 232: This instrument (from the Trade Expansion Act of 1962) allows any federal  department to require a Commerce Department investigation of specified imports that may threaten  national security (defined broadly). The President may then impose tariffs or quotas as a remedy.  The Trump administration used Section 232 to tariff imports of steel and aluminum in 2018, and it  could be a viable approach to legacy chips too.  

232’s main drawback is that it does not allow import bans. An obvious workaround would be to apply a component tariff onto Chinese semiconductors so high that it works effectively as a ban (e.g., north  of 200%).  

5.7. Washington’s Most Powerful Tool – Section 301: The strongest tool for the legacy-chips  challenge might be the Section 301 of the Trade Act of 1974, which gives the Office of the U.S. Trade  Representative broad scope investigate “unreasonable”, “discriminatory”, or  “unjustifiable” actions that burden U.S. commerce.  After an investigation, USTR has sweeping  powers to impose remedies as it sees fit, e.g. with tariffs, import bans, or other sanctions. It gives a president notably broad, flexible, and discretionary powers. 

301 has become the bipartisan tool of choice to address unfair Chinese trade and industrial practices and to reshore supply chains: 

A future 301 investigation could almost certainly find a way to prohibit goods with Chinese-made semiconductors from entering the U.S. market. The United States could open a 301 investigation into  Beijing’s state-led subsidy strategy to do so, as the Biden administration considered doing in 2021. 

Some may worry that 301’s required investigation before applying remedies would slow down a  solution that would ideally begin as soon as possible. But a public investigation of China’s position in the semiconductor industry could have major benefits. It could provide the administration insight into the international microelectronics supply chain, needed to implement a legacy restriction policy. 

And it would send industry a clear message that it should begin shifting its supply chains before the new U.S. policy began.  

Some of History’s Lessons on Decoupling  

One challenge facing this strategy is if it is practically possible to stop Chinese-made chips from  entering the U.S. market, no matter U.S. law. Some have called banning Chinese chips tantamount to trying to “hold sand in your hands”. The U.S. government has limited visibility into global supply chains. How could Washington enforce the next phase of China chips containment? 

Two examples of U.S. efforts to remove goods from international supply chains point to lessons about how the United States could go about doing so successfully today: implementation of the  Uyghur Forced Labor Prevention Act (UFLPA), and the ‘Kimberley Process’ to prevent sourcing blood  diamonds from Africa. They show that Washington will need three things to enforce this strategy: supply chain clarity, active participation from private industry to detect lawbreakers, and an allied  coalition to ensure success in preventing U.S. reliance on Chinese-made chips.  

6.1. Improving on the UFLPA Enforcement: Removing Chinese-made legacy chips from the U.S.  market would not be the first time Washington moved to fundamentally change the U.S.-China  trading relationship in pursuit of excising specific Chinese goods from the United States. The Uyghur Forced Labor Prevention Act, passed by Congress in late 2021, prohibited entirely any goods from  Xinjiang – or those with supply chains stemming from there – from coming into the United States on  grounds that they were tainted with forced labor. UFLPA Republican co-author Marco Rubio vowed  in 2021 that it would “fundamentally change our relationship with Beijing”. Jim McGovern, the  Democratic congressman who authored the House version of the bill, said “No more business as  usual”. 

Yet the law has had a less significant impact on U.S.-China trade flows than initially anticipated, most importantly in the solar industry. Some half of all global polysilicon, a base material for solar panels, comes from Xinjiang. Chinese firms have nonetheless increased their market share in the  United States since the passage of the UFLPA. 

There are three lessons to take from these challenges that policymakers can apply to the coming legacy chip trade war: 

  1. Supply Chain Clarity Needed: The UFLPA granted the administration no additional funding  for enforcement, likely forcing difficult decisions across the administration of how to fund  the stiff demands for research into global forced labor supply chains. Enforcing legacy-chip  protectionism would likely require a major expansion of supply chain analytical capabilities  across the U.S. government, including in the Commerce Department and within Customs  and Border Protection. 
  2. Let Private Industry Help with Enforcement: UFLPA enforcement might have been more  successful if detecting those who violated U.S. law was the responsibility of private industry,  not that of the government. Is this even possible?  


It appears so. The False Claims Act of 1863 allows private parties to initiate a lawsuit on  behalf of the U.S. government against those who have defrauded the U.S. government. Whistleblowers receive some 15% to 30% of the government’s award if they win. This law,  originally passed in the Civil War to crack down on fraud from military contractors, has  increasingly been used against those who commit customs and tariffs fraud. The law triples damages and civil penalties for violators.  

These cases (called “qui tam” cases) have been brought against those who transshipped  Chinese goods through third countries to dodge 301 tariffs. In one case, manufacturing  tools firm King Kong Tools paid $1.9 million in November 2023 to settle allegations that the  firm dodged paying 301 tariffs by falsely claiming its goods were made in Germany. The  case began when a competitor to King Kong brought a qui tam suit alleging that King Kong  produced its products in China, shipped them to Germany, then sent them to the United  States. The whistleblower received an award of $286,000. 

Washington could similarly enlist the private sector to help detect violations of legacy-chip trade rules. At a minimum, the Justice Department could begin a public campaign to  encourage whistleblowers to bring qui tam cases against violators. (Including technology research firms. TechInsights, the company known for teardowns of Chinese  microelectronics to determine their quality, comes to mind here.) The U.S. government  could also find ways to increase the incentive for private parties to bring cases against tariff  dodgers. Congress could update the False Claims Act to boost the reward for whistleblowers,  for example.  

6.2. An Allied System for Legacy-Chip Trade Protection: The Kimberley Process is a UN-mandated  certification scheme launched in 2003 to prevent diamonds that fund conflict from entering global  markets. 85 member states, civil society groups, and industry agreed to commit to transparent  practices and share data to certify that imported diamonds are not tainted by conflict. 

