DOE’s mission and operations have undergone at least three iterations: starting as the Atomic Energy Commission after World War II (1.0), evolving into the Department of Energy during the 1970s Energy Crisis to focus on a wider range of energy research & development (2.0), and then expanding into demonstration and deployment over the last 20 years (3.0). The evolution into DOE 3.0 began with the Energy Policy Act of 2005, which authorized the Loan Programs Office (LPO), and accelerated with the infusion of funding from the American Recovery and Reinvestment Act of 2009. Finally, the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA) crystallized DOE 3.0’s dual mandate to not only drive U.S. leadership in science and technology innovation (as under DOE 1.0 and 2.0), but also directly advance U.S. industrial development and decarbonization through project financing and other support for infrastructure deployment.

While DOE continues to support the full spectrum of research, development, demonstration, and deployment (RDD&D) activities under this dual mandate, the agency is now undergoing another transformation under the Trump administration, as a large number of career staff leave the agency and programs and budgets are overhauled. The Federation of American Scientists (FAS) is launching a new initiative to envision the DOE 4.0 that emerges after these upheavals, with the goals of identifying where DOE 3.0 missed opportunities and how DOE 4.0 can achieve the real-world change needed to address the interlocking crises of energy affordability, U.S. competitiveness, and climate change. 

Crucial to these goals is rethinking program design and implementation to ensure that DOE’s tools are fit for purpose. BIL and IRA introduced new types of programs and assistance mechanisms, such as Regional Hubs and “anchor customer” capacity contracts, to try to meet the differing needs of demonstration and deployment activities compared to R&D. Some were a clear success, while others faced implementation challenges. At the same time, the majority of funding from these two bills was still implemented using traditional grants and cooperative agreements, which did not always align with the needs of the commercial-scale projects they sought to support. Based on lessons learned from the Biden administration, this report provides recommendations to DOE to improve the implementation of different types of assistance and identifies opportunities to expand the use of flexible and novel approaches. To that end, this report also advises Congress on how to improve the design of legislation for more effective implementation.

The ideas and insights in this report were informed by conversations with former DOE staff who played a role in implementing many of these programs and experts from the broader clean energy policy community.

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Distribution of BIL and IRA Funding

Before diving into program design, it’s helpful to first understand the range of technologies and activities that BIL and IRA programs were meant to address, especially where that funding was concentrated and where there may have been gaps, since programs should be tailored to the purpose.

Authorizations and Appropriations

Congress intentionally provided the lion’s share of BIL and IRA funding to demonstration and deployment activities. The table above shows the distribution of BIL and IRA authorizations and appropriations for DOE. The table excludes DOE’s revolving loan programs – the Tribal Energy Financing Program (TEFP), the Advanced Technology Vehicles Manufacturing Loan Program (ATVM), the Title XVII Innovative Energy Loan Guarantee Program (Title 1703), the Title XVII Energy Infrastructure Reinvestment Financing Program (Title 1706) – which are discussed in the following section.¹ The Carbon Dioxide Transportation infrastructure Finance and Innovation program (CIFIA) was included in the table above because that program’s appropriations could be used for both grants and loan credit subsidies. 

The technology areas that received the most DOE funding from BIL and IRA (excluding loans) were building decarbonization, grid infrastructure, clean power – combining solar, wind, water, geothermal, and nuclear power, energy storage systems, and technology neutral programs – carbon management, and manufacturing and supply chains, which each received over $10 billion in funding. 

Below is a breakdown of the funding distribution for each sector/technology. 

Grid Infrastructure received a total of $14.9 billion, second only to building decarbonization. All of the funding went towards demonstration and deployment programs, the majority ($10.5 billion) of which went towards the Grid Resilience and Innovation Partnerships (GRIP) program. The remainder of the funding went towards Grid Resilience State and Tribal formula grants, the Energy Improvement in Rural and Remote Areas, Transmission Facilitation Program, and transmission siting and planning programs. No funding went to R&D or workforce programs. Grid infrastructure was also eligible for the Title 17 and Tribal loans programs.

Power Generation received a total of $13.2 billion, with funding unevenly distributed across technologies and stages of innovation. Nuclear power received the largest share, with over $9.2 billion allocated to the Advanced Reactor Demonstration Program and the Civil Nuclear Credit Program, supporting demonstration of advanced reactors and production incentives to maintain existing nuclear plants, respectively. Geothermal energy received the least funding among power generation technologies, with only $84 million allocated to the Enhanced Geothermal Systems (EGS) Demonstration Program and no other support for R&D or deployment. 

Modest amounts were provided for RD&D in solar ($80 million), wind ($100 million), and water power technologies ($146 million). For deployment, hydropower also received production and efficiency incentives to support existing facilities ($754 million); wind energy received funding for Interregional and Offshore Wind Electricity Transmission Planning and Development ($100 million); and solar qualified for the Renew America’s Schools program ($500 million). To complement these technologies, $505 was provided for energy storage demonstration programs to enable reliable deployment of variable renewables. 

Power generation was also eligible for the Title 17 and Tribal loan programs.

Manufacturing and Supply Chains received $10.8 billion in funding from BIL and IRA. The majority of that funding, $6.3 billion, went towards battery supply chains, primarily for the Battery Materials Processing Program ($3 billion) and the Battery Manufacturing and Recycling Program ($3 billion). Additional focus areas for funding included EV manufacturing ($2 billion), advanced energy manufacturing and recycling ($750 million), high-assay low-enriched uranium (HALEU) supply chains for nuclear power plants ($700 million), and heat pump manufacturing ($250 million). Energy manufacturing and supply chains are eligible for Title 1703 loans, while EV and battery manufacturing and supply chains are eligible for ATVM loans. 

Critical Minerals received a total of $6.9 billion, of which $6 billion was allocated for the Battery Materials Processing Program and the Battery Manufacturing and Recycling Program, which funded demonstration and commercial-scale critical minerals processing and recycling projects. The remainder of the funding went to R&D programs on mining, processing, and recycling technologies; technologies to recover critical minerals from coal-based industry, mining and mine waste, and other industries; and technologies that use less critical minerals or replace them with alternatives. Critical minerals were also eligible for all of DOE’s revolving loan programs, except for CIFIA.

Industrial Decarbonization and Efficiency received a total of $7.5 billion. Six ($6.0) billion of this funding went towards the Industrial Demonstrations Program (IDP), which was sector and solution agnostic and accepted projects for both new facilities and retrofits, making the money extremely flexible. Much smaller funding amounts were allocated to deployment and workforce programs like rebates for energy efficient technologies and systems, decarbonizing energy manufacturing and recycling facilities, and Industrial Training and Assessment Centers. No funding was allocated to R&D programs. 

Hydrogen and Clean Fuels received $8 billion for the Regional Clean Hydrogen Hubs program to support near-term demonstration and commercialization of hydrogen production, transportation, and usage. Hydrogen and clean fuels were also eligible for all of the loan programs, except for CIFIA. Investment across the full research-to-deployment (RDD&D) continuum was lacking. Dedicated funding for clean fuels besides hydrogen was also missing. 

EVs and Transportation funding from BIL and IRA was largely focused on light-duty personal EVs. By contrast, investments in medium- and heavy-duty vehicles and urban transportation were limited. 

EV manufacturing and supply chains received $8.3 billion in funding. The largest single allocations went to the Battery Materials Processing and Battery Manufacturing & Recycling Programs ($6 billion), strengthening domestic battery supply chains for EVs. Domestic Manufacturing Conversion grants ($5 billion), further supported downstream manufacturing of advanced EV technologies. Additional funding supported R&D for battery recycling and second-life applications. EV and battery manufacturing were also eligible for ATVM loans. 

A notable new focus for DOE under BIL was the deployment of EV charging infrastructure. Charging infrastructure was eligible for $1.05 billion in DOE funding through the Renew America’s Schools program and the Energy Efficiency and Conservation Block Grant Program. DOE played a key role in the Joint Office of Energy and Transportation’s implementation of the National Electric Vehicle Infrastructure (NEVI) Formula Program, funded by DOT ($5 billion), and other charging programs. This marks a shift from DOE’s previous focus on developing vehicle technologies and fuels to a broader focus on all of the technology and infrastructure needs for widespread EV adoption. 

Building Decarbonization and Efficiency received the most non-loan funding from BIL and IRA at $15.2 billion. The largest share of this funding, $12 billion, went towards deployment and affordability programs such as the Home Energy Efficiency Rebate Program, High-Efficiency Electric Home Rebate Program, and the Weatherization Assistance Program – all of which aim to reduce energy costs for low-income households by increasing the energy efficiency of their homes. Additional funding supported workforce training and the improvement of building codes. Little to no funding went to R&D and demonstration programs, signaling the relative maturity of building decarbonization and efficiency technologies compared to other sectors. District heating and cooling facilities are eligible for TEFP loans. 

Carbon Management received a total of $11.6 billion. The majority of the funding went towards demonstration and deployment activities, of which $2.1 billion went towards CIFIA to support the deployment of transportation infrastructure, $2.5 billion went towards carbon storage validation and testing, $3.0 billion went towards carbon capture pilots and demonstrations, and $3.5 billion went towards the development of Regional Direct Air Capture (DAC) Hubs. Carbon management was also eligible for loans from the Title 17 programs. 

Loans

DOE’s loan programs operate differently from the way authorizations and appropriations work for traditional assistance programs, which is why they are not included in the chart above. These programs receive both a certain amount of loan authority, which set limits on the size of their portfolios, and appropriations for program administration and credit subsidies, which allows the office to provide low-cost financing. The IRA appropriated $13.8 billion total for these four programs and provided an additional $310 billion in loan authority for Title 1703, Title 1706, and TFP. CIFIA was established in the IRA without a cap on its loan authority. The IRA also repealed the cap on ATVM’s loan authority, which remains uncapped.²

During the four years of the Biden administration, the Loan Programs Office (LPO), now renamed the Office of Energy Dominance Financing (EDF), issued a total of 24 loans and 28 conditional commitments, worth over $100 billion in total. Energy storage, battery manufacturing, clean power, and the grid received the greatest number of loans and conditional commitments, while nuclear energy, carbon management, and non-battery or EV manufacturing received the least. No loans were issued for CIFIA, which is why that program is not shown in the following figures.

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Program Design & Implementation

Flexible Contracting Mechanisms: Grants vs. Other Transactions

The majority of BIL and IRA funding (excluding loans) was implemented in the form of grants and cooperative agreements governed by 2CFR 200 and 2CFR 910. Even for programs for which the legislation did not specify the exact type of assistance mechanism that DOE should use (i.e., unspecified or “financial assistance”), the agency largely defaulted to those grants and cooperative agreements. One argument for this approach was that program officers and contracting officers are trained and experienced in using these mechanisms, which may have helped programs deploy faster. 

However, these grants were originally designed for R&D programs and faced some drawbacks when used for demonstration and deployment programs. 2CFR 200 and 2CFR 910 are almost 200 pages long, requiring extensive compliance that smaller organizations and organizations new to federal applications may not be equipped to navigate. Additionally, some terms and conditions required by those rules (e.g. for intellectual property, real property, and program income) were not compatible with private sector needs for demonstration and commercial-scale projects. Most consequentially, they require a termination for convenience clause, which allows the government to cancel an award without providing a reason. The Trump administration is now using that clause to terminate awards. 

Alternatively, DOE could have more frequently used its Other Transaction Authority (OTA) to enter into contracts without 2CFR regulations, allowing the agency to negotiate contracts more like the private sector would, developing terms and conditions as they make sense for the purpose of the specific purpose. This can enable DOE to design and implement more creative arrangements, such as for demand-pull or market-shaping mechanisms. DOE could have also leveraged OTs to make process improvements, rethink the traditional solicitation and evaluation process, and potentially accelerate implementation.³

DOE 3.0 missed a major opportunity to leverage these benefits of OTs. The few exceptions were the Hydrogen Demand Initiative (H₂DI), the Advanced Reactor Demonstration Program, and Partnership Intermediary Agreements. Towards the end of the Biden administration, DOE discussed transitioning some of OCED’s awards to OT agreements, but did not get a chance to follow through before the presidential transition.⁴

DOE 4.0 should pick up where DOE 3.0 and deploy OTs more broadly among demonstration and deployment programs to overcome the challenges of traditional financial assistance regulations and processes. Congress should ensure that future authorizing legislation is designed to enable this flexibility–for example, by not specifying the type of assistance that DOE should use to implement new programs. 

Flexible Funding

BIL and IRA authorized and appropriated funding for a wide range of programs, many with very specific goals and eligible uses. That approach allows Congress to provide detailed direction to DOE on legislators’ priorities. However, DOE should also be able to respond dynamically to industries and markets as they develop. For example, when BIL and IRA were being developed, next-generation geothermal technologies were still quite nascent and received very little funding from these bills. Within two years though, the technology rapidly advanced, thanks to the success of the first few demonstration projects, and now shows enormous potential for meeting clean, firm energy demand, but DOE has limited funding available to support the industry.

In future legislation, Congress should consider establishing a few flexible funding programs that would give DOE a greater range of options to support the development of energy technologies and infrastructure as the agency’s experts know best. This could look like a pooled pot of funding with broad authority for DOE to use across technologies and/or activities, such as a single fund for demonstration and deployment activities broadly, or a single fund for grid infrastructure needs. If Congress is wary about this, legislators could start with creating flexible funding programs designed to fit within the scope of a single DOE office, before testing programs that cross multiple offices, which may come with intra-agency coordination challenges.

Program Design: Regional Hubs

The Hydrogen Hubs and Regional Direct Air Capture (DAC) Hubs were a new type of program established by BIL, designed to fund clusters of projects located in different regions rather than individual, unrelated projects. BIL invested $7 billion and $3.5 billion in these programs, respectively, and they made some of the largest awards by dollar amount – on the order of $1 billion per award – out of all of the BIL and IRA programs. 

The hub approach aimed to foster an industrial ecosystem, including not only multiple projects aiming to deploy the technology, but also future suppliers, offtakers, labor organizations, academic partners, and state, local, and Tribal governments. Concentrated regional investment and greater coordination would not only accelerate commercialization of hydrogen and DAC technologies but also help distribute the benefits of new clean energy industries across the nation. 

Due to the ambitious size and complexity of their goals, the Hydrogen Hubs and DAC Hubs required, and still require, a long timeline to develop. The structure and oversight DOE applied to the hub development process also extended timelines further. When the Trump administration began re-evaluating Biden-era programs and Congress started looking for funds to rescind, these two programs became appealing targets because of the large amount of funding they held and the lack of on-the-ground deployment progress – even though that was to be expected based on the program timeline.⁵ 

Project cancellations and funding rescissions are a massive waste of both federal and private sector resources. In the future, before creating any other large-scale programs modeled on the Hydrogen Hubs and DAC Hubs, policymakers should first determine whether there is long-term bipartisan commitment to the program’s goals to avoid the possibility that a change of administration will jeopardize the program. If that commitment isn’t guaranteed, this model may simply be too risky to use; other types of assistance may be easier to implement or more resilient to changes in administration.

An alternate regional hub model that Congress and DOE could consider is the CHIPS and Science Act’s Regional Technology and Innovation Hubs and NSF Engines. These programs had a much lower level of ambition, providing awards – on the order of tens of millions instead of one billion – to seed early-stage innovation, build a research ecosystem, and support workforce development, rather than deploying specific technologies. 

Program Design: Demand-Pull 

Demand-pull mechanisms have emerged in conversations between FAS and former DOE staff as a very underutilized but promising tool for enabling the scaling and deployment of clean energy technologies and large-scale infrastructure projects. Confidence in long-term offtake is a requirement for private lenders to provide financing at a viable rate for projects. DOE can help provide that certainty through a wide range of tools, including purchase commitments and capacity contracts, contracts-for-difference, and other financial arrangements. 

By unlocking private sector investment, demand-pull mechanisms can reduce or eliminate the need for DOE to provide additional financing for project construction. However, public sector funding is still useful for pre-construction stages of project development, such as planning, siting, and permitting, which can be hard to get private sector financing for when other risks to a long-term revenue model have not been addressed yet.  

There are three primary use cases for demand-pull mechanisms: building shared infrastructure, demonstrating innovative technologies, and expanding industrial capacity. 

Shared infrastructure projects require a large number of customers and can sometimes struggle with securing them: customers are afraid to commit without the developer demonstrating that they’ve secured other customers first. DOE can help address this challenge by serving as an anchor customer for these projects and help attract additional customers. This also makes it easier to finance the project. 

A successful example of this from BIL is the Transmission Facilitation Program, which authorized DOE to purchase up to 50% of the planned capacity of large-scale transmission lines for up to 40 years. Once the transmission line is built, DOE can then sell capacity contracts to actual customers who need to use the transmission line and recoup the agency’s investment. This approach could be used for other types of shared infrastructure, such as hydrogen or carbon dioxide transportation, or even large clean, firm power plants (e.g., nuclear) for their generation capacity. 

First-of-a-kind projects often struggle to secure offtakers due to the unproven nature of their technology and the lack of a pre-existing market. For example, H₂DI was designed to complement the Hydrogen Hubs program by directly supporting demand for select hydrogen producers and also helping establish a transparent strike price for the nascent market that would benefit all hydrogen producers. Other demonstration programs (e.g. IDP) would have also benefited from DOE support for demand and market formation.

Lastly, the development of new industrial capacity for producing energy technologies and their inputs can also face demand challenges because while there may be a pre-existing global market, the domestic market may be small or nonexistent, and existing offtakers may not be willing to reroute their supply chains without market or policy pressure to do so. This was most obvious with the critical minerals and battery supply chain projects that DOE tried to support. 

One successful model from the IRA was the HALEU availability program. DOE set up indefinite delivery, indefinite quantity contracts with companies developing HALEU production capacity and set aside $1 billion to procure HALEU from the five fastest movers. The purchase commitment created demand certainty, while the competitive model incentivized faster project development and ensured that the DOE’s funding would only go towards the most viable projects. More programs like this would be transformative for domestic supply chain development.

In designing demand-side support programs for these latter two categories, DOE must tailor the programs to the unique challenges of different technologies or commodities, and whether or not there are additional goals of domestic market formation and/or market stabilization. For example, auctions are a great tool for price discovery, while contracts-for-difference can help projects hedge against price volatility and overcome domestic price premiums. 

There are also double-sided market maker programs where DOE serves as an intermediary between producers and buyers, entering into long-term offtake commitments with project developers up front to provide demand certainty, and then reselling the product to buyers on a shorter-term basis when the project comes online This helps make supply chain connections and address mismatches between project developer vs. buyer timelines. For example, for low-carbon cement and concrete, buyers typically procure building materials on a short-term basis as needed for each project, but developers of first-of-a-kind production facilities require long-term offtake commitments in order to secure project financing.