Washington and its allies should agree to collectively work to restrict the import of Chinese made legacy chips. They could share best practices and supply chain intelligence. It could make it  easier for Washington to know where Chinese semiconductors are moving throughout global supply chains. Doing so would help build an allied coalition collectively more resilient against Beijing’s economic coercion. 

The U.S. Bioeconomy needs biomass, but what is it and how do we use it?

In the quest for sustainable energy and materials, biomass emerges as a key player, bridging the gap between the energy sector and the burgeoning U.S. and regional bioeconomies (microbioeconomies). Despite often being pigeonholed as fuel for energy production, biomass holds far-reaching potential that extends beyond combustion. Identifying sustainable biomass feedstocks that are easily accessible and consistent in their makeup could be a game-changer to help regions unlock their bioeconomy potential and support scientific innovations toward more environmentally sustainable materials and chemicals.

Biomass is defined as “any organic matter that is available on a renewable or recurring basis, including agricultural crops and trees, wood and wood residues, plants, algae, grasses, animal manure, municipal residues, and other residue materials” by the Foundation for Food & Agriculture Research (FFAR). Biomass has mainly been viewed by the public as a source of energy through burning or for chemical conversion into biofuels, encouraged by federal incentive programs, including those from the United States Department of Agriculture (USDA) and the Department of Energy (DOE). However, aside from burning or conversion for biofuel, biomass can undergo a complex process of chemical or biological breakdown and be transformed into various building block components that can be used for a wide range of biotechnology applications.

Once the biomass is broken down into its functional components it can be used as a feedstock, which is a “resource used as the basis for manufacturing another product. [Often], . . . a source of carbon to produce an array of chemicals.” For example, lignocellulosic biomass, plant or plant-based materials not used for food, can be hydrolyzed into sugars, which serve as precursors for bio-based chemicals and materials. This allows for new, environmentally sustainable chemicals for use in biotechnology and biomanufacturing applications, thus positioning biomass as a cornerstone resource of the U.S. bioeconomy. In addition to biochemical production, biomass, and feedstock are used in the bioeconomy in bioplastics and biomaterials. To push the U.S. bioeconomy toward environmental sustainability, it is critical to begin building programmatic and physical infrastructure to harness biomass, which is ultimately converted into feedstock using biotechnology applications and used in the biomanufacturing process to create everyday materials for the public.

Not All Biomass is Used for Energy, or Sustainably Produced

While biomass holds promise as a renewable energy source, not all biomass is used for energy, and not all of it is sustainable. Corn is a consistent poster child of the biomass and biofuel industry as a sustainable way to power combustion engines. Yet, the growth of corn relies heavily on the extensive use of fertilizers and pesticides, which can lead to soil erosion, water pollution, and habitat degradation. Depending on how a company conducts its Life Cycle Assessment and Carbon Intensity of its supplies, corn may not truly represent an environmentally sustainable biomass solution.

However, it is tough to beat the productivity of corn and its ability to be used for various biomass and atmospheric carbon capture applications. For example, corn stover, the byproduct stalks and leaves leftover from harvest, can be broken down into biochar for reuse in soil nutrient replenishment and is excellent for carbon sequestration from the atmosphere. Carbon sequestration is the “storage of carbon dioxide (CO2) after it is captured from industrial facilities and power plants or removed directly from the atmosphere”. One California-based company, Charm, is harvesting the leftover corn leaves, husks, and stalks and breaking them down into bio-oil which is stored deep underground in EPA-regulated wells. This bio-oil now contains sequestered carbon from corn crops and locks it away for thousands of years thus allowing a simple, and effective, way to use farm waste materials as carbon sequestration machines. This corn stover may otherwise have been burned or left to rot, releasing its carbon into the atmosphere.

As the DOE Bioenergy Technology Office puts it:

“Crops can serve as a carbon sink, capturing CO2 from the atmosphere. During CO2 fermentation, some of this recycled CO2 can be harnessed for various applications, such as carbon capture and storage, where it can be compressed or stored underground. The convergence of lower input costs, improvement of ethanol production, and CO2 management showcases a sector poised to contribute to a sustainable and prosperous future.”

Read more

While corn remains the leader of the biomass pack for usage in atmospheric carbon capture, it is necessary to begin broadening the biomass portfolio into other crops, both conventional and not, that can offer similar carbon capture and biomass benefits for industrial energy and feedstock use. The introduction of more sustainable biomass inputs, like waste hulls from almond crops, winter oilseed crops, or macro/microalgae, might be the key to introducing options for industries to use for their biomanufacturing processes. To make the U.S. bioeconomy more environmentally sustainable, it will be necessary to prioritize the use of biomass that is sustainable for the creation of bio-based products. To achieve this, policymakers and industry leaders can come together to understand the physical infrastructure needed to support the processing and utilization of sustainable biomass.

Biomass in Carbon Accounting

A contentious issue in biomass utilization revolves around carbon accounting, particularly concerning the differentiation between biogenic and fossil fuel carbon. Biogenic carbon originates from recently living organisms and is part of the natural carbon cycle, while fossil fuel carbon is derived from the remains of extinct carbon-rich plants and animals that decomposed as they were compressed and heated in the ground. When burned, this fossil fuel carbon is released into the atmosphere, contributing to greenhouse gas emissions. The current carbon accounting frameworks often conflate these distinctions, leading to misconceptions and controversies surrounding biomass utilization’s carbon neutrality claims. Addressing this ambiguity is crucial for aligning policy frameworks with scientific realities and ensuring informed decision-making in biomass utilization. As microbioeconomies grow, any confusion about biogenic versus fossil fuel carbon could become another barrier to entry for burgeoning bioeconomy opportunities.

Environmental and Economic Impacts

All across rural America, local economic developers are seeing more biomass conversion projects come to their communities, which offers the chance to boost economic revenues from turning biomass into energy, fuel, or feedstock and creates a broad spectrum of jobs for the area. To capitalize on this, increased bioliteracy on how growing biomass could offer additional financial support for farmers, provide energy to heat communities, and become feedstock for the biotechnology and biomanufacturing industry is critical. The more we activate and connect parts of America that are not located in existing high-density technology hubs, the better prepared these communities will be when biomass projects look to settle in those places. For example, woody biomass was emphasized throughout the DOE 2023 Billion Ton report as an important biomass source for fuel and energy production, yet the process of getting the timber and woody biomass out of the forest and into processing facilities is slow to launch due to concerns over environmental impacts.

While environmental impacts are valid and of great concern in some ecosystems around the U.S., harvesting wood waste and timber in areas that are primed for increased forest fire risk might be a sustainable option for protecting forest ecosystems while also benefiting the community for energy and heat concerns. The USDA Wildland Fire Mitigation and Management Commission discussed the need for further research into forest biomass to understand how it can generate profit for communities with otherwise waste materials while also mitigating fire risk. One recommendation stated the need for “Increase[d] resources for programs to help private landowners dispose of woody biomass”. Although several programs assist landowners in this effort, there are still significant expenses involved. These costs may discourage landowners from conducting fuel reduction activities, leading them to either burn the material, which can harm air quality, or leave it on the land, potentially worsening wildfire severity in case of an outbreak. There’s a necessity for initiatives supporting the disposal of biomass, including wood chipping, hauling, and its utilization. These initiatives could receive support from USDA Rural Development and should explore ways to encourage landowners to sustainably harvest their woody biomass for both financial incentives and for reducing wildfire risk.

Billion Ton Report Recommendations

According to the 2023 DOE Billion-Ton Report, the U.S. used 342 million tons of biomass for energy and bio-based chemicals in 2022. The top biomass source for biofuels is corn, with the U.S. producing nearly 150 tons per year of corn that is converted to ethanol. Whereas ~140 million tons of forestry/wood and wood waste (woody biomass) are used for heat and power purposes. However, many other types of biomass exist and are used for various purposes including transportation or industrial and electrical power. Below is an abbreviated list, based on the Billion-Ton Report, of common biomass examples and some of their uses.

The recent Billion Ton report makes it clear that the U.S. has plenty of available biomass for use in the production of biofuel, heat/energy, and bio-based products, and that further utilization of biomass in these applications and in biotechnology and biomanufacturing industries could be a way forward to mitigate climate change and improve sustainability of the U.S. bioeconomy. To change the mindset of biomass as more than corn grown for biofuel, it will take a concerted effort by the federal agencies involved in funding biomass use projects, like the DOE, USDA, National Science Foundation, and the Department of Defense, to communicate to farmers that growing biomass can be profitable. It will also take a joint effort from the federal government and local governments to build pilot and commercial scale facilities to begin processing diverse biomass.

Overall, there is immense promise in connecting biomass growers, processors, and bio-powered industries. It allows the players in the U.S. bioeconomy to think critically about their waste outputs and how to harness biomass as the key to unlocking a future where all communities, be they rural or urban, benefit from our national bioeconomy. You can learn more about biomass use in biotechnology and biomanufacturing at our upcoming webinar May 1st at 10 AM ET.

Working with academics: A primer for U.S. government agencies

Collaboration between federal agencies and academic researchers is an important tool for public policy. By facilitating the exchange of knowledge, ideas, and talent, these partnerships can help address pressing societal challenges. But because it is rarely in either party’s job description to conduct outreach and build relationships with the other, many important dynamics are often hidden from view. This primer provides an initial set of questions and topics for agencies to consider when exploring academic partnership.

Why should agencies consider working with academics?

What considerations may arise when working with academics?

Table (Of Contents)
Characteristics of discussed collaborative structures
StructurePrimary needPotential mechanismsStructural complexityLevel of effort
Informal advisingKnowledge >> CapacityAd-hoc engagement; formal consulting agreementLowOccasional work, over the short- to long-term
Study groupsKnowledge > CapacityInformal working group; formal extramural awardModerateOccasional to part-time work, over the short- to medium-term
Collaborative researchCapacity ~= KnowledgeInformal research partnership, formal grant, or cooperative agreement / contractVariablePart-time work, over the medium- to long-term
Short-term placementsCapacity > KnowledgeIPA, OPM Schedule A(r), or expert contract; either ad-hoc or through a formal programModeratePart- to full-time work, over a short- to medium-term
Long-term rotationsCapacity >> KnowledgeIPA, OPM Schedule A(r), or SGE designation; typically through a formal programHighFull-time work, over a medium- to long-term
BOX 1. Key academic considerations
Academic career stages.

Academic faculty progress through different stages of professorship — typically assistant, associate, and full — that affect their research and teaching expectations and opportunities. Assistant professors are tenure-track faculty who need to secure funding, publish papers, and meet the standards for tenure. Associate professors have job security and academic freedom, but also more mentoring and leadership responsibilities; associate professors are typically tenured, though this is not always the case. Full professors are senior faculty who have a high reputation and recognition in their field, but also more demands for service and supervision. The nature of agency-academic collaboration may depend on the seniority of the academic. For example, junior faculty may be more available to work with agencies, but primarily in contexts that will lead to traditional academic outputs; while senior faculty may be more selective, but their academic freedom will allow for less formal and more impact-oriented work.

Soft vs. hard money positions.