Authorizing language and/or appropriations can be a barrier to DOE using demand-pull mechanisms. To address this issue, Congress should factor the following considerations into the design of legislation:

1. Flexible Authorities. Due to the variety of demand-pull mechanisms and the need to tailor them to the unique market challenges of different technologies or commodities, they are best implemented using OT agreements. Statutory language that prescribes the exact type(s) of assistance (e.g., grants) for a program can prevent DOE from using demand-pull. Instead, Congress should provide clear goals for a program to achieve and leave DOE with the flexibility to determine the best type of assistance mechanism. 
2. Budget Scoring and Timelines. Demand-pull mechanisms often involve multi-year advance commitments of funding, but the exact amount and timing of transactions may be uncertain, since it is conditional upon project performance and overall market conditions (e.g. contracts-for-difference payments are based on the market price at the time of the transaction). This results in budget scoring issues. Legally binding commitments of money can typically only be made if the agency has enough funding to obligate the full amount of the contract when it is signed, even if that funding probably won’t be paid out until much later.⁶ This results in the need for a significant amount of upfront funding, which can be difficult to obtain from Congress, and long timelines before the outcome of that funding is fully realized, which can make it difficult to manage congressional expectations. These long timelines also mean that no-year funding is ideal for DOE to be able to run demand-pull programs without the funding expiring.⁷
3. Revenue Management. Some demand-pull mechanisms are designed with the potential for revenue generation, so legislation should ideally be designed to include the authorization of a revolving fund to allow revenue to be reused for program costs. Alternatively, DOE may contract with an external entity to manage the program funds, as it did with H₂DI, so that the revenue can stay with the partner entity and be reused. 

Program Design: Prizes

Unlike most financial assistance, which operates on a cost-reimbursement basis and requires cost-share, prizes reward performance and are awarded after activities are completed and criteria have been met. This means there are no strings attached to the funding and no IP requirements, making these programs easier for applicants to work with.⁸ Prizes are also of a fixed amount, which incentivizes innovators to find least-cost solutions in order to maximize revenue from the award. On the flip side, innovators are responsible for any cost overruns, and DOE is not required to shoulder that risk. 

In the past DOE has used prizes wrongly to try and reach potential applicants that struggle with the application process for traditional assistance. It’s important to keep in mind the best use cases for prize programs. For example, prize programs rely on clear milestones, but are agnostic on the approach, making them great for interdisciplinary innovation. They can be beneficial for incentivizing new innovators to get involved with problem areas that don’t have many pre-existing solvers. They are also well-suited for small dollar amount awards that otherwise may not be worth the administrative overhead, since the overhead costs for prize programs are lower than traditional assistance programs once they have been designed.

Moving forward, DOE should keep in mind best practices for designing equitable prize programs. Prize programs should ideally be designed as stage-gated competitions with incremental prize payments for each phase, rather than one big payment at the end, so that innovators with fewer financial resources can participate. For example, the first stage could be the submission of a whitepaper with a proposed plan for developing and testing the technology, then the second stage could be lab work, and so on. Participants would be whittled down between each stage to hone in on the most competitive projects.

Program Design: Loans

DOE 4.0’s loan programs could be improved by setting clearer expectations on risk, clearer guidance on State Energy Financing Institution (SEFI) projects, and a strategy for using additional tools such as equity. 

Risk Tolerance. Discrepancies between statutory language and congressional oversight for DOE’s loan programs have historically made it difficult for the agency to determine the right balance of risk. For example, Title 1703 is designed by legislation to fund innovative, higher-risk, hard infrastructure projects that the private sector is typically reluctant to fund. A high-risk, high-reward program should, by nature, be allowed to have some failed projects and still be considered a success. However, Congress has historically been extremely critical of any defaulted loans, making DOE hesitant to use Title 1703 and ATVM to its full potential.

DOE 3.0 made some attempts to improve communications on its approach to risk management, but the agency could do more to communicate the success of its loan programs. Congressional authorizers should help the agency by building risk into the statute of DOE’s loan programs and budgets and better managing the expectations of oversight members.

State Energy Financing Institution (SEFI) Projects. Another area of reform that DOE 4.0 should tackle is the SEFI-supported projects under Title 17, authorized by BIL, which allows DOE to finance any energy project that also receives “meaningful financial support” from a SEFI, such as state energy offices or green banks. However, ambiguity in the statute behind this new carveout caused confusion among states on how exactly to partner with DOE’s loan program. What is considered meaningful financial support? What qualifies as a SEFI? To clarify these questions from states, either DOE 4.0 should create model SEFI guidance or Congress should amend the statute with clear definitions. 

Equity and Other Financing Tools. The Trump administration’s restructuring of the Lithium Americas Thacker Pass loan to include an equity warrant, which gives DOE the right to acquire equity of the company at a set price in the future, has raised questions as to what DOE’s role should be if it were to become an equity owner in a company and what guardrails and visibility is needed in such a scenario.⁹ Policymakers may also want to consider the risks and benefits of expanding DOE’s loan program authorities to include direct equity investments and other financing tools that agencies like the International Development Finance Corporation (DFC) have access to.¹⁰

Program Design: Technical Assistance

DOE 4.0 should expand its technical assistance offerings in three primary ways: technical advising and verification, navigating federal funding, and talent and workforce needs.

Technical Advising and Verification. DOE’s in-house scientific and engineering expertise is a major draw for funding applicants. For example, according to FAS conversations with former agency staff, the project developers behind Vogtle Units 3 and 4, which received a loan guarantee from DOE, would seek advice from LPO engineers when they had engineering questions. Private investors, who may lack the expertise needed for technical due diligence, often use DOE awards as a proxy for assessing project risk. As a result, some project developers will apply for DOE funding to prove their credibility to private financiers and negotiate lower financing rates. 

In the face of potential budget cuts, DOE 4.0 could leverage this strength by offering project certifications that would entail the same technical support and verification as a demonstration award or loan, without the funding support. This would provide a similar market signal to private investors, without costing DOE as much – just staff time. And since DOE is not taking on any project risk, the application and negotiation process could also be simplified and streamlined to align better with private-sector timelines. 

Navigating Federal Funding. DOE should dedicate increased resources to conducting outreach to underserved communities, small businesses, innovators, and new applicants about funding opportunities and shepherding them through the application process. For example, despite awareness of available funding opportunities, some Native American tribal organizations in Alaska were unable to pursue them due to a lack of bandwidth or expertise to participate in resource-intensive (and often times confusing) application processes, and the awards sizes were too small to make them worth the costs of external private consultants to support. Community Navigator Programs and other forms of technical assistance could help communities overcome these barriers to accessing federal support. PIAs can also help with reaching small businesses and new applicants to apply for programs.

Talent and Workforce Needs. DOE has had success with placing talent at state energy offices and other critical energy organizations like public utility commissions through the Energy Innovator Fellowship to embed expertise in under-resourced offices. DOE should consider expanding this program or establishing new programs to place experts at other institutions, such as grid operators, investor owned utilities, and local governments, to advise and support them in adopting new energy technologies and accelerating infrastructure deployment. 

Program Design: Community Benefit Plans

For all of its demonstration and deployment programs, DOE 3.0 introduced a new requirement that awardees create community benefit plans (CBPs) to ensure that communities would share in the benefits of local clean energy projects. CBPs have been both lauded and criticized by community and labor organizations: they praised their intent, but expressed frustration over their limited influence on companies’ plans and that allowable cost limits constrained what could be included in awards. Where CBPs were most effective, they encouraged developers to consider local communities and jobs, though this often required significant internal coordination to use DOE’s funding contracts as leverage. At the same time, CBPs were seen as an additional administrative burden on program implementation, contributing to delays. Under the Trump administration, CBPs will no longer be enforced and are no longer required for future funding opportunities. 

DOE 4.0 presents an opportunity to restore and improve CBPs as a mechanism for both distributing the benefits of federally-funded projects and improving project quality. To maximize impact, DOE 4.0 should focus on a smaller set of high-priority outcomes with clear, measurable success metrics. DOE 3.0’s broad mandate, which spanned jobs, justice, climate, and deployment across multiple programs, sometimes diluted effectiveness and created confusion for staff managing both program design and operations. In DOE 4.0, these outcomes should be closely linked to actual project success, whether through facilitating social license to ease permitting, or supporting workforce development to train and retain workers, as developers themselves emphasized when aligning with program goals. Providing actionable guidance, including templates and real-world examples of successful community benefits plans, can further improve project outcomes. The advocacy community can help lay the groundwork for DOE 4.0 by documenting successful case studies and model agreement language. Congress could help embed key priorities in statute, providing clear, practical guidance that reflects DOE’s administrative capacity and enhances the likelihood of successful implementation.

Additionally, it is critical that future CBP mechanisms account for community preferences, including local prohibitions on certain technologies and other expressions of community priorities. By proactively respecting local concerns, DOE can foster trust and strengthen the long-term impact of projects. DOE 4.0 will also need to navigate tensions around labor preferences. While the department cannot explicitly require union labor, questions about labor practices may signal preferences that vary across states, including right-to-work contexts. This underscores the importance of sensitivity to local norms and expectations.

Where resources allow, DOE 4.0 should hire and dedicate staff with expertise in labor engagement and community partnerships to review applications and provide technical assistance, supporting applicants in navigating the CBP process and designing high-quality, community-centered projects. Technical assistance needs to be done carefully though to avoid perceptions of bias and influencing the award selection process. 

Lastly, clear and consistent guidance across DOE offices is essential. For example, applicants have reported a lack of clarity about what activities qualify as “allowable costs” in CBPs, and different offices have applied inconsistent standards. Establishing a unified, expansive approach to allowable costs—including activities that indirectly support clean energy workforce development, such as community child care programs—can unlock transformative opportunities for local communities. This standardization should be done for other aspects as well. In general, official guidance needs to find a better middle ground between the overly technical, lengthy documents and vague webinars produced by DOE 3.0, so that ideally applicants can understand requirements without staff intervention. 

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Conclusion

Good program design is fundamental to effectively engaging with researchers, industry, state and local governments, and communities, in order to realize the full potential of DOE funding. Though much of the real-world impact of BIL and IRA is still yet to come, DOE can already begin learning from the challenges and successes of program design and implementation under the Biden administration. The recommendations in this report are just as applicable to the remaining funding from BIL and IRA that DOE has yet to implement, as they are to future programs. Moving forward, Congress has the opportunity to reconsider the way that programs are designed in future legislation, especially those targeting demonstration and deployment activities, and make sure that DOE has clear direction and the right authorities and flexibility to maximize the impact of federal funding.

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Acknowledgements

The authors would like to thank Arjun Krishnaswami for coining the idea of DOE 4.0 and his insightful feedback throughout the development and execution of this project. The authors would also like to thank Kelly Fleming for her leadership of the clean energy team while she was at FAS. Additional gratitude goes to Claire Cody at Clean Tomorrow, Gene Rodrigues, Keith Boyea, Kyle Winslow, Raven Graf and all the other individuals and organizations who helped inform this report through participating in workshops and interviews and reviewing an earlier draft.

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Appendix A. Acronyms

ATVM	Advanced Technology Vehicles Manufacturing Loan Program
BIL	Bipartisan Infrastructure Law (a.k.a the Infrastructure Investment and Jobs Act)
CBPs	Community Benefits Plans
DAC	Direct Air Capture
DFC	International Development Finance Corporation
DOE	Department of Energy
DoW	Department of War
EDF	Office of Energy Dominance Financing
EGS	Enhanced Geothermal Systems
FEOC	Foreign Entity of Concern
FERC	Federal Energy Regulatory Commission
FORGE	Frontier Observatory for Research in Geothermal Energy
GDO	Grid Deployment Office
GETs	Grid Enhancing Technologies
GRIP	Grid Resilience and Innovation Partnerships
GTO	Geothermal Technologies Office
H2DI	Hydrogen Demand Initiative
HGEO	Hydrocarbons and Geothermal Energy Office
IDP	Industrial Demonstration Program
IRA	Inflation Reduction Act
LPO	Loan Programs Office
NARUC	National Association of Regulatory Utility Commissioners
NASEO	National Association of State Energy Officials
OBBBA	One Big Beautiful Bill Act
OCED	Office of Clean Energy Demonstrations
ORISE	Oak Ridge Institute for Science and Education
OT	Other Transactions
OTA	Other Transactions Authority
PPAs	Power Purchase Agreements
SEFI	State Energy Financing Institution
TEFP	Tribal Energy Financing Program
TFP	Transmission Facilitation Program
Title 1703	Title XVII Innovative Energy Loan Guarantee Program
Title 1706	Title XVII Energy Infrastructure Reinvestment Financing Program
USGS	U.S. Geological Survey

Appendix B. BIL and IRA Funding Distribution Methodology

The funding distribution heat map at the beginning of the report includes all of the BIL and IRA programs with funding authorized and/or appropriated directly to DOE, excluding loan programs. The following were not included in this table:

1. Loan programs, which are funded differently than traditional programs;
2. Tax credits that DOE helped design (e.g., 45X), which are also funded through a different mechanism; and
3. Programs implemented by DOE, but funded by other agencies’ appropriations, such as the Methane Emissions Reduction Program funded by the Environmental Protection Agency.

Programs were tagged according to their sector or technology area, their activity area, and type of assistance based on key words in their statutory language. Programs could be tagged with multiple sectors/technologies, activity areas, and/or types of assistance.

To determine the amount of funding for each sector/technology and activity area combination, all of the programs with the corresponding tags were included in the sum. Because of this duplicative counting, the sum of the dollar amounts in the table exceeds the total amount of funding for all of these programs. Sector/technology totals were calculated without this duplication, which is why those amounts are less than what one would obtain by summing all of the activity area amounts for a sector/technology. 

Activity area categories:

• “R&D” includes funding for programs covering research, development, and/or pre-commercial pilots.
• “Demonstration” includes funding for demonstration and commercial pilot programs using innovative technologies.
• “Deployment” includes funding for project planning, financing, and offtake; siting and permitting; and the development of standards or codes.
• “Workforce” includes educational outreach, training programs, apprenticeships, and other workforce development programs. 
• “Energy Access and Affordability” refers to funding to lower the cost of energy for low-income households and to support the development or improvement of energy infrastructure for rural and remote areas and tribal nations. Some of these programs involve multiple sectors/technologies (see below). 
• “National Labs Infrastructure” refers to programs funding construction and facility upgrades at national labs. 

Sector/technology categories:

• “Grid infrastructure” refers to programs focused on any part of the transmission network between power generation facilities and consumer households or facilities, plus the planning, operations, and management of grid and the interconnection of new generation or loads to the grid. These were primarily programs implemented by the former Grid Deployment Office or the Office of Electricity.  
• “Power: Technology Neutral” refers to programs supporting power generation or storage that any zero-emission generation technology was eligible for.
• “Power: Solar Energy”, “Power: Wind Energy”, “Power Hydro and Marine Energy”, “Power: Geothermal Energy”, “Power: Nuclear Energy”, and “Power: Energy Storage Systems” refers to programs focused on the underlying technologies and the demonstration and deployment of power generation and storage facilities using these technologies. Demonstration and deployment programs for the manufacturing of these energy technologies and input materials and components (e.g. battery manufacturing or HALEU fuel) were not included in these categories, but rather under the “Manufacturing and Supply Chains” category. 
• “EV Charging Infrastructure” refers to programs supporting charging infrastructure for EVs of any weight class. 
• “Critical Minerals” refers to programs supporting the mining, processing, recycling, and recovery from non-traditional sources of materials on either DOE’s Critical Materials List or the U.S. Geological Service’s Critical Minerals list.
• “Manufacturing and Supply Chains” refers to programs supporting the manufacturing of energy technologies and their input components and materials, as well as advanced manufacturing technologies in general. This category can overlap with both “Critical Minerals” (e.g. the Battery Materials Processing Program) and “Industrial Decarbonization/Efficiency” (e.g. the Advanced Energy Manufacturing & Recycling Grants Program)
• “Industrial Decarbonization & Efficiency” refers to programs supporting the reduction or elimination of carbon emissions from manufacturing industries.
• “Building Decarbonization & Efficiency” refers to programs supporting the reduction or elimination of carbon emissions from building heating, cooling, and electricity consumption. The manufacturing of building technologies was not included in this category, but rather the “Manufacturing and Supply Chains” category.
• “Hydrogen and Clean Fuels” had only one program, the Regional Clean Hydrogen Hubs.
• “Carbon Management” refers to programs supporting the capture (point source and direct air), transportation, utilization, and storage of carbon dioxide.
• “Cross-cutting” refers to programs that are not specific to any one sector or technology.

This piece is the last in a series analyzing the current state of play at DOE, one year into the second Trump administration. The first piece covers staff loss and reorganization; the second piece looks at the status of BIL and IRA funding and the impact of award cancellations.

Overview of DOE Funding for FY26

On January 15th, Congress passed the FY26 E&W Appropriations as part of a second minibus along with the Commerce, Justice, Science and the Interior and Environment Appropriations (bill text and joint explanatory statement). Assuming the President signs this package into law, it will dictate DOE’s funding through the rest of FY26, which ends in September, and potentially into FY27 if any continuing resolutions are passed in the next appropriations cycle. 

Though the administration originally requested drastic cuts to all of DOE’s offices involved in clean energy RDD&D, the FY26 E&W Bill takes a much more restrained approach to budget cuts and reprograms some BIL funds to bolster EERE, NE, FE, and SC budgets. Notably, Congress increased appropriations levels for SC, NE, and SCEP, despite DOE’s request to zero out the budget for SCEP. Overall, compared to FY25, the FY26 Appropriations enact a 1.4% cut to the agency’s budget – a modest amount compared to DOE’s original request for a steep 7.0% cut. 

The passage of the FY26 E&W Appropriations is a major accomplishment for Congress, especially given the short timeline over which the conferenced bill came together and the rejection of the deep cuts advocated for by this administration. Nevertheless, even minor cuts threaten to decelerate progress on energy innovation, manufacturing, and infrastructure necessary for the United States to meet energy demand growth, reliability, affordability, and security challenges – precisely when we need it the most. As we begin the FY27 appropriations process this year, it’s all the more important that Congress not only maintain stable funding levels for DOE, but also begin to rebuild momentum for energy innovation and technological progress.