Soft money positions are those that depend largely or entirely on external funding sources, typically research grants, to support the salary and expenses of the faculty. Hard money positions are those that are supported by the academic institution’s central funds, typically tied to more explicit (and more expansive) expectations for teaching and service than soft-money positions. Faculty in soft money positions may face more pressure to secure funding for research, while faculty in hard money positions may have more autonomy in their research agenda but more competing academic activities. Federal agencies should be aware of the funding situation of the academic faculty they collaborate with, as it may affect their incentives and expectations for agency engagement.

Sabbatical credits.

A sabbatical is a period of leave from regular academic duties, usually for one or two semesters, that allows faculty to pursue an intensive and unstructured scope of work — this can include research in their own field or others, as well as external engagements or tours of service with non-academic institutions . Faculty accrue sabbatical credits based on their length and type of service at the university, and may apply for a sabbatical once they have enough credits. The amount of salary received during a sabbatical depends on the number of credits and the duration of the leave. Federal agencies may benefit from collaborating with academic faculty who are on sabbatical, as they may have more time and interest to devote to impact-focused work.

Consulting/outside activity limits.

Consulting limits & outside activity limits are policies that regulate the amount of time that academic faculty can spend on professional activities outside their university employment. These policies are intended to prevent conflicts of commitment or interest that may interfere with the faculty’s primary obligations to the university, such as teaching, research, and service, and the specific limits vary by university. Federal agencies may need to consider these limits when engaging academic faculty in ongoing or high-commitment collaborations.

9 vs. 12 month salaries.

Some academic faculty are paid on a 9-month basis, meaning that they receive their annual salary over nine months and have the option to supplement their income with external funding or other activities during the summer months. Other faculty are paid on a 12-month basis, meaning that they receive their annual salary over twelve months and have less flexibility to pursue outside opportunities. Federal agencies may need to consider the salary structure of the academic faculty they work with, as it may affect their availability to engage on projects and the optimal timing with which they can do so.

Advisory relationships consist of an academic providing occasional or periodic guidance to a federal agency on a specific topic or issue, without being formally contracted or compensated. This type of collaboration can be useful for agencies that need access to cutting-edge expertise or perspectives, but do not have a formal deliverable in mind.

Academic considerations

Regulatory & structural considerations

Box 2. Key structural considerations
Regulatory guidance.

Federal agencies and academic institutions are subject to various laws and regulations that affect their research collaboration, and the ownership and use of the research outputs. Key legislation includes the Federal Advisory Committee Act (FACA), which governs advisory committees and ensures transparency and accountability; the Federal Acquisition Regulation (FAR), which controls the acquisition of supplies and services with appropriated funds; and the Federal Grant and Cooperative Agreement Act (FGCAA), which provides criteria for distinguishing between grants, cooperative agreements, and contracts. Agencies should ensure that collaborations are structured in accordance with these and other laws.

Contracting mechanisms.

Federal agencies may use various contracting mechanisms to engage researchers from non-federal entities in collaborative roles. These mechanisms include the IPA Mobility Program, which allows the temporary assignment of personnel between federal and non-federal organizations; the Experts & Consultants authority, which allows the appointment of qualified experts and consultants to positions that require only intermittent and/or temporary employment; and Cooperative Research and Development Agreements (CRADAs), which allow agencies to enter into collaborative agreements with non-federal partners to conduct research and development projects of mutual interest.

University Office of Sponsored Programs.

Offices of Sponsored Programs are units within universities that provide administrative support and oversight for externally funded research projects. OSPs are responsible for reviewing and approving proposals, negotiating and accepting awards, ensuring compliance with sponsor and university policies and regulations, and managing post-award activities such as reporting, invoicing, and auditing. Federal agencies typically interact with OSPs as the authorized representative of the university in matters related to sponsored research.

Non-disclosure agreements.

When engaging with academics, federal agencies may use NDAs to safeguard sensitive information. Agencies each have their own rules and procedures for using and enforcing NDAs involving their grantees and contractors. These rules and procedures vary, but generally require researchers to sign an NDA outlining rights and obligations relating to classified information, data, and research findings shared during collaborations.

A study group is a type of collaboration where an academic participates in a group of experts convened by a federal agency to conduct analysis or education on a specific topic or issue. The study group may produce a report or hold meetings to present their findings to the agency or other stakeholders. This type of collaboration can be useful for agencies that need to gather evidence or insights from multiple sources and disciplines with expertise relevant to their work.

Academic considerations

Regulatory & structural considerations

Case study

In 2022, the National Science Foundation (NSF) awarded the National Bureau of Economic Research (NBER) a grant to create the EAGER: Place-Based Innovation Policy Study Group. This group, led by two economists with expertise in entrepreneurship, innovation, and regional development — Jorge Guzman from Columbia University and Scott Stern from MIT — aimed to provide “timely insight for the NSF Regional Innovation Engines program.” During Fall 2022, the group met regularly with NSF staff to i) provide an assessment of the “state of knowledge” of place-based innovation ecosystems, ii) identify the insights of this research to inform NSF staff on design of their policies, and iii) surface potential means by which to measure and evaluate place-based innovation ecosystems on a rigorous and ongoing basis. Several of the academic leads then completed a paper synthesizing the opportunities and design considerations of the regional innovation engine model, based on the collaborative exploration and insights developed throughout the year. In this case, the study group was structured as a grant, with funding provided to the organizing institution (NBER) for personnel and convening costs. Yet other approaches are possible; for example, NSF recently launched a broader study group with the Institute for Progress, which is structured as a no-cost Other Transaction Authority contract.

Active collaboration covers scenarios in which an academic engages in joint research with a federal agency, either as a co-investigator, a subrecipient, a contractor, or a consultant. This type of collaboration can be useful for agencies that need to leverage the expertise, facilities, data, or networks of academics to conduct research that advances their mission, goals, or priorities.

Academic considerations

Regulatory & structural considerations

Case studies

External collaboration between academic researchers and government agencies has repeatedly proven fruitful for both parties. For example, in May 2020, the Rhode Island Department of Health partnered with researchers at Brown University’s Policy Lab to conduct a randomized controlled trial evaluating the effectiveness of different letter designs in encouraging COVID-19 testing. This study identified design principles that improved uptake of testing by 25–60% without increasing cost, and led to follow-on collaborations between the institutions. The North Carolina Office of Strategic Partnerships provides a prime example of how government agencies can take steps to facilitate these collaborations. The office recently launched the North Carolina Project Portal, which serves as a platform for the agency to share their research needs, and for external partners — including academics — to express interest in collaborating. Researchers are encouraged to contact the relevant project leads, who then assess interested parties on their expertise and capacity, extend an offer for a formal research partnership, and initiate the project.

Short-term placements allow for an academic researcher to work at a federal agency for a limited period of time (typically one year or less), either as a fellow, a scholar, a detailee, or a special government employee. This type of collaboration can be useful for agencies that need to fill temporary gaps in expertise, capacity, or leadership, or to foster cross-sector exchange and learning.

Academic considerations

Regulatory & structural considerations

Case studies

Various programs exist throughout government to facilitate short-term rotations of outside experts into federal agencies and offices. One of the most well-known examples is the American Association for the Advancement of Science (AAAS) Science & Technology Policy Fellowship (STPF) program, which places scientists and engineers from various disciplines and career stages in federal agencies for one year to apply their scientific knowledge and skills to inform policy making and implementation. The Schedule A(r) hiring authority tends to be well-suited for these kinds of fellowships; it is used, for example, by the Bureau of Economic Analysis to bring on early career fellows through the American Economic Association’s Summer Economics Fellows Program. In some circumstances, outside experts are brought into government “on loan” from their home institution to do a tour of service in a federal office or agency; in these cases, the IPA program can be a useful mechanism. IPAs are used by the National Science Foundation (NSF) in its Rotator Program, which brings outside scientists into the agency to serve as temporary Program Directors and bring cutting-edge knowledge to the agency’s grantmaking and priority-setting. IPA is also used for more ad-hoc talent needs; for example, the Office of Evaluation Sciences (OES) at GSA often uses it to bring in fellows and academic affiliates.

Long-term rotations allow an academic to work at a federal agency for an extended period of time (more than one year), either as a fellow, a scholar, a detailee, or a special government employee. This type of collaboration can be useful for agencies that need to recruit and retain expertise, capacity, or leadership in areas that are critical to their mission, goals, or priorities.

Academic considerations

Regulatory & structural considerations

Case study

One example of a long-term rotation that draws experts from academia into federal agency work is the Advanced Research Projects Agency (ARPA) Program Manager (PM) role. ARPA PMs — across DARPA, IARPA, ARPA-E, and now ARPA-H — are responsible for leading high-risk, high-reward research programs, and have considerable autonomy and authority in defining their research vision, selecting research performers, managing their research budget, and overseeing their research outcomes. PMs are typically recruited from academia, industry, or government for a term of three to five years, and are expected to return to their academic institutions or pursue other career opportunities after their term at the agency. PMs coming from academia or nonprofit organizations are often brought on through the IPA mobility program, and some entities also have unique term-limited, hiring authorities for this purpose. PMs can also be hired as full government employees; this mechanism is primarily used for candidates coming from the private sector.

Unlocking American Competitiveness: Understanding the Reshaped Visa Policies under the AI Executive Order

The looming competition for global talent has brought forth a necessity to evaluate and update the policies concerning international visa holders in the United States. Recognizing this, President Biden has directed various agencies to consider policy changes aimed at improving processes and conditions for legal foreign workers, students, researchers, and scholars through the upcoming AI Executive Order (EO). The EO recognizes that attracting global talent is vital for continued U.S. economic growth and enhancing competitiveness. 

Here we offer a comprehensive analysis of potential impacts and beneficiaries under several key provisions brought to attention by this EO. The provisions considered herein are categorized under six paramount categories: domestic revalidation for J-1 and F-1 Visas; modernization of H-1B Visa Rules; updates to J-1 Exchange Visitor Skills List; the introduction of Global AI Talent Attraction Program; issuing an RFI to seek updates to DOL’s Schedule A; and policy manual updates for O-1A, EB-1, EB-2 and International Entrepreneur Rule. Each policy change carries the potential to advance America’s ability to draw in international experts that hugely contribute to our innovation-driven economy.

Domestic Revalidation for J-1 and F-1 Visas

The EO directive on expanding domestic revalidation for J-1 research scholars and F-1 STEM visa students simplifies and streamlines the renewal process for a large number of visa holders. 

There are currently approximately 900,000 international students in the US, nearly half of whom are enrolled in STEM fields. This policy change has the potential to impact almost 450,000 international students, including those who partake in optional practical training (OPT). The group of affected individuals consists greatly of scholars with advanced degrees as nearly half of all STEM PhDs are awarded to international students.

One of the significant benefits offered by this EO directive is the reduction in processing times and associated costs. In addition, it improves convenience for these students and scholars. For example, many among the several hundreds of thousands of STEM students will no longer be obligated to spend excessive amounts on travel to their home country for a 10-minute interview at an Embassy.

Aside from saving costs, this directive also allows students to attend international conferences more easily and enjoy hassle-free travel without being worried about having to spend a month away from their vital research waiting for visa renewal back home.

Expanding domestic revalidation to F and J visa holders was initially suggested by the Secure Borders and Open Doors Advisory Committee in January 2008, indicating its long-standing relevance and importance. By implementing it, we not only enhance efficiency but also foster a more supportive environment for international students contributing significantly to our scientific research community.