Reallocation of Unobligated BIL Funds

Section 311 of the FY26 E&W bill repurposes $5.16 billion in unobligated funding from BIL for the following programs:

• $1.28 billion from the Civil Nuclear Credit Program;
• $1.5 billion from the Carbon Dioxide Transportation Infrastructure Finance and Innovation program (CIFIA);
• $1.04 billion from the Regional Direct Air Capture (DAC) Hubs;
• $950 million from the Carbon Capture Large-Scale Pilot Projects and the Carbon Capture Demonstration Projects; and
• $394 million from BIL programs funded through EERE’s account, including those implemented by MESC and SCEP.

The Civil Nuclear Credit Program is a new addition that was not present in either the House or the Senate’s original versions of the E&W bill. The other programs targeted for reallocation and the corresponding amounts were all proposed in either the House and/or the Senate’s original versions of the E&W bill. Notably, funding for the Hydrogen Hubs was spared after conferencing, despite previous inclusion in both chambers’ E&W bills.

The reprogrammed funds are to be used as follows:

• $3.1 billion for NE to be used for the Advanced Reactor Demonstration Program;
• $375 million for the Grid Deployment Office “to enhance the domestic supply chain for the manufacture of distribution and power transformers, components, and materials, and electric grid components, including financial assistance, technical assistance, and competitive awards for procurement and acquisition”;
• $1.15 billion for EERE activities;
• $100 million for NE activities;
• $140 million for FE activities;
• $150 million for SC activities; and
• $150 million for Title 17.

These moves reflect Congress’ emphasis on advanced nuclear demonstration projects, growing concern over grid supply chain bottlenecks, and continued commitment to funding EERE activities, as well as skepticism about the goals and execution of carbon management demonstration programs. 

Zooming in: EERE Suboffices

DOE’s FY26 budget request proposed a major contraction of the EERE portfolio, explicitly requesting zero funding for four sub-accounts Hydrogen and Fuel Cell Technologies, Solar Energy Technologies, Wind Energy Technologies, and Renewable Energy Grid Integration. For the first three, the Department argued that these technologies had reached sufficient market maturity to rely primarily on private capital—which is definitely not the case for hydrogen and fuel cell technologies, and inconsistent with DOE’s continued funding for more mature technologies such as nuclear, coal, and gas. For Renewable Energy Grid Integration, DOE argued that the work would be absorbed into other programs. DOE also sought to near-eliminate the budget for the Building Technologies Office (BTO) and the Vehicle Technologies Office (VTO) by requesting only $20 million and $25 million, respectively, signaling a broader retreat from technologies that would support electrification, energy efficiency, and affordability.

Congress largely rejected wholesale eliminations in the FY26 bill they passed. Compared to FY24 and FY25 enacted levels, the deepest cuts for FY26 were for Solar Energy Technologies (31%) and Wind Energy Technologies (27%). Hydrogen and Fuel Cell Technologies was also targeted for deep cuts in the original House and Senate appropriations bills, but ended up with only a 6% budget cut after conferencing and passage, putting the office in a better position than many of the other EERE suboffices that lost more than 10% of their annual budget. The only two offices that received budget increases were Geothermal Technologies (27%) and Water Power Technologies (10%), reflecting Congress’ prioritization of clean firm energy technologies. 

EERE suboffice funding amounts are dictated in the Joint Explanatory Statement, a report that accompanies annual appropriations bills and provides detailed guidance on how funds are to be allocated within the topline account numbers set by the appropriations bill. Historically, agencies have always adhered to report language; even under full-year continuing resolutions, agencies would still follow the funding guidance set in the prior fiscal year’s report language. 

The second Trump administration broke this precedent: DOE’s FY25 spend plan – released more than three-quarters of the way through the fiscal year – shifted more than $1 billion away from core clean energy programs under EERE, disregarding Congressional direction in the FY24 appropriations report.¹ DOE moved funding away from Vehicle, Hydrogen and Fuel Cell, Solar, Wind, and Building Technologies, towards Renewable Energy Grid Integration and Water Power, Geothermal, Industrial, and Advanced Materials and Manufacturing Technologies. These actions have raised concerns about whether the administration will attempt to do the same in FY26.

Zooming in: National Labs

The Joint Explanatory Statement does not provide guidance on how DOE allocates funding to national labs, though there tends to be a trickle down effect depending on which offices labs are reliant on funding from. DOE proposed drastic cuts to the FY26 budgets of many national labs, particularly those that get a significant amount of funding from EERE. Under the proposed budget cuts, the national labs would reportedly plan to lay off 3,000 or more scientists and other staff. 

The National Renewable Energy Laboratory (NREL) – recently renamed the National Lab of the Rockies, or NLR for short – faces the largest proposed budget cut of 72% because it’s affiliated with EERE and gets the majority of its funding from that office. Such deep cuts would require NLR to lay off up to a third of its staff and shut down many of its facilities and ongoing activities. 

With the passage of FY26 appropriations, hopefully, DOE will reconsider funding for national labs and adjust budgets upwards to reflect the much milder cuts that Congress passed.

Long-Term Impacts

Sustained budget cuts to DOE pose significant long-term risks to the nation’s scientific enterprise and ability to compete globally. Because DOE is the federal government’s primary engine for energy research and advanced technology commercialization, reductions in funding have both immediate operational consequences, as well as lasting structural ones. 

Budget cuts translate directly into workforce attrition across DOE program offices, national laboratories, and partner institutions. When staffing levels fall, the federal government’s capacity to execute world-leading scientific research diminishes. Essential functions like managing user facilities, overseeing complex R&D portfolios, and ensuring the continuity of long-term research programs are all jeopardized, slowing the pace of innovation and limiting the nation’s ability to respond to emerging scientific and energy challenges.

Loss of program funding and workforce capacity raises a broader strategic concern: the U.S. may no longer retain the scientific and engineering talent necessary to develop next-generation energy technologies. DOE plays a critical role in cultivating and sustaining technical talent pipelines through early-career research programs, national lab fellowships, university partnerships, and long-term R&D initiatives that span decades. When the continuity of these programs is disrupted, students, postdocs, and mid-career researchers may exit the field entirely or shift their expertise abroad, diminishing the domestic talent base. These losses cannot be quickly reversed as rebuilding a skilled scientific workforce takes sustained investment, stability, and opportunity signals that cuts fundamentally undermine. 

Attrition is not limited to DOE itself. The broader U.S. science and innovation workforce – spanning clean energy startups, universities, private-sector R&D, and communities that host national laboratories – absorbs the shock of federal retreat. Reduced research funding forces universities to shrink labs, scale back graduate cohorts, and limit collaborations with DOE facilities. National laboratory communities, often in rural or specialized high-tech regions, face economic consequences when jobs disappear or major facilities reduce their operating capacity. The ripple effects of lost researchers, technical staff, and support personnel weaken the entire innovation ecosystem that underpins clean energy deployment. 

Quantifying these long-term losses is essential. Each scientist or engineer who leaves the field takes with them years of specialized training, intellectual and institutional capital, and future contributions to technological advancement. The economic value of these foregone innovations – from delayed commercialization timelines to missed breakthrough discoveries – can be substantial. A shrinking innovation pipeline also slows private-sector investment domestically and increases dependence on imported technologies at a moment when global competition in clean energy, advanced computing, and critical minerals is accelerating. 

In the long run, sustained budget cuts compromise the United States’ ability to remain a global leader in science and innovation. They jeopardize advancements in energy innovation, undermine national competitiveness, and reduce the nation’s capacity to deliver affordable, secure, and clean energy solutions. Protecting DOE’s workforce and research infrastructure is therefore not only a matter of annual appropriations, but also a long-term investment in America’s economic strength and technological leadership. 

Conclusion: The Path Forward

As we begin the second year of the second Trump administration, DOE sits upon the precipice of transformation. Over the past year, the rapid pace and unprecedented scale of changes to the agency’s staff, organizational structure, programs and awards, and budget have generated waves of uncertainty and volatility that has rippled out across the energy sector, destabilizing commercial projects worth billions of dollars, as well as DOE’s relationship with the private sector, state and local governments, its own career staff.

After all these changes, whether DOE transforms for better or worse will depend on the decisions this administration makes over the next three years. Realizing this administration’s priorities of energy dominance and abundance will require DOE to rebuild its technical and organizational capacity to design and implement programs, oversee loans and awards, and engage in public-private and intergovernmental partnerships. 

This should start with carefully managing the agency’s reorganization and providing clearer, more detailed explanations to the public on the mandate and internal structure of new offices and where existing programs and activity areas have been moved, and guidance to employees about how the reorganization will impact their roles and the programs on which they work.  DOE leadership should then evaluate the functions and capacities missing under the new organizational structure and rehire for those roles, ideally with the reinstatement of remote work flexibility.

As the agency rebuilds internal capacity, it should reorient efforts away from reacting to the previous administration and towards actions that will build the infrastructure necessary to modernize and expand the energy system, ensure reliability and affordability in the face of demand growth, secure energy supply chains, and maintain U.S. leadership in energy innovation. The wave of funding opportunity announcements for BIL critical minerals programs over the past few months was a good start, but that is not DOE’s only mandate. DOE must also restart activities across other technologies and sectors. Luckily, the agency still has $30 billion plus in funding from BIL and IRA that has yet to be awarded. In implementing the remaining funding, DOE can learn from the many lessons learned reports on the previous administration’s experience and adopt internal reforms. The agency should also make sure to adhere closely to the statutory intent behind this funding.

Lastly, stable year-to-year funding is essential for progress. As Congress begins the FY27 appropriations process this month, congress members should also turn their eyes towards rebuilding DOE’s programs and strengthening U.S. energy innovation and reindustrialization. Higher DOE funding levels will be necessary to put the United States back on a growth trajectory with respect to global energy leadership and competitiveness. 

Acknowledgements

The authors would like to thank Megan Husted and Arjun Krishnaswami for their pivotal roles in shaping the vision for this project, planning and executing the convenings that informed this report, and providing insightful feedback throughout the entire process. The authors would also like to thank Kelly Fleming for her leadership of the project team while she was at FAS. Additional gratitude goes to Colin Cunliff, Keith Boyea, Kyle Winslow, and all the other individuals and organizations who helped inform this report through participating in workshops and interviews and reviewing an earlier draft. 

This piece is the second in a series of analyzing the current state of play at DOE, one year into the second Trump administration. The previous piece on staff loss and reorganization can be read here.

Introduction

$25.8 billion in BIL appropriations, over a third of the total amount, have yet to be awarded, plus up to $4.3 billion in IRA funding left after OBBBA rescissions. Yet, for the entire first year of the Trump administration, DOE has focused primarily on undoing the work of the prior administration. Politically motivated award cancellations and the delayed distribution of obligated funds have broken the hard-earned trust of the private sector, state and local governments, and community organizations. DOE also carried out a significant internal reorganization that eliminated many of the commercialization and deployment focused offices and moved their programs into other offices, leaving their futures unclear. 

The implementation of remaining BIL and IRA funding has been stalled across the board (except for critical minerals-related programs), and the administration has attempted to push the limits of legislative interpretation by redirecting funds for carbon capture and rural and remote energy improvements towards bringing inactive coal power plants back into service and/or extending the life of coal plants near retirement. 

Overview of BIL and IRA Funding Status

BIL and IRA appropriated $71 billion and $35 billion, respectively, in funding for DOE clean energy programs. Once appropriated, DOE funding moves through three phases before being received by awardees:

1. First, funding is awarded when DOE selects and announces the recipients for a program. Only 57% of BIL funding and 52% of IRA funding was awarded by the end of the previous administration.
2. Then, funding is obligated when DOE legally commits the amount to the recipient through a contractual agreement. Obligations may be made in phases over time, especially if the award is of a large amount. Thirty-three percent (33%) of BIL funding has been obligated as of December 17th, 2025.
3. Finally, funding is outlayed when the money is paid to the recipient(s) and officially transferred out of the federal government’s account. This can occur in installments over the course of the period of performance or through a single up-front payment. Four point eight percent (4.8%) of BIL funding has been outlayed as of December 17th, 2025.

Under the current administration, at least $11 billion, or 32%, of unobligated IRA funding was rescinded through the One Big Beautiful Bill Act (OBBBA), including the IRA credit subsidy appropriations for DOE’s loan programs, while $5.16 billion in BIL funding was transferred for other purposes by the Fiscal Year 2026 (FY26) Energy and Water Development (E&W) bill. Mass rescissions and reallocations of funding on this scale have been unheard of in the past.

A further $6.8 billion in BIL awards and $2.5 billion in IRA awards have been cancelled by the Department of Energy, primarily because they do not align with the new administration’s priorities. For BIL, the cancellations will impact 17% of awarded funding, 14% of obligated funding, and 3% of outlayed funding. For IRA, the cancellations will impact 7% of awarded funding. While DOE has in the past made one-off cancellations of individual awards for various reasons, mass cancellations on this scale are unprecedented and uniquely destructive to the relationship between DOE and the private sector, not to mention state and local governments and community organizations.

Award Cancellations

The first round of DOE award cancellations were announced in May 2025. The 24 cancelled awards, worth $3.7 billion, all came from OCED programs funded by BIL and IRA. The Industrial Demonstration Program (IDP) was the most severely impacted: 18 awards worth $3 billion, half of the total for the program, were cancelled. The other primary targets from this round of cancellations were the Carbon Capture Demonstrations Program and the Carbon Capture Large-Scale Pilots Program.

In early October 2025, DOE announced the cancellation of another 321 awards, worth over $8 billion. Of those awards, five from the IDP were duplicates from the May announcement. Once again, OCED’s programs were the most heavily impacted, with GDO a close second. The largest awards cancelled were the two west coast Hydrogen Hubs, each worth at least $1 billion and three of the Grid Resilience and Innovation Program (GRIP) awards located in California, Minnesota, and Oregon. Unlike the first round, other DOE awards not funded by BIL or IRA, roughly half of the list, were also cancelled. These awards primarily came from EERE and FE.

Only about 1.5% of the funding for these BIL and IRA awards was outlayed before they were cancelled. Non-BIL and IRA awards fared slightly better, with 38% of funding outlayed before they were cancelled. As a result of these cancellations, awardees may decide to abandon their projects entirely, which would end up wasting the hundreds of millions of dollars of federal funding that has already been spent.

The most direct impact of these cancellations is that communities that were promised jobs and other benefits will no longer get them. DOE is breaking its commitment to companies, workers, and other stakeholders, taking away the economic opportunity that new investments provided. 

Moreover, federal funding would not be the only funding wasted: many of the canceled awards came with matching private-sector investments, totaling over $5.7 billion. In order for those private-sector investments to be put to use, project developers would need to seek additional funding to close the gap left by cancelled DOE awards. Even in the best case scenario, that process requires additional time and effort, resulting in delays and higher overall project costs. 

The vast majority of these private-sector investments were intended to fund grid resilience and modernization projects. In the face of demand growth and grid reliability challenges, particularly from data centers, it seems counterintuitive to pull funding from these projects rather than doubling down on investments to improve and expand our grid infrastructure. These cancellations also run counter to the administration’s stated priority of “unleashing American energy” and will make it harder to provide the electricity needed to power the AI applications and innovations touted by this administration.

An additional list of projects has been circulating since the beginning of October, said to contain an additional $16 billion worth of projects being considered by DOE for cancellation. In late October 2025, Politico’s E&E News reported that DOE confirmed the cancellation of five of the projects on that list, totaling $718 million in funding, because they were not “economically viable.” All of the projects were funded by the Office of Manufacturing and Energy Supply Chains (MESC), which had been largely spared by the previous rounds of cancellations. Four of the cancelled awards were from the Battery Materials Processing and Battery Manufacturing Grant Programs, while the other award came from the Advanced Energy Manufacturing and Recycling Program. Since then, at least one of the projects, a lithium iron phosphate plant in Missouri, has folded, partially as a result of the DOE award cancellation.

In response to the cancellations, most companies are challenging the decision and seeking as much compensation as they can through the courts. The Supreme Court has ruled that challenges to the termination of specific awards must be filed through the U.S. Court of Federal Claims, which is understaffed and struggling with significant backlogs and delays. However, while large companies may be able to wait six months or up to one year for compensation, many small businesses and startups will go under if they cannot get recourse in time and run out of funding to keep paying their employees. Furthermore, the Federal Claims Court does not have the authority to reinstate terminated grants or contracts, which is what companies actually want.

A coalition of energy and environmental organizations filed a lawsuit over seven of the cancelled grants and won, arguing that DOE’s termination decisions were politically motivated and thus illegal, targeting awards primarily because they were located in blue states and/or funded clean energy technologies that the administration opposes. Those seven award cancellations have now been blocked by the judge’s decision, but the hundreds of other cancellations will continue unless additional lawsuits are brought forth.

All of this has resulted in a growing belief across the private sector (and also local governments and community organizations) that federal grants and contracts are no longer guaranteed to survive a change in administration. This destroys the trust built by 50 years of DOE upholding its contracts and commitments to the private sector. The Biden administration expanded this partnership with the private sector further, conducting significant outreach to improve interest from top tier companies in BIL and IRA programs. Now, all of that hard-won trust has been undone. 

Members of Congress from both sides of the aisle have been watching these cancellations with concern. Section 301 of the FY26 E&W Bill introduces a new requirement that DOE must notify both the House and Senate Appropriations Committees at least three full business days before the agency issues a letter to terminate a grant, contract, other transaction agreement, or lab call award in excess of $1 million. The same requirement applies to any letter to terminate nonoperational funding for a national lab if the total amount is greater than $25 million.

Loan Cancellations, Delays, and New Terms

In addition to reevaluating and cancelling awards, DOE leadership also reevaluated the loans and conditional commitments made under the Biden administration, slowing down the evaluation process. So far, DOE has publicly terminated a $4.9 billion conditional commitment for the Grain Belt Express transmission. DOE was also reported to have plans to cancel six more conditional commitments and one active loan, totaling $8.5 billion. Former LPO staff have shared that these terminations were mutually agreed upon between the borrowers and DOE due to project economics. Some of this administration’s policies (e.g. the permitting ban on wind energy projects) may have indirectly contributed to worsening project economics.

Under the current administration, DOE has moved some projects that align with the White House’s priorities from conditional commitment to close – namely, AEP’s transmission upgrades and Wabash Valley Resources’ Coal-Powered Fertilizer Facility – and fast tracked a loan to restart the Three Mile Island Crane nuclear unit directly to close. However, for other projects less aligned with this administration’s priorities, DOE appears to be delaying the process to move conditional commitments forward and close out the loans. Former agency staff from the office claim that this is a way to softly cancel loans by putting timelines in limbo and waiting out the borrower, since conditional commitments have a maximum window of two years to either move to close or be rejected.