Modernization of H-1B Visa Rules

The EO directive to update the rules surrounding H-1B visas would positively impact the over 500k H-1B visa holders. The Department of Homeland Security recently released a Notice of Proposed Rulemaking to reform the H-1B visa rules. It would allow these visa holders to easily transition into new jobs, have more predictability and certainty in the renewal process and more flexibility or better opportunities to apply their skills, and allow entrepreneurs to more effectively access the H-1B visa. Last year, 206,002 initial and continuing H-1Bs were issued. The new rules would apply to similar numbers in FY2025. But what amplifies this modification’s impact is its potential crossover with EB-1 and EB-2 petitioners waiting on green cards—currently at over 400k petitions. 

Additionally, the modernization would address the issue of multiple applications per applicant. This has been a controversial issue in the H-1B visa program as companies would often file multiple registrations for the same employee, thus increasing the exhaustion rate of yearly quotas, thereby reducing chances for others. This modernization could potentially address this problem by introducing clear rules or restrictions on the number of applications per applicant. USCIS recently launched fraud investigations into several companies engaging in this practice.

Updates to J-1 Exchange Visitor Skills List

The EO directive to revamp the skills list will synchronize with evolving global labor market needs. Nearly 37k of the J-1s issued in 2022 went to professors, research scholars and short term scholars, hailing from mainly China and India (nearly 40% of all). Therefore, this update not only expands opportunities available to these participants but also tackles critical skill gaps within fields like AI in the U.S. Once the J-1 skills list is updated to meet the realities of the global labor market today, it will allow thousands of additional high skilled J-1 visa holders to apply for other visa categories immediately, without spending 2-years in their countries of origin, as laid out in this recent brief by the Federation of American Scientists.

Global AI Talent Attraction Program

Recognizing AI talent is global, the EO directive on using the State Department’s public diplomacy function becomes strategically important. By hosting overseas events to appeal to such crucial talent bases abroad, we can effectively fuel the U.S. tech industry’s unmet demand that has seen a steep incline over recent years. While 59% of the top-tier AI researchers work in the U.S., only 20% of them received their undergraduate degree in the U.S. Only 35% of the most elite (top 0.5%) of AI researchers received their undergraduate degree in the U.S., but 65% of them work in the U.S. The establishment of a Global AI Talent Attraction program by the State Department will double down on this uniquely American advantage.

Schedule A Update & DOL’s RFI

Schedule A is a list of occupations for which the U.S. Department of Labor (DOL) has determined there are not sufficient U.S. workers who are able, willing, qualified and available. Foreign workers in these occupations can therefore have a faster process to receive a Green Card because the employer does not need to go through the Labor Certification process. Schedule A Group I was created in 1965 and has remained unchanged since 1991. If the DOL were to update Schedule A, it would impact foreign workers and employers in several ways depending on how the list changes:

Foreign workers with occupations that are on Schedule A do not have to go through the PERM (Program Electronic Review Management) labor certification process, a process that otherwise takes on average 300 days to complete. This is because Schedule A lists occupations for which the Department of Labor has already determined there are not sufficient U.S. workers who are able, willing, qualified and available. An updated Schedule A could cut PERM applications filed significantly down from current high volumes (over 86,000 already filed by the end of FY23 Q3). While the EO only calls for an RFI seeking information on the Schedule A List, this is a critical first step to an eventual update that is badly needed.

Policy Manual Updates for O-1A, EB-1, EB-2 and International Entrepreneur Rule

The EO’s directive to DHS to modernize pathways for experts in AI and other emerging technologies will have profound effects on the U.S. tech industry. Fields such as Artificial Intelligence (AI), Quantum computing, Biotechnology, etc., are increasingly crucial in defining global technology leadership and national security. As per the NSCAI report, the U.S. significantly lags behind in terms of AI expertise due to severe immigration challenges.

The modernization would likely include clarification and updates to the criteria of defining ‘extraordinary ability’ and ‘exceptional ability’ under O-1A, EB-1 and EB-2 visas, becoming more inclusive towards talents in emerging tech fields. For instance, the current ‘extraordinary ability’ category is restrictive towards researchers as it preferentially favors those who have received significant international awards or recognitions—a rarity in most early-stage research careers. Similarly, despite O-1A and EB-1 both designed for aliens with extraordinary ability, the criteria for EB-1 is more restrictive than O-1A and bringing both in line would allow a more predictable path for an O-1A holder to transition to an EB-1. Such updates also extend to the International Entrepreneur Rule, facilitating startup founders from critical technology backgrounds more straightforward access into the U.S. landscape.

Altogether, these updates could lead to a surge in visa applications under O-1A, EB-1, EB-2 categories and increase entrepreneurship within emerging tech sectors. In turn, this provision would bolster the U.S.’ competitive advantage globally by attracting top-performing individuals working on critical technologies worldwide.

Enhanced Informational Resources and Transparency

The directives in Section 4 instruct an array of senior officials to create informational resources that demystify options for experts in critical technologies intending to work in the U.S. The provision’s ramifications include:

Streamlining Visa Services 

This area of the order directly addresses immigration policy with a view to accelerating access for talented individuals in emerging tech fields. 

Using Discretionary Authorities to Support and Attract AI Talent

The EO’s directive to the Secretary of State and Secretary of Homeland Security to use discretionary authorities—consistent with applicable law and implementing regulations—to support and attract foreign nationals with special skills in AI seeking to work, study, or conduct research in the U.S. could have enormous implications. 

One way this provision could be implemented is through the use of public benefit parole. Offering parole to elite AI researchers who may otherwise be stuck in decades long backlogs (or are trying to evade authoritarian regimes) could see a significant increase in the inflow of intellectual prowess into the U.S. Public benefit parole is also the basis for the International Entrepreneur Rule. Given how other countries are actively poaching talent from the U.S. because of our decades long visa backlogs, creating a public benefit parole program for researchers in AI and other emerging technology areas could prove extremely valuable. These researchers could then be allowed to stay and work in the U.S. provided they are able to demonstrate (on an individual basis) that their stay in the U.S. would provide a significant public benefit through their AI research and development efforts.

Another potential utilization of this discretionary authority could be in the way of the Department of State issuing a memo announcing a one‐​time recapture of certain immigrant visa cap numbers to redress prior agency failures to issue visas. There is precedence for this as when the government openly acknowledged its errors that made immigrants from Western Hemisphere countries face longer wait times between 1968 and 1976 as it incorrectly charged Cuban refugees to the Western Hemisphere limitation. To remedy the situation, the government recaptured over 140,000 visas from prior fiscal years on its own authority, and issued them to other immigrants who were caught in the Western Hemisphere backlog. 

In the past, considerable quantities of green cards have gone unused due to administrative factors. Recapturing these missed opportunities could immediately benefit a sizable volume of immigrants, including those possessing AI skills and waiting for green card availability. For instance, if a hypothetical 300,000 green cards that were not allocated due to administrative failures are recaptured, it could potentially expedite the immigration process for a similar number of individuals. 

Finally, as a brief from the Federation of American Scientists stated earlier, it is essential that the Secretary of State and the Secretary of Homeland Security extend the visa interview waivers indefinitely, considering the significant backlogs faced by the State Department at several consular posts that are preventing researchers from traveling to the U.S. 

In August 2020, Secretary Pompeo announced that applicants seeking a visa in the same category they previously held would be allowed to get an interview waiver if their visa expired in the last 24 months. Before this, the expiration period for an interview waiver was only 12 months. In December 2020, just two days before this policy was set to expire, DOS extended it through the end of March 2021. In March, the expiration period was doubled again, from 24 months to 48 months and the policy extended through December 31, 2021. In September of 2021, DOS also approved waivers through the remainder of 2021 for applicants of F, M, and academic J visas from Visa Waiver Program countries who were previously issued a visa.

In December 2021, DOS extended its then-existing policies (with some minor modifications) through December 2022. Moreover, the interview waiver policy that individuals renewing a visa in the same category as a visa that expired in the preceding 48 months may be eligible for issuance without an interview was announced as a standing policy of the State Department, and added to the department’s Foreign Affairs Manual for consular officers.  In December 2022, DOS announced another extension of these policies, which are set to expire at the end of 2023. 

As the State Department recently noted: “These interview waiver authorities have reduced visa appointment wait times at many embassies and consulates by freeing up in-person interview appointments for other applicants who require an interview. Nearly half of the almost seven million nonimmigrant visas the Department issued in Fiscal Year 2022 were adjudicated without an in-person interview. We are successfully lowering visa wait times worldwide, following closures during the pandemic, and making every effort to further reduce those wait times as quickly as possible, including for first-time tourist visa applicants. Embassies and consulates may still require an in-person interview on a case-by-case basis and dependent upon local conditions.”

These changes would also benefit U.S. companies and research institutions, who often struggle to retain and attract international AI talent due to the lengthy immigration process and uncertain outcomes. In addition, exercising parole authority can open a new gateway for attracting highly skilled AI talent that might have otherwise chosen other countries due to the rigid U.S. immigration system. 

The use of such authorities can result in a transformational change for AI research and development in the U.S. However, all these outcomes entirely depend upon the actual changes made to existing policies—a task that many acknowledge will require serious thoughtfulness for walking a balance between remaining advantageously selective yet inclusive enough.

In summary, these provisions would carry massive impacts—enabling us to retain foreign talent vital across sectors including but not limited to education, technology and healthcare; all fuelling our national economic growth in turn.

Increasing Students Opportunity-to-Learn Through Better Data Systems

Research shows that giving students equitable opportunities to learn requires access to key inputs. These include, at a minimum: access to qualified, experienced, in-field, and effective teachers; a rich curriculum; adequate funding; support staff; up-to-date facilities; standards-based materials; and technology. Since the 1960s education scholars have argued that federal, state, and local policymakers should use evidence-based opportunity-to-learn (OTL) indicators to inform education improvement processes and decisions about educator recruitment and retention, targeted student-centered programming, and equitable resource allocation. The current availability of district-level relief funds, the restarting of state accountability systems, and a possible reauthorization of the federal Education Sciences Reform Act (ESRA), are unique policy openings for education leaders to innovate using OTL indicators, incorporate promising practices from existing reporting systems, and establish place-based measures that fit local needs.

Challenge and Opportunity

COVID-19 placed an enormous burden on our education system. Lost instruction, student absences, teacher shortages, school discipline, and the wavering mental health of our nation’s youth have all made headlines since the pandemic began. To address these challenges, policymakers, educators, parents, and community members need multiple data points—in addition to test scores—to both identify achievement and opportunity gaps and spotlight successful models. 

Luckily, a 2019 National Academies of Sciences study, in addition to several resources from the Department of Education and policy experts, demonstrate how OTL indicators can inform school, district, and systems-wide improvement. According to Stephen Elliot and Brendan Bartlett, OTL indicators “generally refer to inputs and processes within a school context necessary for producing student achievement of intended outcomes.” Such indicators can include those identified by the National Academies of Sciences in Table 1 and may also incorporate other indicators of school conditions and outcomes. When states, districts, and schools use various combinations of OTL indicators and disaggregate them by student subgroup, they can more accurately gauge and purposefully increase students’ opportunities to learn.