Changes to the term sheet when closing a loan is another way to force applicants out of the pipeline. Applicants typically receive an initial term sheet with the conditional commitment and then a final term sheet when closing the loan; applicants may not be able to accept or accommodate drastic changes between the two.

Notably, this administration restructured Lithium Americas’ Thacker Pass loan after it was closed, but before funds were disbursed. LPO has the right to restructure loan terms and get new conditions or concessions to protect taxpayer resources if there are concerns, but this is rarely done. LPO negotiated the right to 5% equity in Lithium Americas and 5% equity in the Thacker Pass joint venture in the form of a warrant. The agency statement points to LPO’s loan to Tesla in 2010 as precedent for using warrants. This move raises the question of whether LPO will be negotiating additional equity stakes in future loan agreements, given this administration’s many other equity deals. 

Remaining BIL & IRA Funding and Awards

Loans are not the only thing DOE has slow-walked: recipients of active BIL and IRA awards have complained that DOE also delayed the distribution of obligated funds and was not paying invoices in a timely manner. This issue was especially acute in the beginning of 2025, when many grants and contracts were frozen and recipients were told to stop all work while new DOE leadership reviewed their funding. While some projects were allowed to move forward, some remained in limbo even towards the end of 2025, causing significant uncertainty and financial stress to awardees.

As for the remaining unobligated BIL and IRA funds, DOE has not issued any new funding opportunity announcements (FOAs), except for critical minerals-related programs, which have been favored by this administration, and a repurposing of BIL funding to support coal power plants:

• FE issued two FOAs for piloting byproduct critical minerals and materials recovery and mine technology proving grounds. MESC issued an FOA for a rare earth elements demonstration facility and a notice of intent to issue an FOA for round three of the Battery Materials Processing and Battery Manufacturing and Recycling Grant Program.
• FE issued an $525 million FOA “to expand and reinvigorate America’s coal industry.” Up to $175 million of funding would come from BIL funding for energy improvements in rural and remote areas. The remaining $350 million would come from BIL funding for the Carbon Capture Demonstration Projects Program and the Carbon Capture Large-Scale Pilot Projects, which both have unobligated balances as a result of prior award cancellations. Critics have questioned the legality of repurposing the carbon capture program funds in this way, since the FOA allows federal funding to be used for near-term reliability upgrades “without requiring immediate Carbon Capture Utilization and Storage (CCUS) installation,” even though the Congress specifically directed this funding to be used “to demonstrate the construction and operation of six facilities to capture carbon dioxide from coal electric generation facilities, coal electric generation facilities, natural gas electric generation facilities, and industrial facilities” and specifically two of each kind.¹ 

Acknowledgements

The authors would like to thank Megan Husted and Arjun Krishnaswami for their pivotal roles in shaping the vision for this project, planning and executing the convenings that informed this report, and providing insightful feedback throughout the entire process. The authors would also like to thank Kelly Fleming for her leadership of the project team while she was at FAS. Additional gratitude goes to Colin Cunliff, Keith Boyea, Kyle Winslow, and all the other individuals and organizations who helped inform this report through participating in workshops and interviews and reviewing an earlier draft. 

Appendix: Methodology for BIL and IRA Funding Analysis

Data on total BIL and IRA appropriations and award amounts was obtained from the archived Invest.gov website created by the Biden administration’s White House. Loan amounts were not included, since loan authority is separate from appropriations. The archived Invest.gov website has not been updated since the end of the Biden administration. As of December 17th, 2025, the Trump administration has not made any new awards yet with BIL or IRA funding, so the data should be accurate up to that date.

Data on obligations and outlays came from the Department of Treasury’s USA Spending database. The total amount of obligations and outlays of BIL funding for DOE was determined by filtering for the Disaster Emergency Fund Codes for Infrastructure Spending associated with BIL and DOE as the Awarding Agency. All assistance awards and contracts that resulted from these filters were included in the total amounts. 

The obligations and outlays for cancelled BIL and IRA awards in October were determined by searching the database for each unique award ID found in the list obtained by Latitude Media. The total amount of obligations and outlays for cancelled BIL and IRA awards in May was determined by searching the database for the awardees in the list reported by The New York Times and matching the award amounts, award location, and/or award description. All available data up until December 17th, 2025 was included. USA Spending tracks the amount of obligations and outlays for each award that came from BIL; this data was used to determine whether or not a cancelled award was funded by BIL. Whether or not a cancelled award was funded by the IRA was determined based on whether or not the award description explicitly mentions IRA and/or searching official DOE announcements and other public documents for the specific award using the recipient name and award description available on USA Spending. Any remaining awards were assumed to be funded by neither BIL nor IRA.

In this report, the total amount of unobligated funding rescinded by OBBBA is a minimum estimate. The minimum rescission amount for every loan program listed in Section 50402 of the OBBBA was determined by subtracting the total funding obligated from the loan program account between FY23 and FY25 (found on USA Spending) from the total appropriations for the program from the IRA (found in the bill text). The minimum rescission amount for every other program listed in Section 50402 of the OBBBA was determined by subtracting the total funding awarded for the program from the total appropriations for the program (both obtained from Invest.gov).

This piece is the first in a series analyzing the current state of play at DOE, one year into the second Trump administration.

As the heart of energy innovation and infrastructure policy in the federal government, the Department of Energy (DOE) and its national labs play a crucial role in ensuring that the energy sector can meet the needs of the American people and the economy. DOE serves as a key funder of R&D for not just energy technologies, but also basic science and emerging technologies like AI and quantum computing. DOE’s 17 national labs are key supporters of that mission, conducting R&D in house and hosting facilities used by tens of thousands of researchers and innovators from the private sector and academia. 

Over the course of 2025, the second Trump administration has overseen a major loss in staff at DOE; the cancellation and slow-walking of awards across the agency, primarily from Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA) programs but also others; the rescission of billions of dollars from IRA programs through the One Big Beautiful Bill Act (OBBBA). Most recently, Congress passed FY26 appropriations for DOE, reducing funding levels and reallocating BIL funding.

These changes will not deliver the energy and innovation impacts that this administration, or any administration, wants. The departure of seasoned career staff takes with them significant technical expertise and institutional knowledge; while the loss of new talent recruited from the private sector diminishes DOE’s industry and project finance expertise. Reducing DOE’s organizational capacity like this undermines DOE’s fundamental ability to carry out its mission and implement programs crucial to U.S. energy security, innovation and abundance. 

Staff Loss

DOE has experienced deep and systematic cuts to its career staff. Early in the administration, the President issued an executive order calling for “large-scale reductions in force” (RIFs) across all executive branch agencies.¹ As a part of that effort, the administration launched the Deferred Resignation Program (DRP), which was first offered on January 28th, 2025 and then again at the end of March 2025. This “fork in the road” gave career staff the option to resign or, if eligible, retire voluntarily in return for retaining their pay and benefits through September or December 2025, respectively. Expectations of upcoming RIFs incentivized many career staff to opt in to the program, rather than risk being laid off without the DRP benefits. Congressional leaders have questioned the legality of this program.

Nevertheless, the DRP was fully implemented by the Trump administration over the course of 2025, driving the majority of staff departures at DOE during the first six months of the administration. Staff data obtained by FAS indicate that 21% of DOE staff departed the agency between January 16th, right before the Trump administration began, and June 6th of 2025.² Nineteen percent (19%) of DOE staff participated in the DRP, far outnumbering those who left the agency through other paths (e.g. layoffs, other resignations or retirements, etc.).³,⁴

The largest number of departing staff came from the offices under the former Under Secretary for Infrastructure (S3), which lost 52% of its staff due to the DRP and 55% of staff overall. At the most extreme end, the Office of Clean Energy Demonstrations (OCED), established by BIL under the Biden administration, lost 80% of its staff due to the DRP and 84% of its staff overall.  Other new offices established under the Biden administration, such as the Grid Deployment Office (GDO) and the Office of State and Community Energy Programs (SCEP), also suffered heavy losses.

In addition to the DRP, the S3 offices lost a number of staff to the Trump administration’s decision to end remote work, despite a Government Accountability Office (GAO) report finding that remote work policies improve talent attraction and retention, while reducing costs and enhancing productivity. Under the Biden administration, remote work policies enabled DOE to hire early- and mid-career staff who were unable or unwilling to move, especially those from the private sector who had valuable experience with commercial project development and finance.⁵ The new S3 offices established under the Biden administration benefitted the most from this, since they needed to rapidly hire qualified staff to design and implement programs for the large amounts of funding they received from BIL and IRA.

By attracting many industry leaders from the private sector, the S3 offices were able to build trust with major energy companies, leading to much higher participation from top companies in BIL and IRA programs compared to the American Recovery and Reinvestment Act (ARRA). Many of the staff responsible for this heightened private sector trust have now left the agency. 

Offices under the former Under Secretary for Science and Innovation (S4) also suffered greater than average loss of staff: 28% due to the DRP and 29% overall. Even the Office of Fossil Energy (FE) and the Office of Nuclear Energy (NE) lost nearly a third of their staff. According to former DOE staff, some people moved from S3 to S4 in anticipation of the transition to the Trump administration.⁶ In particular, many of them moved to NE, which is why the number of staff in NE on January 16th actually exceeded the number of total positions the office was supposed to have.

During the October government shutdown, the Trump administration directed agencies to move forward with another round of RIFs. DOE leadership informed staff in OCED, the Office of Energy Efficiency and Renewable Energy (EERE), the Office of State and Community Energy Programs (SCEP), and the Office of Minority Economic Impact that they may be fired, transferred, or reassigned due to their involvement in implementing programs under the Biden administration. The Data Foundation estimated that 187 staff were impacted by the RIF. However, the Continuing Resolution, passed on November 12th to end the shutdown, rescinded the RIF notices and guaranteed backpay to impacted federal workers.

The Impacts of Staff Loss

Staff changes and resignations at DOE will inevitably slow down implementation and threaten DOE’s ability to fulfill its mandate. DOE has struggled over the past few years to obligate funding from its budget due to its lengthy application and award negotiation process. Crucial to that process are the institutional knowledge and cohesion between technical and legal contracting teams that career staff build up over time. Every staff member lost creates a gap in the implementation process; the loss of so many staff members threatens to break down DOE’s operations entirely. Even if new staff are hired, that institutional knowledge and working dynamic can’t be recovered.

Contracting in particular is a major bottleneck for implementation. Career staff with decades of contracting experience have now left the agency and national labs. In particular, this loss will make it more difficult to implement demonstration and deployment programs like those funded by BIL and IRA, which require novel and very detailed contracting work.

Furthermore, the deep cuts to S3 call into question DOE’s ability to implement the remaining BIL and IRA funding for demonstration and deployment programs, not to mention DOE’s ability to oversee the billions of dollars worth of demonstration and deployment awards it has already made. Many of the new S3 staff were intentionally hired from the private sector for their industry knowledge and connections. These federal workers were subsequently the first to leave after the presidential transition. They took a risk in working for the federal government, and then were made to feel expendable by the new administration’s heavy-handed attempts to push people out. That experience will color any future attempts by DOE to rehire private sector talent.

The damage to implementation from staff losses will have direct impacts on peoples’ lives. For example, a 63 percent cut to SCEP staff means that whichever new office in charge of its programs post-reorganization (see next section) will not have enough capacity to run key energy affordability programs, like rebates to low-income households for cost-saving appliances or weatherization programs that keep peoples’ homes warm and reduce utility bills. Gutting of OCED and GDO will mean that major projects have a smaller chance of getting built, denying communities the new jobs and energy infrastructure they were promised. 

In addition to implementation capacity, DOE is losing technical expertise that is crucial to informing its research and innovation agenda. DOE’s S4 offices have historically housed the top experts on technology areas from battery chemistry to solar panel design to advanced turbines. Many of these industry-leading experts have now left the agency, which will hamstring DOE’s ability to support private sector innovation in technologies that are critical to building an affordable and reliable energy sector and maintaining U.S. leadership globally.  

The loss of crucial staff can also be expensive. For example, DOE has traditionally relied on internal counsel for the majority of its programmatic work. Now, however, roughly 50% of the field lawyers at DOE who run contracting and oversee the national labs are gone. In September 2025, DOE issued a solicitation for up to $50 million worth of external counsel in support of the agency’s day-to-day needs.

Lastly, the management of national labs (NLs) from DOE headquarters is becoming significantly harder. As seasoned program managers leave, DOE is losing the deep institutional knowledge necessary to manage the Government-Managed Laboratory Complex and to execute core functions, especially the allocation and oversight of funds that Congress intends for the labs. The flow of funds requires experienced staff who understand authorizing statutes, lab agreements, and budget execution mechanics; losing them creates the risk of both bottlenecks and misalignment.

Reorganization

In November 2025, DOE leaders announced a sweeping reorganization that eliminated, consolidated, and rebranded major program offices while creating several new ones, formalizing a significant shift in the Department’s priorities (see Figures 1 and 2).⁷ Several of DOE’s most recognizable clean energy innovation and deployment offices — including EERE, OCED, SCEP, the Grid Deployment Office (GDO), and the Office of Manufacturing and Energy Supply Chains (MESC) — were dissolved as standalone entities. Their programs were redistributed across a new set of divisions organized around broad technology themes rather than the previous approach of differentiating between developmental stages (i.e. R&D vs. demonstration and deployment).

Figure 1. DOE organization chart prior to November 20th, 2025 (Source: DOE).

Figure 2. DOE’s new organizational structure after November 20th, 2025 (Source: DOE)

As part of this shift, DOE created or elevated new offices focused on emerging priorities. A new Office of Critical Minerals and Energy Innovation now centralizes critical minerals programs, which were previously spread across EERE, FE, and MESC, while also seeming to be a catch-all office for remaining EERE, OCED, MESC, and SCEP programs. A Hydrocarbons and Geothermal Office merges FE with the Geothermal Technologies Office. The reorganization also expanded the department’s work on emerging technologies by splintering off programs that used to be contained within the Office of Science: pairing AI and quantum programs into a new office and creating a dedicated fusion office with a more prominent role than before.

These changes significantly alter DOE’s internal map. Programs that once lived together are now split apart, while other functions have been consolidated under new leadership structures. The result is a department whose mission areas are organized very differently than they were even a few months ago, leaving open questions about how core clean energy, deployment, and innovation functions will be staffed and managed going forward.

Though previous administrations, including the Biden administration, have conducted reorganizations of DOE in the past, this reorganization was implemented with significantly less transparency. As of late December, the brief initial announcement and new organization chart are the only information the public has received on the reorganization. DOE’s website is currently inaccessible. Career staff have reported that they still lack clarity as to how their chains-of-command will be affected and whether or not the programs they work on will continue or change. 

These structural changes are unfolding at the same time DOE is experiencing substantial workforce losses, which heightens uncertainty about staff capacity. It remains unclear how remaining staff are being reassigned within the new organizational chart. With offices being renamed or re-scoped — and in many cases merged, split, or relocated — advocacy and stakeholder communities cannot easily determine whether DOE retains the necessary expertise or institutional knowledge to carry out ongoing work. 

Basic information like program areas and suboffices within each office, program leadership, and staffing data is now outdated, making it difficult to track where core functions have moved. Managing this transition is essential for retaining remaining staff and preventing further loss of expertise. DOE leaders must clearly communicate roles, reporting lines, and program continuity to restore internal morale and ensure the agency can continue driving energy innovation and promoting energy abundance amid an unprecedented U.S. energy affordability crisis.

This uncertainty underscores the need for greater transparency from DOE. Providing updated information on each new office’s missions and internal structure, staffing data, and explanations of how programs map onto the new structure would help rebuild trust and give stakeholders a clearer understanding of the agency’s operational capacity. Without this information, questions about DOE’s ability to execute its mission will persist at precisely the time when federal leadership on clean energy, innovation, and energy affordability is most needed.

Acknowledgements

The authors would like to thank Megan Husted and Arjun Krishnaswami for their pivotal roles in shaping the vision for this project, planning and executing the convenings that informed this report, and providing insightful feedback throughout the entire process. The authors would also like to thank Kelly Fleming for her leadership of the project team while she was at FAS. Additional gratitude goes to Colin Cunliff, Keith Boyea, Kyle Winslow, and all the other individuals and organizations who helped inform this report through participating in workshops and interviews and reviewing an earlier draft.

Appendix: DOE Staff Data

The United States’ nuclear command, control, and communications (NC3) system remains a foundational pillar of national security, ensuring credible nuclear deterrence under the most extreme conditions. Yet as the United States embarks on long-overdue NC3 modernization, this effort has received less scholarly and policy attention than the modernization of nuclear delivery systems. This paper addresses that gap by providing a critical assessment of the U.S. NC3 enterprise and its evolving role in a rapidly transforming strategic environment.

Geopolitically, U.S. NC3 modernization must now contend with issues including China’s rise as a nuclear near peer, Russia’s deployment of increasingly threatening hypersonic and counterspace capabilities, and the erosion of norms restraining limited nuclear use.

Technologically, the shift from legacy analog to digital architectures introduces both great opportunities for enhanced speed and resilience and unprecedented vulnerabilities across cyber, space, and electronic domains.

Bureaucratically, modernization efforts face challenges from fragmented acquisition responsibilities and the need to align with broader initiatives such as Combined Joint All-Domain Command and Control (CJADC2) and the deployment of hybrid space architectures.

This paper argues that successful NC3 modernization must do more than update hardware and software: it must integrate emerging technologies, particularly artificial intelligence (AI), in ways that enhance resilience, ensure meaningful human control, and preserve strategic stability. The study evaluates the key systems, organizational challenges, and operational dynamics shaping U.S. NC3 and offers policy recommendations to strengthen deterrence credibility in an era of accelerating geopolitical and technological change.

Read the complete publication here.

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This publication was made possible by a grant from the Carnegie Corporation of New York. The statements made and views expressed are solely the responsibility of the author.

Observers of Chinese nuclear politics and force posture are old friends with information challenges. Open-source analysts of China’s nuclear force drew heavily on published Chinese-language writings, footage, and interviews by official Chinese media or private Chinese citizens, as well as commercial satellite imagery. These powerful open-source tools enable scholars to gain insight into some of the Chinese government’s most closely guarded secrets, such as the construction of 119 nuclear missile silos. Reports from well-regarded institutions, such as the PLA Rocket Force Order of Battle report by the James Martin Center for Nonproliferation Studies, offer open-source research that provides concrete data on the Chinese nuclear force, using thoroughly analyzed imagery and Chinese-language materials. Other studies, such as several reports by the RAND Corporation and the Air University’s China Aerospace Studies Institute (CASI), extensively used Chinese military and technical writings to identify patterns in the People’s Liberation Army (PLA)’s strategic thinking in its own words. Combined with the Federation of American Scientists (FAS)’s annual report on nuclear forces, there is a growing and vibrant open-source intellectual community on the People’s Liberation Army Rocket Force (PLARF).

While researchers continue to dissect new information from China, obtaining reliable data has become increasingly difficult for two reasons. First, the Chinese government has curtailed foreign access to sources like academic databases that were previously fair game for scholarly use, complicating the already dense “information fog” over China’s political and military apparatus. Second, unverified, digitally altered, and AI-generated disinformation and misinformation are commonplace on popular social media platforms like X (formerly Twitter). Combined with the multitude of Chinese social media and video websites, weeding out the noise and distraction has become an increasingly challenging task for new researchers in this field.

This essay provides introductory guidance on the usefulness of Chinese social media and video platforms for observers and researchers of China’s nuclear force. This guide may assist researchers in identifying what to look for and on which platform, especially for those who are not advanced or native speakers of Mandarin. In the sections below, I compare a set of popular Chinese social media platforms and discuss the usefulness of each with respect to open-source study of the Chinese nuclear force. I also present a brief glossary of nicknames and vernacular terms related to nuclear matters in Mandarin, along with their translations. I conclude with a brief discussion of the use of AI-enabled translation tools for open-source research on the PLA.

Chinese media and OSINT: What’s good for what?

Sina Weibo (新浪微博)

Weibo is useful for providing timely, authoritative, and chronologically documented information on training exercises, operations, and policy changes that are of propaganda or morale-promoting value. The equivalent of X in China, Weibo is the biggest Chinese-language social media with over 500 million monthly active users as of 2024. It is likely the most influential social media platform in China, as indicated by the vast number of users and a highly agile and effective censorship system. Due to Weibo’s ability to rapidly disseminate information, all major state and military organs, including the PLA Daily, the Ministry of Defense, individual service branches, and all five PLA Theater Commands (战区), maintain official accounts on Weibo (Figure 1). These accounts are directly managed by dedicated propaganda or public affairs teams and authorized to post military content, which sometimes features approved footage and photos of training exercises. Details revealed in the footage or pictures may help researchers identify the unit leadership and the weapon systems used during the exercise. Additionally, Weibo is often the first platform to announce state media PLA news. The People’s Daily, CCTV, and the Xinhua Agency regularly post links to news articles and updates on Weibo to facilitate dissemination.

For researchers, Weibo contains a reasonably reliable search system. Researchers may use the Weibo search bar to look for mentions of “strategic deterrence,” “nuclear force,” or names of nuclear missiles and use the filter function to screen for content released by official accounts. For well-publicized events like a missile exercise, the topic may be included in the trending (热搜) section for real-time updates. However, a significant limitation of Weibo is that scholars must distinguish whether the content posted by the official accounts directly reflects the Party’s policy or simply shows a lower-level interpretation of the policy by individual units. These official accounts are likely managed by young, tech-savvy officers or civilian employees trained in public affairs.

Figure 1. An example of PLARF Weibo post on 17 May 2025. A link is embedded in the picture that leads to an article.

Sometimes, these individuals might improvise and go beyond what they were prescribed. Some more active accounts, such as the Eastern Theater Command official account, have interacted with random Weibo users in the past and have eagerly implied their belligerent stance toward Taiwan. This led many Chinese netizens to interpret the official account’s posts as a sign of imminent military action, which thankfully was not the intention. Additionally, state-run accounts have also taken down content (primarily propaganda material) for reasons other than revealing unapproved or sensitive information. Again, since the accounts are likely managed by younger personnel at the lower level, contents could be removed when it was later found to be too politically sensitive or too unpersuasive. In 2019, the People’s Liberation Army Army (PLAA) official account posted a propaganda article on Weibo aimed at inspiring nationalistic fervor. It quoted a passionate patriotic poem written by Wang Jingwei (汪精卫), whom the Chinese government considered a “traitor (汉奸)” for cooperating with the Imperial Japanese invaders, most likely because the editor had known about the poem but not its authorship. The comment section quickly pointed out this “political mistake (政治错误)”, leading to the content’s prompt removal. As such, researchers should be aware that removed content does not necessarily suggest valuable information worth hiding.

It is also important to note that accessing Weibo sometimes involves more than typing in the URL. Aside from the content available on the front page (e.g., the trending section), the rich content of the platform is only accessible after logging in. One does not need a mainland Chinese phone number to create an account on Weibo. A virtual number from a trusted provider is also sufficient. Even without an account, researchers could still access the Weibo homepage of many accounts by searching the account’s name in a search engine (for instance, here is the direct link to the official PLA Eastern Theater Weibo page). However, Sina Weibo’s search bar will not be available for unregistered users.

CCTV.com (央视网)

CCTV.com is a webpage that gives scholars access to the state media’s TV programs without a registered account. In addition to live-streamed news stories, the webpage also serves as a large but incomplete archive of past TV programs. CCTV.com has high-definition PLA video footage and interviews, which may be particularly useful for open-source analysis. Some of the CASI reports made clever use of video footage released by Chinese state media to identify key information regarding training exercises and unit deployment, particularly the CCTV-7 channel dedicated to military content. Other open-source intelligence analysts were able to map out key personnel, location, and weapon system information from CCTV news broadcasts and military TV programs. The search bar supports keyword searches and includes government-sponsored TV programs from various channels. The search also returns results from CCTV webpages and the Xinhua Agency. This is the most useful for finding information related to specific missile systems. For instance, among the top results for “DF-26” include footage of a DF-26 missile from a documentary (Figure 2). The search result for “dual-capability” also returned a video by a Chinese military commentator who states that China’s hypersonic vehicle is dual-capable (Figure 3). For open-source analysis, having the ability to revisit footage that might contain useful information on the PLARF is a major advantage of this platform. At the same time, the search function is limited to the titles of the program, not necessarily the content. Furthermore, many of the videos available on CCTV.com are commentaries from Chinese military experts. While the commentary from the Chinese experts may be useful, the visual component may not always be the latest developments. Because of the length requirement of the TV program, the visual element may only have looped videos of known weapon testing or parade footage. Researchers may consider comparing the footage from different programs to remove the repeated material.

Figure 2. An example of searching for the DF-41 ICBM on CCTV.com. Note that the research results contain programs from multiple TV channels.

Figure 3. A screenshot of search results for “dual-capability”. Note that the Chinese official media also uses this term for the submarine force.

Bilibili (哔哩哔哩), Douyin (抖音), Kuaishou (快手)

Bilibili, Douyin, and Kuaishou are among the most used entertainment video-sharing and short-video platforms in China. Bilibili is a video service primarily for animation, comics, and games (ACG) content. It has a “bullet comment (弹幕)” function that allows users to inject text over the video content in real time. The platform attracts over 100 million daily users as of 2024. Douyin (the Chinese mainland version of TikTok) and Kuaishou are short-video platforms with a significantly larger user base than Bilibili, with Douyin content reaching over 1 billion active users monthly. Unsurprisingly, the PLA, the individual Theater Commands, and the Chinese government and Party organs maintain an active presence on these platforms for propaganda, news updates, and publicity programs, often repeating the same message sent across other outlets.

However, despite these platforms’ popularity, they are not great resources for open-source nuclear force research for two reasons. First, there is overwhelming noise from private click-farming content creators who would grossly overstate or fabricate China’s military capabilities to profit from nationalistic sentiments. A researcher may find many videos speculating about the capabilities of the H-20 bomber with no credible source to back up the claims. Private content creators typically have no privileged access to information. In the rare cases where some villagers filmed a rocket booster falling from the sky (some Chinese rocket boosters in the past landed in populated villages), the video is often quickly censored on these closely watched platforms. Second, official government accounts on these platforms almost always repeat information that has been released on Weibo and other traditional news platforms. Some Party organs, such as the Communist Youth League (共青团), which pushes propaganda to the younger generation, would convey the same approved message using CGI videos to boost nationalist sentiment, but the content itself is no more useful than reading the official news release. Overall, there is little added advantage of using the entertainment-based services for potentially useful open-source information.

Combining Sources

While Chinese video and social media platforms could assist OSINT research on China’s nuclear forces, researchers could also combine the visual element of weapon systems with textual data gathered from authoritative Chinese platforms like China Military Online (中国军网), PLA Procurement website (军队采购网), and Qi Cha Cha (企查查). The visual data can help identify many technical aspects of the PLA’s nuclear weapons, but the textual information can greatly inform the acquisition, production, and deployment of the weapon and support systems. Provinces with robust military and heavy industries, such as Heilongjiang, Liaoning, Shandong, and Shaanxi, sometimes release contracting and procurement information locally on provincial and municipal government websites. The information found on local government websites is admittedly sporadic, making broad, systematic collection difficult. Still, such information could serve as valuable first-hand sources for OSINT researchers. For more technical analysis of weapon systems, the China National Intellectual Property Administration (中国国家知识产权局) has a patent database that could be useful to track the development and ownership of certain enabling technologies for nuclear systems. This may be further enhanced by using the China National Knowledge Infrastructure (中国知网CNKI) to locate academic articles on the relevant technology, though access to CNKI articles usually requires an institutional subscription through a university library. Note that many of the Chinese government and military websites do not support a secure HTTPS connection. Some, like Qi Cha Cha, may require the user to access its content from a Chinese mainland IP address. Researchers should deploy cybersecurity tools to take full advantage of these resources.

Nicknames and Vernacular

In addition to the advantages and limitations of different social media platforms, researchers should be aware of the common nicknames and vernacular related to the Chinese nuclear force. Much like how the F-16 is commonly called “viper” instead of the official name “fighting falcon,” there are also nicknames for weapons and systems in the PLA. The table below summarizes several common terms and explains their meaning and primary usage.

Nickname/Vernacular	Direct Translation	Used by	Meaning
东风快递	“East Wind Express” or “DF Express”	Private citizens, but later adopted by the official PLARF Weibo Account and official state media	A common vernacular for any modern DF ballistic missiles, to include both nuclear and conventional missiles. The term is a reference to the express courier and takeout services in China, which are known for their timeliness and accuracy. A common usage of the term is “sending [a country] a DF Express”, which refers to delivering a fast and precise attack using a DF ballistic missile. While this could refer to any DF missile, the DF-17, DF-26, and DF-41 are the most common systems dubbed with this nickname due to their roles in a potential conflict with the United States.
关岛快递	“Guam Express”	Private citizens, some state-run media	Largely based on the same logic as the above, this term specifically refers to the DF-26 IRBM, which can range Guam.
真理	“The Truth”	Private citizens, but also used and discussed by official Chinese media	This usually refers to long-range nuclear weapons for strategic deterrence, but can also describe long-range conventional systems. The origin of reference is from the phrase “the truth is only within the range of the cannon,” which is possibly misattributed to Otto von Bismarck. The phrase is popularized in China by late Nankai University professor Ai Yuejin (艾跃进), who repeatedly gave lectures saying, “dignity only exists on the edge of the sword, and the truth is only within the range of the cannon 尊严只在剑锋之上, 真理只在大炮射程之内.” Additionally, the official Chinese commentary for the strategic missile forces during the 2019 military parade used the phrase “[we] insist on convincing others with the truth (坚持以真理说服人)” which further added to the term’s connection to a show of strength. Regardless of the origin, this highly realpolitik perception of international security resonates well among the Chinese people, leading many to dub nuclear ICBMs as “the truth” due to their long ranges and destructive power.
大国重器	“The Pillars of a Great Power”	Official state media	This term may refer to any strategic or critical technology that is not only vital to China’s national interests but also demonstrates China’s status and prestige as a great power. In the PLA context, this usually refers to missile systems that can give China a strategic advantage over its potential adversaries. Examples may include the dual-capable DF-26 and the nuclear ICBMs. Note that the same term is also used to describe China’s achievements in non-nuclear heavy industry. There is a state-sponsored documentary of the same name that traces the history of China’s heavy industry.
战略武器	“Strategic weapon”	Nonspecific	While this term is usually reserved for major nuclear deterrence systems in the U.S. context, it is used a lot more liberally in China. It may be used to describe any weapon that could gain China a decisive advantage in war, which could be a dual-capable missile like the DF-26 or an advanced conventional missile. In the 2015 military parade, the DF-21 ASBM was among the “strategic attack phalanx (战略打击方阵)”, though the missile was not known to be nuclear-capable.

A Note on Using AI Translation Services

There is little doubt that AI-enabled translation services like DeepL offer convenient and mostly accurate translations of Chinese texts. However, users should exercise caution when asking the AI to translate lengthy or complicated Chinese texts. Since the Chinese written language system is not space-delimited and often contains a mix of recently invented slang words, formal, and classical Chinese (文言文) phrases and quotes, the translation software sometimes cannot adjust properly to the context in which the classical phrases are used. This could easily lead to misinterpretation.For instance, translating and searching for the phrase “nuclear force (核力量)” may return results that contain the phrase “hardcore power (硬核力量)”, which is unrelated to nuclear weapons. In another example, a PLA Daily article uses the phrase “北约军费连增虚实几何” as the title, which mixes the classical grammar with modern Mandarin. DeepL would translate the word “几何” as “geometry” because it is the most used meaning in modern Mandarin, whereas the correct interpretation is “to what extent” or “by how much” in this context (Figure 4).

Figure 4. A screenshot of DeepL translation confused by classical Chinese grammar regarding context

In a similar instance, DeepL entirely fails to translate the part that contains classical grammar and offers an incorrect translation (Figure 5). This is most likely because the software treats the original Chinese phrase as a statement, whereas the classical grammar indicates a question.

Figure 5. Another example of DeepL translation confused by classical Chinese grammar and punctuation

Therefore, it is prudent to cross-reference and look up phrases individually when using AI-enabled translation tools. Inserting complete paragraphs is likely less accurate than looking up difficult phrases or individual vocabulary.

Conclusion

This paper  provides a preliminary guide on using Chinese social media and video platforms for nuclear-related open-source research by reviewing the usefulness and credibility of the content released by various official and privately owned platforms (Table 2). In sum, there is no singular most useful platform for information on the Chinese nuclear force, but some may help piece together interesting findings upon cautious review and cross-reference. While advanced Chinese language proficiency and cultural familiarity remain irreplaceable skills that can greatly enhance the accuracy and speed of open-source analysis, they are neither necessary nor sufficient for successful open-source analysis on China’s nuclear forces. Researchers can still make effective and efficient use of publicly available information by applying analytical due diligence and having context-specific awareness of Chinese sources.

Platform	Ownership	Great for	Limitations
Sina Weibo	Private	Prompt, official releases of the Chinese government and the PLA Evaluating the salience of nuclear issues in the Chinese community	Need to determine if official accounts are getting ahead of central guidance Official accounts may take down content arbitrarily Requires an account to use the search function and browse smoothly, though much content is available via direct search through a search engine.
CCTV.com	Government	High-definition footage of training exercises and test launches of nuclear-capable missiles Search function returns cross-platform results from government-run sources	Footage tends to be reused for different TV programs Some programs are meant for a foreign audience (e.g., CCTV-4), with a higher concentration of nationalist propaganda.
Bilibili	Private	Understanding how the Chinese nuclear force is viewed by young Chinese citizens	Excessive nationalist propaganda and content farming by private accounts The search bar is not always reliable for specific terms.
Douyin	Private	Limited understanding of how the Chinese nuclear force is viewed by the general Chinese population	Excessive nationalist propaganda and content farming by private accounts The search function often returns the most viewed but low-quality content Comprehensive censorship
Kuaishou	Private	Limited understanding of how the Chinese nuclear force is viewed by the general Chinese population	Excessive nationalist propaganda and content farming by private accounts The search function often returns the most viewed but low-quality content Comprehensive censorship

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This publication was made possible by a generous grant from the Carnegie Corporation of New York. The statements made and views expressed are solely the responsibility of the author.

The American power grid in 2025 faces a set of challenges unlike any in recent memory. The United States is deploying clean energy far too slowly to meet load growth, avoid spikes in electricity prices, and combat climate change. To get within striking distance of the Paris climate goals and plan for the lowest electricity costs, we must build 70 to 125 gigawatts of clean energy per year, much higher than the record 50 gigawatts built in 2024. 

Grid upgrades, too, are proceeding far too slowly. To meet growing electricity demand and integrate new clean power at lowest cost, transmission capacity must more than double within regions and increase more than four-fold between regions by 2035. But large transmission projects frequently take 7 to 15 years from initial planning to in-service operation and only 322 miles of new high-voltage transmission lines were completed in 2024—the third slowest year of new construction in the last 15 years.

Even before the One Big Beautiful Bill Act (OBBBA) gutted federal clean energy incentives, non-cost challenges like uncertain and lengthy interconnection and siting processes, local restrictions on development, and supply chain bottlenecks led to lower levels of clean energy deployment than projected and slowed down grid upgrades. Now, clean energy and transmission face additional cost and financing barriers from Congressional rollbacks and permitting restrictions from the Trump Administration.

Past federal and state clean energy policies, including the Inflation Reduction Act (IRA) and the Bipartisan Infrastructure Law (BIL) as well as state renewable portfolio standards, have leaned heavily on financial incentives to drive deployment and incentivize grid upgrades and expansion. These incentives successfully attracted massive investment in clean energy projects, but they largely did not grapple with non-cost challenges—like siting restrictions—to building projects.

Political challenges have made it difficult to pass, implement, and defend clean energy policies. A mismatch between public needs, government programs, and industry incentives has led to unsatisfactory outcomes and degraded public trust in the government. 

Now, policymakers, industry, and the advocacy community are paying more attention to non-financial issues that can impede deployment, like siting and permitting. The abundance movement, for example, has identified two causes of America’s building problem: ineffective government programs and burdensome permitting processes. This diagnosis is incomplete. Getting to a world where we can build things quickly and make government work will require us to identify the full suite of problems, not just these convenient two. 

To maximize clean energy deployment, we must address the project development barriers that slow down investment and construction. And to build more durable and effective energy policies, we must interrogate and address the political barriers that have held us back from smart policymaking and implementation that can withstand political change. Overcoming these challenges is necessary to address the climate crisis, rein in rising utility bills, and ensure that government can deliver on its energy promises to the public it serves. 

In early 2025, the Federation of American Scientists (FAS) set out to identify and categorize these barriers through research and interviews with experts and practitioners. Following this research, at the 2025 Climate Week NYC, FAS convened a group of researchers, advocates, industry leaders, and policymakers to solicit feedback on this framework. 

The outcome of that convening allowed us to ground-truth the following report—which we intend to use as a rubric for state-level electricity policies and efforts to rethink federal energy policy. We should ask: to what extent do new policies under consideration reduce the major barriers to building clean energy and transmission while addressing the shortcomings that have made past policy less durable? 