Table 1. OTL Indicators shared by the National Academies of Sciences
Academic readinessSelf-regulation skills
School engagementCourse performance
Test performanceOn-time graduation
Postsecondary readinessRacial, ethnic, and economic segregation
Access to high-quality pre-K programsEffective teaching
Rigorous courseworkCurricular breadth
Academic supportsSchool climate
Non-exlusionary discipline practicesIntegrated student support services
Source: National Academies of Sciences, Engineering, and Medicine. 2019. Monitoring Educational Equity. Washington, DC: The National Academies Press. https://doi.org/10.17226/25389.

OTL indicators can also provide information about the nature of the teaching and learning opportunities states, districts, and schools make available to students across the country. For example, if a state’s curriculum frameworks and assessments outline standards for science or career and technical education that requires laboratory work, computers, specialized courses, and teaching expertise—states and districts should know whether students have access to these resources.

Federal and Expert Support for OTL Indicators

Over the past two years the Department of Education (ED) released two key resources supporting OTL implementation:

Table 2. OTL Indicators shared by the Department of Education
Student chronic absenteeism ratesStudent discipline rates (e.g., in-and out-of-school suspensions, expulsions)
Data from student, staff and family surveysAccess to integrated support services (e.g., ratio of students to nurses, counselors, social workers)
Educator certification (e.g., National Board Certification) Educator experience
Educator effectiveness Educator chronic absenteeism and turnover rates
Educator supports (e.g., mentors, induction programs, professional development) Home and school Internet access and student device ratios (e.g., 1:1)
Quality of remote learning Educator access to PD for the effective use of technology
Advanced course participation and completion Culturally and linguistically responsive curriculum designs
Using diagnostic assessments Access to project-based, experiential learning opportunities
Source: U.S. Department of Education. (2021) ED COVID-19 Handbook Volume 2: Roadmap to Reopening Safely and Meeting All Students’ Needs.

In addition, several organizations released OTL-related resources describing different indicators and how they are being used to support student achievement. For example:

Ideas to Use Data to Increase Opportunities to Learn

Taken together, the resources above from ED and policy experts can facilitate the following local, state, and federal actions to increase the use of OTL indicators.

Supporting Student Opportunity to Learn through Local Data Systems

States and districts have broad flexibility to use American Rescue Plan Act funds to support student achievement—including “developing and implementing procedures and systems to improve the preparedness and response efforts of local educational agencies.” These systems could arguably include building data collection and reporting infrastructure to track OTL indicators, monitor student progress, and respond with evidence-based interventions. Instead of starting from scratch, states and districts can pull best practices from existing cradle-to-career models such as the Schott Foundation’s Loving Cities Index, or StriveTogether which track various forms of OTL data from a student’s early years (e.g., kindergarten readiness) through their entry into career paths (e.g., postsecondary enrollment).  School Systems can also adapt aspects of OTL indicators to show how they are meeting the needs of their students. For example, Houston Independent School District has an ESSER Spending Dashboard showing how much funding has been spent on educators, support staff, tutors, devices, programming, and physical health. 

Supporting Student Opportunity to Learn through State Accountability and Improvement and Reporting Systems  

At the state level, policymakers can help advance OTL indicators by using flexibility included in the Every Student Succeeds Act (ESSA) and further described by ED’s 2022 accountability guidance. For example, ESSA requires states to add at least one indicator of “school quality or student success” to their accountability systems. A number of states have responded by adding indicators of college and career readiness, extended-year graduation rates, suspension rates, school climate, and chronic absenteeism, which all provide information about the broader set of outcomes and opportunities that shape student achievement. For example, the District of Columbia amended its ESSA plan in 2022 to include academic growth, access to dual enrollment courses, and a five-year graduation rate. Many states also represent OTL data in accessible formats such as the school data dashboard in California, a parent dashboard in New York, School and District Profiles in Oregon, and school climate survey reports in Illinois. 

Supporting Student Opportunity to Learn through State and Federal Grant Programs

State and federal governments can also incorporate OTL indicators into reporting metrics for grantees. Specifically, state and federal government can solicit feedback on which indicators are most helpful to each program through public notices. By developing equity-centered measures with researchers, policymakers, and practitioners, federal agencies can help grantees build lasting data systems for reporting and continuous improvement. For example, the Full-Service Community School grant program went through negotiated rulemaking to reshape the program’s priorities and drew from suggestions submitted by policy experts to incorporate 13 reporting metrics for new grantees. To help make the collection less burdensome, agencies can also provide technical assistance and release guidance with existing data sources, best practices, and examples.

Supporting Student Opportunity to Learn through Education Sciences Reform Act (ESRA) Implementation and Reauthorization 

The federal government can help states and districts close opportunity gaps by assisting in the collection, reporting, validation, disaggregation, and analysis of OTL data through ESRA-funded programs. For example, states and districts can leverage technical assistance and research dissemination through the Regional Educational Laboratories (RELs), creating resources and providing further support through the Comprehensive Centers Program, and equipping the Statewide Longitudinal Data System (SLDS) program to aid in building state and local capacity in measuring students’ opportunity to learn. Officials at the Institute for Education Sciences (IES) can also point states and districts to existing models such as Kentucky’s Longitudinal Data System and Washington’s Indicators of Education System Health, which incorporate data across a student’s academic continuum to inform policy and practice. 

Conclusion

If state and local leaders are committed to supporting the “whole child,” then they need more than just outcome-based measures such as test scores or graduation rates (i.e., outputs). So much happens before students take a test or graduate. To improve outcomes, students, parents, teachers, and education stakeholders need better information about factors that contribute to student learning (i.e., inputs). For years federal, state, and local leaders have been assessing our students mainly to find the same persistent achievement gaps, which correlate heavily with race, ethnicity, and socioeconomic status. Expanding the use of OTL indicators also assess our federal, state, and local systems so they can find new opportunities for students to learn.