A future paper will detail the priority solutions that make progress on each of the project development barriers while improving our toolkit to overcome the political barriers that impede durable policy.

Contents

Project Development Barriers: Making it Harder to Build

Jump to chapter

Interconnection

Siting & Permitting

Misaligned Incentives

Financing

Grid Planning

Supply Chains

Political Barriers: Making it Harder to Pass, Implement, and Defend Policy

Jump to chapter

Energy Affordability

Incumbent Interests

Delayed Impact

Conclusion: What’s Next?

Jump to chapter

Project Development Barriers: Making it Harder to Build

Clean energy technologies are mature and cost competitive, if not least cost, across the country. Yet we are not building clean energy as fast as necessary, and in many places we are building new gas plants instead, raising costs for customers and intensifying the climate crisis. This trend is the result of several barriers that make it more difficult to build clean energy. 

Interconnection

The Barrier

The interconnection process is one of the most significant constraints on clean energy deployment in the United States. At the end of 2023, nearly 2,600 gigawatts (GW) of generation and storage were queued, which is more than double the U.S. installed capacity (~1,280 GW). Today’s grid was built around a small number of large, centralized fossil fuel plants; the grid must now accommodate thousands of diverse, geographically distributed projects. Processes that were designed for a handful of large plants per year are now evaluating orders of magnitude more proposals, each with more complex grid interactions. These processes are not able to adequately handle the current grid, nor have they kept pace with development in grid planning and analysis tools. The result is a massive backlog of projects waiting to interconnect to the grid and a review system that is fundamentally misaligned with the scale and pace of the energy transition. 

Developer experience confirms that interconnection challenges rank among the most decisive barriers to clean energy buildout. In the 2024 Lawrence Berkeley National Laboratory (LBNL) developer survey, respondents ranked interconnection delays and network upgrade costs higher than permitting, supply chain constraints, or workforce shortages as reasons for project cancellations or deferrals. Many projects face cost uncertainty on the order of tens to hundreds of millions of dollars as interconnection studies shift responsibility for broad system upgrades onto single developers. Interconnection costs are rising, and it is difficult for developers to predict what their interconnection bill will be at the end of the process. This unpredictability increases financing risk, reduces developer participation, and leads to large-scale attrition. 

Outdated processes for evaluating and approving new projects have led to enormous project delays, averaging 4-5 years from request to commercial operation. This delay has raised prices and led some grid operators to keep old, expensive coal plants online in lieu of new capacity. Both of these trends benefit incumbent transmission and generation companies, who have significant decision-making power over the entities that control interconnection, making it difficult to update the processes. Clean energy projects also face higher interconnection costs than gas projects because they are more likely to need transmission upgrades to connect to the grid, which increases the chances of project cancellation.

These barriers have direct system-wide consequences. Only about 15 to 20 percent of projects that enter the queue ultimately reach commercial operation, meaning most of the clean energy capacity counted as “planned” will not materialize unless interconnection processes are reformed.  Long queue timelines and uncertainty also make it more difficult to finance projects. The result is slower emissions reductions, delayed IRA-driven investment and job creation, and higher costs for consumers as operators extend the life of aging coal and gas resources to meet growing load. 

The Past Playbook

Federal interconnection policy has largely gone through the Federal Energy Regulatory Commission (FERC). In 2023, FERC issued Order 2023, which made significant changes intended to speed up interconnection and increase certainty for new projects. The rule (1) replaced outdated serial studies, in which operators study projects one by one as their applications come in, with cluster studies, in which operators study projects in batches, (2) required grid operators to speed up study timelines and imposed penalties for failing to meet deadlines, and (3) directed grid operators to update rules to reflect technological advancements, like grid-enhancing technologies and hybrid solar-plus-storage projects. Some grid operators have gone further than Order 2023 to improve interconnection processes, and some states have pushed grid operators for more ambitious reform. In addition to FERC rules, the federal government has also provided limited resources to grid operators to improve interconnection processes. 

To date, federal efforts have largely fallen short of what’s necessary to reform interconnection processes to enable adequate buildout of clean energy, and in most places states have limited tools. For one, FERC rules rely on effective implementation from grid operators, which has been a mixed bag. Order 2023 also strayed from making more fundamental changes to the interconnection process, like fixed entry fees that provide certainty to developers or proactive modeling and transparency of information to allow projects to connect quickly in places with transmission headroom. It fully does not address the fundamental problem that rising, variable interconnection costs are killing projects. The federal government has limited resources to support grid operators through, for example, funding for increased staffing or new technology to automate studies. 

Where Do We Go From Here?

The next era of energy policy must radically transform the way we connect projects to the grid to enable faster, greater deployment of clean energy, including through an expanded role for federal and state governments. Policy must shorten study timelines using automation and other new technology, enable smarter planning with proactive modeling and greater transparency for developers, increase upfront cost certainty, and reduce the amount that projects end up paying for interconnection. And in addition, the next playbook must address governance and decision-making structures that favor incumbents who benefit from a congested grid. 

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Siting & Permitting 

The Barrier

Siting and permitting processes have become two of the most visible friction points in the clean energy buildout. While federal policy receives the most attention, most clean energy siting and permitting decisions are made at the state and local level, where zoning boards, planning commissions, county supervisors, and community members have significant influence over whether a project proceeds. In many states, local jurisdictions have adopted new ordinances that restrict or outright ban wind, solar, and transmission development. According to recent analyses, roughly one-fifth of U.S. counties now have formal restrictions on clean energy, and many more are considering them. Even in states with strong climate and clean energy targets, municipal-level land use rules can effectively halt projects that align with statewide goals.

These local barriers are often rooted in concerns about landscape change, perceived impacts on property values, agricultural land use, wildlife, or community identity. But they are also a reflection of who benefits and who bears the immediate impacts of clean energy development. Benefits like lower system-wide electricity prices, cleaner air, and national decarbonization progress tend to be distributed widely, while the visual and land-use impacts are concentrated locally. Developers may not readily have the resources to meet community needs to come to agreement on projects, and federal and state governments often do not have adequate resources to support community benefits. Misinformation and disinformation—spread by incumbent interests who stand to lose money with greater clean energy or transmission deployment—also seed opposition in communities.

Permitting requirements add an additional layer of delay and uncertainty. Most clean energy projects, particularly solar and storage projects—which make up the bulk of new planned capacity—rarely trigger major federal environmental statutes and primarily deal with state-level permitting. Developers must navigate state statutes governing clean water, conservation, and environmental impacts, which serve important purposes but are often still implemented through outdated processes (e.g., many states still require paper permits; in Arizona, digitization reduced timelines for one permit process by 91 percent) administered by understaffed agencies. Projects such as transmission lines, offshore wind facilities, pumped storage hydropower, nuclear plants, geothermal projects, and any project on federal land or receiving federal grants generally must also navigate federal permitting processes. When new projects trigger federal review, they must comply with the National Environmental Policy Act (NEPA) and sometimes other federal permitting statutes, like the Marine Mammal Protection Act, the National Historic Preservation Act, and the Endangered Species Act. These reviews can take multiple years, particularly when agencies have limited staffing or when studies must coordinate across several state and federal entities and jurisdictions. 

Delays from local siting and state and federal permitting translate directly into cost escalation and canceled projects. Developers report that siting challenges can add years to development schedules and millions of dollars in carrying costs before a shovel ever hits the ground. For technologies like wind and solar, where the business model depends on tight capital cost margins, extended pre-construction periods can be the difference between a viable project and one that never breaks ground. Transmission development is even more exposed: large lines can spend a decade or more navigating route identification, landowner negotiations, environmental review, and litigation. Without new transmission capacity, interconnection backlogs grow, power costs increase, and states are forced to rely on older fossil resources simply because they are already in place.

Yet, the challenge isn’t so simple. It is not simply “local opposition” or “slow permitting.” It is that the scale of clean energy land use today is fundamentally different from the past century of centralized fossil energy development. We are building more projects, in more places, at a pace that communities have not previously experienced.

The Past Playbook

Siting and permitting reforms have increasingly been part of the federal and state policy agenda. Reforms have largely focused on process changes and improving coordination across agencies, with some focus on building capacity for analysis and review in some federal agencies and states. In general, these reforms are insufficient and not widespread enough to match the urgency and scale of the U.S. energy transition. 

The federal government has pursued a range of reforms over the past few years to improve the permitting process for projects that involve federal land, funding, or regulatory triggers. Key cross-agency initiatives include the Coordinated Interagency Transmission Authorizations and Permits Program, which made the Department of Energy (DOE) the lead agency for coordinating environmental review and permitting for transmission lines, and FAST-41, which aims to align multiple agency reviews and reduce duplicative permitting processes. Agencies have taken additional steps to improve individual permitting processes. For example, the Bureau of Land Management (BLM) designated solar and wind energy zones on public lands to reduce conflicts and expedite approvals, and the Bureau of Ocean Energy Management modernized offshore wind leasing and programmatic NEPA reviews (although the Trump Administration overhauled these reforms by halting all offshore wind leasing). 

Several states have attempted to reduce delays and uncertainty by centralizing siting authority and standardizing permitting rules. For example, New York’s Office of Renewable Siting and Massachusetts’ Energy Facilities Siting Board can override local opposition for large projects, while other states provide model ordinances to guide counties on setbacks, noise, and environmental protection. DOE has also helped states: the agency provided a small amount of technical assistance to states to help local governments with planning, siting, and permitting decisions and a larger tranche of funding for transmission projects to provide benefits to local communities to help with siting and community buy-in. In some places, these reforms have improved consistency across counties and reduced the influence of NIMBY-driven delays.

This playbook, while directionally correct, has fallen short of what is necessary. Local restrictions on clean energy continue to proliferate, siting power plants and large transmission lines remains a major challenge, and many state and federal permitting processes still pose significant barriers. Existing efforts have several gaps: (1) many states have not addressed local restrictions on development, (2) process improvements, especially at the state level, have happened in a piecemeal fashion and have not extended to the full suite of state-level permitting requirements, (3) existing efforts often do not cover the full set of solutions (e.g., broken permitting for customer-owned solar is a huge impediment that keeps U.S. solar costs much higher than other countries), (4) governments and developers have insufficient tools to ensure that local communities get what they want out of projects, and (5) efforts to increase state and federal government capacity (i.e., hiring and training the right staff and increasing analytical capabilities) have fallen far short of what is needed to have a fast, effective, and responsible permitting and siting process. 

Where Do We Go From Here?

The next era of energy policy must wrestle with the fundamental siting and permitting challenges and introduce new frameworks for planning, permitting, and building projects. That means upfront planning to make major decisions about tradeoffs between clean energy, water, conservation, and other goals, expanding the tools and resources necessary to ensure that local communities benefit from projects, dramatically improving government capacity to do siting and permitting well, and taking a holistic approach across federal, state, and local governments to prevent new bottlenecks from emerging. 

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Misaligned Incentives 

The Barrier

Most clean energy and grid upgrade projects are financed by private capital and procured or built by companies, either utilities or independent power producers. The profit motives of those financiers and companies determines the solutions they invest in, within the bounds of policy requirements. Across states and regions, outdated utility regulations and market designs have created flawed incentives that have limited investment in some necessary solutions and resulted in overinvestment in others. Utilities have wielded significant political power, built by lobbying with ratepayer money, to maintain today’s incentive structure. 

For example, in vertically integrated states, utilities are incentivized to prioritize capital expenditures that earn them the highest returns, within the bounds of commission approval. This incentive structure deprioritizes solutions like increasing imports of clean energy through new transmission and leveraging distributed resources like customer-owned solar. 

Most commissions are often not well-equipped or willing to ensure that utilities pursue the full toolkit. In most states, utility planning is driven by the utilities, who conduct detailed analysis and provide proposals on planning and ratemaking to their commissions. Commissions have more limited capacity to conduct analysis and interrogate utility proposals. 

Organized markets also have flawed incentive structures. For example, incentive structures in organized markets were generally designed around an electricity grid made up of a small number of large power plants. As a result, market rules and incentive structures provide limited to no support for distributed energy resources, which makes it harder to finance these projects. Governance structures exacerbate this issue. In some organized markets, incumbent generators have significant decision-making power in important determinants of clean energy deployment, including interconnection and transmission planning. Some organized markets have maintained rules that make it difficult to connect new power plants.

Misaligned incentives reduce the effectiveness of other policy solutions. For example, tax credits to reduce the cost of clean energy projects are most effective if utility companies have a profit incentive to build those projects instead of other generation types. The effectiveness of bulk transmission grant programs is limited by the willingness of utility companies to collaborate on projects. 

The Past Playbook

Federal policy has largely ignored utility incentive structures and instead attempted to influence private-sector behavior by working within existing incentive structures (e.g., by making it easier for utility companies to use tax credits to build clean energy). Federal agencies have attempted to overcome misaligned incentives through regulations (e.g., pollution standards on power plants that require generation owners to make changes). Some efforts to change incentives structures (e.g., the Clean Electricity Payment Program included in the 2021 Build Back Better Bill) have gained momentum but failed to pass. 

Many states have also used tools that operate within existing incentive structures, like renewable portfolio standards that require utilities to procure an increasing share of their electricity from clean sources. States have attempted to change incentive structures to varying extents. More than 15 states have adopted some form of performance-based ratemaking to align utility incentives with desired outcomes. However, these efforts vary in how comprehensively they have changed the dominant incentives for companies. 

Where Do We Go From Here?

The next era of energy policy must reform incentives to realign private sector interests with public benefit, including affordable bills, reliability, and decarbonization. To achieve the scale, speed, and depth of transformation needed to address the challenges facing our grid, policy must address misaligned incentives for distribution utilities, generation owners, and integrated utilities in different regulatory contexts. That requires a greater focus on realigning incentive structures at the state and regional level (through organized market reform) as well as creative federal tools to directly change incentives or help states and organized markets to do so. Increasing regulator scrutiny of utilities and bolstering capacity at commissions must also play a larger role moving forward to ensure that utilities are focusing on the best solutions, not just what is most profitable. Greater use of publicly owned or publicly financed projects can also ensure investment in solutions that are underutilized by private companies. 

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Financing

The Barrier

The federal government has created new financial barriers for clean energy projects.  OBBBA’s changes to tax incentives and increased regulatory and permitting uncertainty make clean energy projects more expensive and harder to finance. Macroeconomic changes like persistent inflation and other uncertainty, including on tariffs and interest rates, have also affected investment. 

While the clean energy industry has continued to move forward (2025 investment in solar, storage, and wind is similar to 2024 levels, and the industry is benefiting from demand growth, as many projects are able to find offtakers like tech companies willing to pay higher prices), the full effects of federal policy changes are likely delayed, as the tax credits have not fully expired. Moving forward, financing may become a larger barrier. In addition, rising utility bills have opened a conversation about the cost of private finance for grid projects and whether there are alternative approaches that come with lower costs for customers. 

Financing less mature clean energy technologies, like advanced nuclear, enhanced geothermal, and aggregated distributed generation (i.e., virtual power plants), remains a major issue. 

The Past Playbook

Financial support has played a dominant role in the federal energy policy playbook. Tax incentives, which were dramatically expanded by the IRA and pared down by OBBBA, have been central to energy policy for decades. Grant and loan programs, also dramatically expanded by the IRA, have also been a core driver of clean energy deployment, grid upgrades, and large-scale demonstrations and commercialization of advanced energy technologies. States have also used tax incentives, grant programs, and green banks to finance and incentivize clean energy and grid projects. This model has largely been successful at deploying mature technologies like wind, solar, and storage, but it has fallen short when it comes to commercializing some newer clean energy technologies. Gaps also remain in financial support for projects that struggle to get private capital.  

Where Do We Go From Here?

Financing and financial support should continue to be a major pillar of clean energy policy. The next era must incorporate a broader, more diverse set of financing tools in the capital stack, including state-led public financing for more types of projects and state efforts to create demand certainty for clean energy by leveraging procurement and working with corporate buyers. 

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Grid Planning

The Barrier

Today, the U.S. bulk transmission system faces significant constraints that limit where new clean energy projects can be built and threaten reliability. Congestion already causes curtailment of low-cost low-carbon power, higher consumer electricity prices, and dampened investment in clean energy. Many regions with abundant clean energy resources simply do not have enough high-voltage transmission capacity to deliver that power to population centers. As a result, developers are increasingly unable to move generation projects forward even when siting, permitting, financing, and interconnection queue positions are in place. 

These challenges stem in large part from fragmented and inadequate planning processes. Coordinated planning is essential to ensure that transmission is expanded in the right places and that new clean energy investments flow to areas with sufficient transmission capacity. Despite the need for coordination, the United States conducts virtually no interregional transmission planning, and regional planning has been lacking in many regions. The result is piecemeal grid planning, as transmission providers and developers focus on smaller lines which meet near-term needs and are profitable within their own footprint. Planning for these smaller lines is easier as fewer parties are involved. Where we have successfully built larger regional lines, they are the result of transmission providers conducting robust planning processes. And because no unified authority or planning framework exists to shepherd large, high-impact projects across regions, the U.S. has built essentially zero major interregional transmission lines in recent history.

Lack of coordination between transmission and generation planning also creates inefficiencies and prevents smart development. In deregulated markets (and some vertically integrated states), transmission and generation planning processes occur largely in isolation without systematic processes to align long-term clean energy expansion with major grid upgrades. 

Together, these gaps make expanding the transmission system an inefficient process at best, and an unworkable process at worst, at precisely the moment when the need for additional capacity is growing most rapidly. 

The Past Playbook

Policymakers have made progress in addressing transmission planning bottlenecks, but these reforms remain far short of what’s needed. FERC Order 1920 is the most significant recent step: it requires long-term, forward-looking, multi-value regional planning. It was designed to improve transparency in the planning stages and help regions identify beneficial projects earlier. Yet the rule stops at regional borders and thereby doesn’t meaningfully advance interregional planning. 

A patchwork of state and regional efforts has emerged alongside federal reforms. New Mexico created a new entity called the Renewable Energy Transmission Authority to map and finance new lines. Similarly, Colorado created the Colorado Electric Transmission Authority to plan and develop transmission lines to meet power needs, unlock clean energy, and lower costs. California conducts long-term transmission planning intended to incorporate transmission needs to accommodate clean energy deployment required to meet the state’s climate goals. Federal tools like National Interest Electric Transmission Corridors (NIETCs) were designed to accelerate siting of critically important lines, and part of DOE’s Grid Resilience and Innovation Partnerships (GRIP) funding has helped bring utilities, states, and developers together to plan large projects. On the interregional front, DOE has conducted analysis to demonstrate where new capacity would create the greatest benefits and inform planning.

These efforts certainly make progress and will likely result in expansion of local and regional transmission capacity. The magnitude of progress will depend in large part on how transmission providers implement Order 1920—for most regions, compliance filings will be submitted this month (December 2025) or by June 2026. 

However, this playbook had significant gaps and pitfalls. Lack of interregional planning is the most glaring gap, but other tools had limitations, too. GRIP had limited funding and power to solve cost allocation disputes. NIETCs did not translate into built infrastructure. In many places transmission planning will not take into account the long-term clean energy expansion required for deep decarbonization, leaving high-value opportunities—like pairing wind resources with long-distance transmission—unrealized. The result is a set of reforms that move in the right direction but still fall short. 

Where Do We Go From Here?

The next era of energy policy must tackle interregional planning, while following through on Order 1920 with effective implementation. We must require transmission providers to plan decisively for futures with significant load growth and levels of clean energy deployment necessary for deep decarbonization. Future federal policy must also expand the government’s tools to bring parties to the table for smart, effective planning. In parallel, states should continue to use creative policies, like Colorado and New Mexico’s transmission authorities, to strategically plan new transmission lines to maximize benefits. And the next era must also include national, forward-looking land-use planning for clean energy deployment, in sync with transmission planning. 

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Supply Chains

The Barrier

Grid components, such as electrical steel and transformers, are necessary to increase grid capacity to support additional generation and load. However, grid component supply chains are still suffering from disruptions caused by the COVID-19 pandemic and lack of domestic manufacturing capacity. The rising demand for grid components and battery technology have further stressed supply chains, drawing out lead times and increasing prices. For example, across transmission and distribution equipment, the lead time for components averaged 38 weeks in 2023, nearly double from the year prior, with costs escalating nearly 30 percent year-over-year. Bottlenecks in the supply chains from upstream suppliers to manufacturers among these components risk power system stability, the ability to deploy clean energy, and the ability to build new industrial production and technology facilities at scale. 

The Past Playbook

Federal policy has increasingly focused on building secure supply chains for clean energy technologies. The IRA included tax credits, grant programs, and loan authority to build out domestic supply chains for clean energy and storage technologies. The federal government has also used demand-side pressure to bolster supply chains (e.g., through a bonus tax incentive for clean energy projects that use domestic content and Build America Buy America requirements on federal grant programs). These policies led to major investment in domestic supply chains. 

This playbook was quite successful at building out domestic supply chains for some industries, but it had major gaps. For example, the IRA and BIL included no dedicated support for grid components, and the minimal support that was embedded in larger programs was insufficient. Federal demand-side programs were structured as incentives for downstream industries to use domestic content, but this design had too much uncertainty to sufficiently derisk upstream domestic supply chains.  

Today’s programs have also struggled to respond quickly when conditions change. For example, the federal government had limited tools with which to respond when the utility industry faced a debilitating shortage of large power transformers or when it became clear that incentives were not large enough to drive domestic investment for some clean energy components. 

Where Do We Go From Here?

The next era of energy policy must build on the same financial tools to support secure supply chains that enable clean energy deployment and grid upgrades. The playbook must include policies that more directly create demand for domestic components to provide certainty for manufacturers and derisk new investments. Future policy must also provide more flexible and dynamic tools to rapidly address supply chain shortages as they arise. 

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Political Barriers: Making it Harder to Pass, Implement, and Defend Policy

Clean energy advocates have focused on economic competitiveness, climate, and public health benefits as the winning messages to support and defend policies. The BIL and IRA came out of this model, and the architects of those policies hoped that the industry that benefitted from these policies would step up to defend them. While this strategy has enabled passage of significant new policies, it has failed to withstand changing political dynamics. The swift rollback of major parts of BIL and IRA is the prime example. Our ability to successfully implement and defend clean energy policies—and make further progress—has been hampered by several key political barriers. The next era of clean energy policy must address these barriers to be successful. 

Energy Affordability

The Barrier

Rapidly rising utility bills have become an urgent cost-of-living issue. People pay 13 percent more for electricity in 2025 than they did in 2022, and nearly 40 percent of households sometimes have to choose between paying for food and medicine or keeping the lights on. 

Rising electricity prices are a political barrier to some clean energy policies. For example, states have struggled to follow through on procurement of advanced clean energy technologies like nuclear and offshore wind as prices have risen. New York recently cancelled a planned transmission line, using affordability as a justification. Clean energy opponents are using prices to oppose climate policies, even though deployment of wind and solar has generally reduced rates. Concerns about electricity affordability make it difficult to justify major grid infrastructure investments under current regulatory and ratemaking structures, as additional spending to update the grid will lead to near-term bill increases. High prices also make it difficult to replace direct fossil fuel use in vehicles, buildings, and factories with electricity. 

The Past Playbook

Federal energy policy has largely dealt with affordability in two ways. 

First, the federal government has provided important but limited direct assistance to struggling households through the Low-Income Home Energy Assistance Program, which helps households pay for energy, and the Weatherization Assistance Program, which funds energy- and cost-saving home improvements. However, these programs are significantly underfunded and oversubscribed—many households that need support do not get it.

Second, federal financial support results in long-term savings. IRA incentives for low-cost clean energy were projected to reduce generation costs, which in the long term translates to lower prices. Tax incentives and grant programs for distributed energy resources and home energy improvements save energy and costs for customers that make upgrades. However, this approach falls short in two ways: (1) it does not address the root causes of rising electricity bills, which means bills will continue to rise, and (2) the benefits are long term and do not show up on peoples’ bills on politically relevant timelines. 

Where Do We Go From Here?

The next era of energy policy must provide sufficient and swift relief for customers that are on the edge of catastrophe due to rising costs, make it easier to deploy cheap, clean energy to reduce generation costs, and target the root causes of high and rising bills to unlock a sustainable utility ratemaking regime that allows for major new investments in the grid without harming regular people. The new playbook must also include more effective cross-sector tools to cut total system and household costs, including by transferring planned spending on gas infrastructure to home electrification and grid upgrades where possible. 

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Incumbent Interests

The Barrier

Many solutions, including adding new generation in organized markets, relying more on regional and interregional transmission, and deploying distributed and demand-side solutions, threaten the profits of incumbent interests under current market and regulatory structures. For example, utilities make money through a return on qualified capital investments in things like power plants and distribution infrastructure. Increasing bulk transmission capacity to connect the Southeast with other regions would lead to more imports of lower cost clean energy, which would reduce the utilities’ reliance on local generation. That makes it harder for the utilities to justify capital expenditures in new power plants, which is how the utilities make a profit, so new transmission poses a threat to the business model. As a result, Southeastern utilities are opposed to policies that would expand bulk transmission to better connect different regions, even though these policies would reduce costs and increase reliability. These dynamics make it politically difficult to pursue policies that expand transmission capacity.

The Past Playbook

Federal clean energy policy has largely avoided changing incumbent incentive structures or decision-making processes at the state and regional level. Instead, policymakers have used financial incentives to bring incumbents to the table and increase their investment in clean energy and grid upgrades. As a result, the misaligned incentives described above, combined with decision-making structures that reward incumbents over innovation, make it difficult to fully address the barriers to clean energy deployment and grid upgrades at the necessary scale. 

Where Do We Go From Here?

The next era of clean energy policy must address governance issues through reform of regional grid operators and public utility commissions. Strengthening the role of regulators is critical to reining in incumbent interests where they do not align with public benefit. It must also realign industry incentives (e.g., through performance-based ratemaking) where possible with affordability and decarbonization goals. 

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Delayed Impact

The Barrier

Another major political barrier is the lengthy time it takes to get from enactment and implementation to tangible benefits for people. Transforming major sectors of the economy is a time-intensive, multi-stage project, and climate advocates have accordingly focused on long-term goals, such as 100 percent clean electricity by 2035 or net-zero emissions by 2050. The IRA and BIL were made up primarily of multi-year (even some decadal) programs to drive major changes in the economy. As a result, the largest benefits were projected to come in the late 2020s and early 2030s, far outside the window of political memory. That mismatch makes it difficult for the public to understand the point of policies and in turn makes those policies hard to defend. 

Where policies do have near-term benefits, those benefits have often been delayed by the implementation process. Successfully shifting the private sector requires precise policy and new programs, which take time to implement. Implementation of new programs can also run up against the government typically works, and that friction causes delays. Implementation delays make it difficult to connect the dots between policy and tangible improvements to peoples’ lives.

The Past Playbook

Policymakers have used three dominant approaches to overcoming this barrier. First, they tout near-term signs of economic change. For example, the Biden administration consistently cited private-sector investment in clean energy as a key metric to convince the public that the IRA and BIL were driving benefits for people. Second, they rely on the quickest economic changes to demonstrate impact. For example, the IRA and BIL drove a near-term increase in construction jobs. Real and announced job creation was the dominant message to support and defend these policies. Third, they cite projected benefits. For example, the Biden administration frequently cited the 1.5 million jobs and the $27 to $33 billion in energy cost savings that the IRA was projected to drive. 

Attention to long-term impact is important for addressing long-term problems like climate change and load growth. However, politics runs on instant gratification. As of late 2024, only 39 percent of Americans had heard of the IRA. And federal energy policy failed to make a near-term dent in the issue that was most visible for people: utility bills. 

Where Do We Go From Here?

The next era of clean energy policy must tangibly and visibly benefit people in the short term. The playbook must include a better balance of policies geared toward long-term transformation of the economy and policies focused on pressing issues for regular people. That means including programs that are designed for quick implementation and real-world change. 

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Conclusion: What’s Next?

The power sector sits at an inflection point. The challenges facing the grid are immediate, interconnected, and solvable but only if we confront the real sources of delay and dysfunction. Accelerating clean energy deployment requires moving beyond our old playbook—dominated by financial incentives and regulations that see-saw based on the political winds—toward a new approach that addresses both project development barriers that slow investment and construction and political barriers that impede durable policymaking. Building durable, effective energy policy demands a clear-eyed assessment of the barriers that have undermined smart policymaking and implementation.

In a forthcoming publication, we will move from diagnosis to action, detailing policy solutions that can unlock faster, more reliable project development while expanding the policy toolkit needed to overcome the political barriers that have prevented durable reform. Together, these solutions aim to strengthen grid reliability, rein in rising utility bills, and put the United States back on a credible path to decarbonization. These stakes could not be higher, and the opportunity to build a more affordable, resilient, and clean energy system has never been more urgent. 

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What goes on in the mind of an analyst during satellite imagery analysis? Four broad steps included in this report – establishing context, collecting imagery, analyzing imagery, and drawing conclusions – serve as a simple outline for analysts interested in assessing satellite imagery with a particular focus on the nuclear field. This report uses China’s CFR-600 reactor site as a case study, providing a roadmap to the analytical thought processes behind the analysis of satellite imagery.

This report was adapted into an ArcGIS StoryMap, an interactive multimedia narrative. Click here to view the StoryMap.

The Trump administration has scrapped over $8 billion (so far) in grants for dozens of massive clean energy projects in the United States. For those of us who worked on the frontlines of Bipartisan Infrastructure Law (BIL) and Inflation Reduction Act (IRA) implementation, the near-weekly announcements and headlines have been maddening, especially at a time when many of these projects would have helped address soaring electricity prices and surging demand growth.

While some of these cancellations were probably illegal, they nevertheless raise fundamental questions for clean energy advocates: why was so much money still unspent…and why was it so easy to cancel?

In a new report, we begin to address these fundamental implementation questions based on discussions with over 80 individuals – from senior political staff to individual project managers – involved in the execution of major clean energy programs through the Department of Energy (DOE). 

Their answer? There is significant opportunity – as our colleagues at FAS have written – for future Executive branch implementation to move much faster and produce much more durable results. But to do so, future implementation efforts must look drastically different from the past, with a ruthless focus on speed, outcomes, and the full use of Executive Branch authorities to more quickly get steel in the ground.

The risk of risk aversion

Take the grant cancellations example. The Trump administration has relied on one small clause in the Code of Federal Regulations (2CFR 200.340(a)(4)) as the legal basis for its widespread cancellations. This clause, traditionally included in most grants between the government and a private company, allows the government to cancel any grant that “no longer effectuates the program goals or agency priorities” and essentially functions as a “termination for convenience” clause.

But including this “termination for convenience” clause was optional. DOE could have leveraged a different, more flexible contracting authority for many awards. It also could have processed what’s known as a “deviation” in order to exclude the clause from standard contracts. Leaders of program offices were aware of these options, with some staffers strenuously objecting to the inclusion of termination for convenience.

But in the end, DOE offices generally opted to keep this clause because it was the way the agency had always executed (primarily R&D) grants in the past, and because sticking to established procedures was seen as the best way to avoid the risk of Congressional or Inspector General oversight. 

And yet, this risk-averse approach perversely increased the risk of project failure, by creating an easy kill switch for an administration looking for grounds on which to cancel particular projects.

This attitude toward risk – which saw defaulting to the status quo as the most prudent path – was a constant barrier to effective implementation. (In addition to opening up grants to cancellation, the embrace of 2CFR 200 regulations meaningfully slowed negotiations as companies bristled at the obscure accounting and other compliance measures the regulations would impose on them.)

Understanding this culture of risk aversion offers two takeaways for improving government: (1) rigorously question status quo decisions and avoid defaulting to agency precedent and (2) avoid excessive focus on eliminating every risk or avoiding external backlash or oversight (especially given that backlash and oversight are likely regardless of the approach.) 

Speed is paramount

Of course, excluding the termination for convenience clause would not have been a panacea. It’s likely the Trump administration would have devised some other pretext for cancelling the grants that may have been just as successful, though perhaps legally shakier.

That’s why implementers also told us that speed is critical. The best defense is a strong offense. And the best way to prevent money from being taken back is to have already spent it on promising projects. The federal government has moved faster in implementation of large policies before. During the New Deal, the Tennessee Valley Authority moved from passage of its founding law to beginning construction on a major dam in just four months. Operation Warp Speed delivered cutting-edge life-saving vaccines to millions of Americans in about a year. While the contexts and goals of these programs were different, we know from history that the federal government can move fast.

But at DOE, only 5% of the funds appropriated through the Bipartisan Infrastructure Law had actually been spent (not just obligated) by the time the Biden administration ended three years later. In addition to making clean energy projects more vulnerable to subsequent cancellations, the pace of the rollout meant that the basic political hypothesis animating clean energy legislation—that the economic development projects brought, especially to red states, would create a durable bipartisan coalition for clean energy—went untested.

Practically everyone we spoke with expressed frustration at the slow pace of implementation. Interviewees highlighted many challenges associated with a relatively slow pace of BIL and IRA implementation, such as:

• “Too many cooks” dynamics at every level of implementation.
• A lack of coalitional policy prioritization. 
• Overcomplicated award processes.
• Regulatory compliance issues that were at odds with industry realities. (Davis-Bacon, NEPA, Build America Buy America, and the Paperwork Reduction Act were those most frequently mentioned.)

The work begins now

One commonality between these and other issues identified in our report is encouraging: they are mostly within the Executive Branch’s power to solve. A sufficiently prepared future administration could address many of these challenges for future federal clean energy efforts without relying on the vagaries of the legislative process. But the work must begin now. 

On contracting, for instance, a future administration’s DOE could make better use of Other Transactions Authority for clean energy. But it should be prepared with drafts of the basic commercial terms of agreements between the government and companies it works with. Similarly, a proactive future administration will come in with a clear view on how to streamline compliance with environmental, prevailing wage, domestic sourcing, and other cross-cutting requirements. On decision-making, a future administration can set norms pushing decision-making to the lowest possible level, clarify processes to elevate and execute major issues, and establish small, clear, and empowered teams that own frontline negotiations. 

If pursued, this updated approach to federal clean energy implementation will look drastically different. But one way or another it will have to: the next time there is a federal government interested in accelerating clean energy, it is likely to be dealing with a private sector much more wary of working with the government, fiscal constraints that limit the likely scale of any clean energy funding, and a dramatically altered federal workforce and state apparatus.

Much can be done outside of the federal government — including at state and local levels — to prepare for those circumstances. It is possible for a future federal administration to achieve faster and more durable clean energy outcomes. But to make that possible, the work must begin now. 

It’s not enough to say we need to make full use of DOE’s authorities; we need the drafted Secretarial directives and advance legal legwork to do it, and leadership well-equipped with the details and government-insider knowledge to execute on it. 

It’s not enough to say we want more nuclear, transmission, or critical minerals projects; we need to have identified the priority projects and designed the strategies and programs needed to actually put them in motion on Day 1. 

It’s not enough to say we should take a “whole-of-government” approach to an issue like clean energy; we need a detailed plan for how to use the $5 billion/year in electricity purchases and the PMA’s 45,000 miles of transmission lines—all under the direct control of the federal government—to achieve explicit policy outcomes. 

And it’s not enough to say we need to rebuild the federal workforce; we need a roster of hundreds of people that can be brought on and trained rapidly to implement within weeks.

To live up to the spirit of the New Deal and Operation Warp Speed—the spirit that turned ambitious goals into massive real-world impact in a matter of months—the next administration must come armed not only with broad aspirations, but also with the detailed plans required to implement them.

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The 2010 New START Treaty, the last bilateral agreement limiting deployments of U.S. and Russian strategic arsenals, will expire in February 2026 with no option for renewal. This will usher in an era of unconstrained nuclear competition for the first time since 1972, allowing the United States and Russia to upload hundreds of additional warheads onto their deployed arsenals if they made a political decision to do so. The removal of both the verifiable limits on nuclear weapons, as well as the agreed and proven mechanisms of information sharing about each country’s nuclear arsenal, will increase mistrust, lead to nuclear military planning based on worst case scenarios, and potentially accelerate a global nuclear arms race amid a worsening geopolitical environment.

Traditional nuclear arms control, including New START, relies on the availability of on-site inspections to verify compliance. However, Russia has suspended its participation in New START and opposes intrusive inspections, while political conditions make negotiating an equally robust successor treaty improbable in the near term. 

The proposal: verifiable nuclear arms control without on-site inspections

This report outlines a framework relying on “Cooperative Technical Means” (CTM) for effective arms control verification based on remote sensing, avoiding on-site inspections but maintaining a level of transparency that allows for immediate detection of changes in nuclear posture or a significant build-up above agreed limits. This approach builds on Cold War precedents—particularly SALT II, which relied largely on national technical means (NTM)—while leveraging modern Earth-observation satellites whose capabilities have significantly advanced in recent years.

The proposed interim agreement would:

• Preserve New START’s central limits on launchers and warheads.
• Resume notifications and  data exchanges.
• Uphold the principle of non-interference with national technical means of verification.
• Incorporate a set of cooperative measures to expose systems for satellite verification, making possible remote monitoring and counting of nuclear delivery vehicles and nuclear weapons.

Such a regime could either be a formal, legally-binding treaty or an informal political arrangement. A non-binding arrangement may also encourage the participation of other nuclear states willing to freeze the production and deployment of new nuclear weapons, including China, the United Kingdom, France, India, and Pakistan. 

How would it work?

Significant increases in both the quality and quantity of state-owned and commercial observation satellites now allow global monitoring of missile silo fields, weapons storage sites, air bases, and ports at high resolutions, in different bands, and at actionable frequencies of observation. These developments make it possible to:

• Count strategic launchers. Missile silos, mobile launchers garrisoned in bases, submarines in ports, and heavy bombers at air bases are all observable by electro-optical and synthetic aperture radar (SAR) sensors. Large-scale silo construction is now nearly impossible to conceal.
• Assess deployment status. Cooperative measures—such as opening silo doors for satellite passes—could verify whether launchers contain missiles. AI-assisted SAR and EO imagery could detect, classify and count nuclear bombers. Unique markings or alphanumeric codes placed on mobile launchers and bombers could facilitate counting and identification from space.
• Estimate deployed warheads. New START counts every nuclear bomber as carrying a single warhead. A similar counting rule could be established for other delivery vehicles. Otherwise, exposing missiles’ re-entry vehicles (RV) during coordinated satellite overpasses could allow for the counting of warheads remotely. While this could not confirm if the displayed RVs are nuclear or decoys, it would set verifiable upper limits.
• Address non-strategic and non-deployed weapons. Novel SAR observation techniques can help detect undisclosed activity and traffic around storage facilities, ensuring weapons are not secretly moved in or out.

Why this matters

Arms control is a crucial tool for managing nuclear risks. The proposed remote-sensing verification regime could help maintain transparency, facilitate communication, and provide predictability between the United States and Russia beyond 2026, reducing the danger of nuclear arms racing without needing to tackle the politically sensitive issue of on-site inspections.

No past or present arms control regime is perfect and completely safe against cheating. An agreement fully relying on observation satellites would not fully eliminate uncertainty, but it would be relatively easier to negotiate than one with on-site inspections, and it would increasingly raise the costs of deception, providing visibility into major nuclear developments and leaving a pathway to more comprehensive arms control once it becomes politically viable in the future.

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For the last two years, experts from the Federation of American Scientists and Nagasaki University have engaged with American, Japanese and South Korean experts as well as partners with valuable insights on nuclear policies in China and Russia to assess the risks of nuclear use and escalation in Northeast Asia.  The results of this work are sobering, but not surprising.  The growing reliance on nuclear weapons and growing geo-political tensions in the region are a recipe for nuclear disaster.  Only purposeful and coordinated actions among countries that seek to avoid war and the use of nuclear weapons can reverse these trends and address these dangers.  If current trends and dynamics continue, the risk of nuclear use will continue to increase.

Our consultations included commissioned working papers from U.S., Japanese and South Korean authors, as well as experts on China and Russia to assess the role nuclear weapons play in the security policies of those countries, and how each country views the prospect of war and nuclear risk.  Two workshops, one in Seoul and one in Tokyo, were convened by our organizations over the last year and a half.  These events included discussions both before and after the U.S. election, and before and after the declaration of martial law in South Korea. The papers and discussions led to a recently published special feature on “The Future of Nuclear Stability in East Asia” of Journal for Peace and Nuclear Disarmament ( J-PAND) . 

As the lead researchers for this project, we have developed the following assessments and believe pursuing a set of concrete and deliberate recommendations are essential if Governments seek to reduce the risks of nuclear conflict through accident or miscalculation.  The authors do not assume that such steps will change the broader geo-strategic realities in the region. However, these steps, if integrated into government action, offer the prospect of constructive collaboration among states where such efforts are scarce. Furthermore, it remains possible that, once engaged on an issue of mutual self-preservation, the momentum can be created for other cooperative efforts.

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Reducing Nuclear Risks and Salience

Unless the policies and activities of all nuclear-armed states and their allies change in East Asia, the probability of a nuclear crisis will continue to grow.  This reality should be alarming to all states in the region, as all will suffer should the region (or the world) witness the use of nuclear weapons in combat or even during peacetime as tools for coercion.  What is needed is both a recognition of the dynamics driving the potential for crisis by national leaders, coupled with deliberate actions to reduce the risks of accident, escalation, and, where possible, reliance on nuclear weapons for anything other than core nuclear deterrence.  Even then, the risks of accidents due to human behavior and complex systems should lead any responsible country to establish in advance a set of mechanisms for communicating to avoid misperception or mistakes when a crisis emerges, which inevitably will.

Of course, not all analysts see these dynamics the same way.  The dominant view in the United States is that America’s nuclear capabilities are both essential and highly valuable in both deterring and assuring, and the more reliable and credible these capabilities are, the more stable will be U.S. alliances, and the region as a whole.  However, if one considers multiple national perspectives as well as the risks of both accident and miscalculation, there are clear consequences for increasing nuclear salience and enhancing reliance on nuclear weapons that should lead to a deeper examination of alternatives and steps to mitigate those risks.  At a minimum, recognizing that the risk of nuclear acquisition, signaling, and use in the region are increasing must lead to closer examination of ways to reduce the risks of accidental or unintended conflict, and to find ways to separate broader U.S. reliance on nuclear weapons from the possible decision by more states in the region to acquire nuclear weapons of their own. 

Of course, as long as nuclear weapons exist, there will be an inherent risk that they will be used, and indeed multiple nations continue to rely on nuclear deterrence as a basis for their security.  However, there should be no tolerance for accepting unnecessary nuclear risks associated with accidents and miscalculation.  Moreover, while all states seek to project their ability to use and manage escalation to their own benefit, there needs to be greater work invested to understanding escalation dynamics among all states in the region and time spent avoiding the risk of uncontrolled or runaway escalation pressures.

In its simplest form, the world and the nations of the region need to recognize that they are part of a multipolar nuclear vortex of potential conflict among four states with nuclear weapons, and two others advanced conventionally-armed states who could trigger (intentionally or otherwise) a conflict with global dimensions.  The risks of conflict in the region are as grave as they have ever been, and concerted, reasoned and multi-faceted efforts to manage the nuclear risks inherent in the region are required.

Just as states in the region have different perspectives about what enhances or reduces stability, states also have different interests when it comes to measures perceived to enhance stability and predictability.  Eager to maintain the regional security status quo, the United States has sought for many years to promote a set of dialogues and norms to reduce the risks of conflict and accident.  However, not content with the status quo, in which the United States maintains broad sway and can project military power in the region, China has resisted crisis management or risk reduction efforts. U.S. officials have proposed repeatedly to establish a set of guard rails on escalation, to which Chinese officials have remarks that such protections may only encourage the U.S. to continue reckless behavior.

Nevertheless, all states regardless of history and intent need to be attentive to the region’s growing nuclear dangers.  Russia, China, and the United States have adopted a common position that a nuclear war cannot be won and must never be fought.  North Korea, which is not recognized formally as a nuclear-weapon state under the NPT, has not issued any similar statements.  However, the consequences of any nuclear use in the region would be extreme and must be avoided at all costs.  

Steps that could be pursued to that end are discussed below.  These include working to reinforce the norm of non-nuclear use, as well as development of tangible mechanisms that can be used in a crisis to communicate and potentially avoid unwanted or accidental escalation.

Political and Diplomatic Steps

Nuclear Leadership

Leaders in the participant countries, and mainly in those with nuclear weapons, need to invest the time and effort to better understand the magnitude of the nuclear risks they manifest, and to communicate with each other at the direct, personal level that they understand those realities.  In all of the affected countries, the military services and organizations that support nuclear missions tend to take on a momentum of their own in service of providing their leadership with options for military victory and possible nuclear use. That is their job, yet their actions also can place pressures on leaders whose interests are necessarily broader.  Demonstrating at a high political level that those authorized to use and provide options for the use of nuclear weapons understand the risks and consequences involved is an essential step in reducing nuclear dangers.  The temptation to bluff, project indifference, or adopt “mad man” postures must be conclusively rejected by all states in the region.

Allied/Conventional Leadership

Japan and South Korea, as the non-nuclear states in the region – as well as Taiwan – should continue to take and expand efforts to encourage constructive engagement and risk reduction measures so that leaders of China, the United States, Russia and North Korea recognize the new nuclear age the world has entered.  The lessons that led the leaders of the Soviet Union and United States to end the last global nuclear arms race appear to have been forgotten or lost, a form of collective amnesia about the virtues of cooperative approaches to tempering risks. America’s non-nuclear allies can stimulate broader engagement including through academic, Track II, civil society, economic and other forms of indirect, non-governmental engagement. These channels may not produce immediate results, but should be pursued as they are low risk approaches that can be valuable in expanding consultations, increasing the flow of information, and identifying opportunities for governmental engagement.   Through intermediaries, regional groupings, and other bi- and multilateral settings, the non-nuclear weapon states endangered by the nuclear dynamics in East Asia need to increase their efforts to build and support risk reduction dialogues, or avenues for those discussions among the nuclear states.  

Intra-alliance Discussions

In today’s environment, it is both important and appropriate for U.S. allies to be vocal in encouraging the United States to remain an active security provider and a conduit for constructive dialogues in the region. However, U.S. allies should also speak out and engage their counterparts in Washington when and if they believe it will be harder for them to continue strong security cooperation with the United States if Washington is not actively seeking to reduce the risks of escalation to the nuclear level in a conflict with other regional powers.  There is no region where U.S. allies can expect to reap security benefits of a nuclear alliance with Washington without risk.  Yet it remains impossible to predict how increased nuclear risks might influence political dynamics in U.S. allies such as South Korea and Japan.  This dynamic should be an open part of expanding extended deterrence and security discussions among the U.S. and its security partners.

Within the U.S. extended deterrent relationships with South Korea and Japan, as well as its partnership with Taiwan, there also needs to be a more fulsome and mature discussion about the balance between deterrence and defense, and risks of nuclear escalation.  The U.S. relationships with Japan and South Korea especially over the last decades has matured to the point that Tokyo and Seoul take an active role in understanding, assessing, characterizing, and planning detailed responses to specific threat scenarios.  This coordination benefits all of the states, but should also include active discussions about conventional-nuclear weapon dynamics, including the risks of accidents and escalation within and beyond the nuclear level, and develop more robust tools for preventing and controlling such escalation, and avoiding miscommunication and accidents.  It is unknown, and perhaps unknowable in advance of a conflict, whether the United States will act on its defense commitments in a conflict.  However, with increased doubts about U.S. commitments comes the risk both that U.S. allies will seek to expand their own capabilities, drawing a reaction from China and North Korea (while allies’ actions are already reactions to their actions), and furthering the action-reaction cycle that defines arms race instability.  Of course, there is also the omnipresent concern that China or North Korea will miscalculate, may assume they can act with impunity, and then find the U.S. ready, willing and able to meet its defense commitments.  In short, the region is going to be more unstable and U.S. allies have a direct interest in ensuring not only that they are prepared to face a possible attack, but that they and the United States invest the time and effort now to avoid a conflict should one start by accident or through miscalculation, or escalate beyond the conventional level.

One of the most positive developments for security and deterrence in East Asia over the last few years has been the improved coordination and tempering of political animus between Japan and South Korea, owing in part to the active encouragement of the United States.  It is no overstatement that the United States cannot hope to create a stable deterrent relationship with China if it is unable to work with two like-minded partners in Japan and South Korea, not least if those two countries cannot work together toward a common goal of stability and conflict avoidance.  To be sure, Seoul and Tokyo have different threat concerns and priorities.  But the ability to deter conflict, project strength and coordination, and act quickly and decisively to terminate a conflict and avoid escalation comes through enhanced and durable political and military coordination and collaboration among the United States and its allies in the region.  A thickening of US-ROK-Japan as a trilateral security partnership is among the best options those states have to preserve peace and stability in East Asia.

Technical Tools

It remains an open question whether geopolitical tension in the region have led to arms racing or whether arms racing has led to geopolitical tensions.  The growth of conflict and tension in the region is a long history and regardless of whether one believes weapons drive conflict or conflict drives weapons, the dynamics in the region are clear for all to see.  It is possible that no amount of dialogue, engagement, and risk reduction efforts will disrupt these dynamics.  The history of humanity is, in many ways, the history of warfare.  However, that history is also loaded with episodes of unwanted and unnecessary conflicts that were detrimental to all involved.  As technology improves, countries and other groups will have tools to reduce the risks of accidents and miscommunication, as well as unintended escalation.  To be effective, these tools need to be in place before any conflict begins.  Examples include:

Crisis communication tools

The public often considers telephone hotlines as the standard tool for communicating with leaders in a crisis. However, it is not widely known that the United States and Soviet Union, and later Russia, put in place a basic but more capable computer-based system that did not rely on voice communications between leaders to pass messages, but established an open computer display in each capital to ensure that no matter the contingency, messages could be sent and read without any action by the receiving side. In fact, the nuclear risk reduction centers remain in place and in use between Washington and Moscow to this day. The ability to send a message without having to wait for the other side to “pick up the phone” has proved to have important political and technical advantages over more simple telecommunications.

No similar system (except for some bilateral mechanisms that require the other side to respond) exists anywhere in East Asia between the United States or any of the countries in the region. The establishment of risk reduction communication centers in all of the capitals, or simply establishing them between bilateral pairs, is one way to create mechanisms before a crisis strikes to help resolve misunderstandings or miscommunications. While it is entirely possible that a message sent will not be reciprocated or well received, there is little to any cost to establishing such a system. Indeed, even the absence of a response can be important information that aids decision making.

The United States and Russia could offer to expand their current system to include other countries, share and demonstrate the technology that they use for consideration by China, South Korea, Japan, and North Korea, or pairs of states could establish similar networks on their own. One way to facilitate this process might also be for a civil society group, such as National Academies of Science or other equivalent academic centers to establish test networks that could be used and demonstrated over a period of months for national military and leaderships in the individual countries to observe the system in use before they commit to them as a political decision.

Incident Agreements

The United States and the Soviet Union worked over the course of the Cold War to establish norms of behavior and then create operational tools for their militaries to communicate at the operational level to manage accidents.  These were largely successful both in providing tools to manage crises and signaling that both sides had an interest in avoiding unintended or unwanted conflicts. Despite efforts to create similar systems and tools in East Asia, agreements or tools that have been put in place (such as 1998 US-China Military Maritime Consultative Agreement as well as 2018 Maritime and Aerial Communication Mechanism between the Japan-China Defense Authorities and 2023 Hotline between Japanese and Chinese Defense Authorities) to manage potential incidents among the relevant armed forces (naval and air forces being the main focus with China, and ground forces being a major concern on the Korean Peninsula) are far from enough. They should first make these existing mechanisms effective and useful and then expand them to establish norms of behavior and create operational communication tools.

Not all states in the region support the establishment of such mechanisms, but they are a potentially useful tool that willing states should look to establish and promote.  Demonstrating responsible behavior and signaling a concern about the direction of regional security are both valuable opportunities for leaders, and despite some concerns would have no tangible effect on the ability to both deter and prepare for a potential clash of forces.  There have been multiple studies done on best practices for such systems including how to establish pre-existing norms of behavior, conduits for communication, and how states should behave if an accident or unplanned clash among forces takes place.  These efforts should continue and be enhanced.  Where possible U.S., ROK and Japanese approach for intra-alliance/partner behavior and products  should be published and promoted as standards that could form the basis for broadening of such efforts to include China and North Korea, as well as Russia.

Build and Use Open-Source Networks

The space revolution has provided governments and independent analysts with a stunning set of tools that previously were inaccessible to all but intelligence agencies in a handful of developed countries.  Now, the availability of commercial observation satellites and low-cost drones create potential tools for states in the region to monitor each other’s military behaviors, anticipate potential moves that undermine the security of another, and have detailed information that can be used as part of risk reduction or crisis management processes.  Obviously, not all countries in East Asia are pleased with the newfound transparency that can be imposed from outside of their own borders, but this technology will only continue to expand and provide potential tools for others in the region. This will at once reduce the likelihood of military surprises, yet at the same time, the growth of information manipulation technologies, including artificial intelligence, will mean that not everything a country can see is necessarily the truth. This balance between information and mis- or disinformation is a particular challenge in the 21^st-century that should concern all states in the region, even though that might seek to use mis- and disinformation to their own advantage.

One concept that should be further developed and promoted is the creation of open-source information fusion cells, involving relevant experts from all of the countries involved in East Asian security dynamics. Having a single location with participants from the various countries who can assess, analyze, and even discuss data being provided by open-source capabilities could be a powerful tool in developing a common framework for discussing a crisis, should one take place.  It is unlikely given the current political dynamics that all of the countries in the region will soon agree to establish such a center, thus an interim step might be to establish a trial open-source operation through academic or non-governmental civil society organization that could be accessed by countries in the region by invitation.

Build on what is working

One of the simplest tools for avoiding miscalculation utilized by the United States and the Soviet Union/Russia has been advance notification of ballistic missile test launches.  More recently, the United States and China have engaged in apparently reciprocal advance notifications of recent ICBMs tests.  This basic step can avoid the risk that a simple test launch might occur at a time of tension and catch any state off guard.  Efforts should be made by the United States and China to encourage other states in the region, including North Korea, to follow this standard model to encourage responsible behavior, if not moderation. 

Other Steps by the United States, and Allies and Partners 

These above steps, whether used in bilateral or multilateral settings, could improve the ability of states to avoid a crisis or manage one should it take place.  However, there are other steps 

that can be pursued by the United States and its friends and allies in the region that can also improve the outlook for avoiding unwanted or unnecessary nuclear risks.

Broaden routine deterrence and assurance dialogues among the United States and its allies and partners in both bilateral and multilateral formats. Existing dialogues and committees have been useful political tools for improving transparency within bilateral alliances, improving trilateral engagement, and finding ways to enhance military reassurance and deterrence.  However, these discussions often overlook other important areas of interdependence among the United States, Japan, and South Korea—and how their cooperation in these areas contributes to the security and prosperity of all three countries.  In addition to continuing and deepening these discussions, to include regular engagement on what specific threats they seek to deter and how to do so without taking unnecessary nuclear risks, the countries should also look to engage on economic, technical, cultural, and human exchange dynamics to deepen the anchors for these alliances and partnerships that form the basis for their security in the region.

Expand trilateral communication and coordination mechanisms among the United States, Japan and ROK. Japanese and ROK officials in particular need to put forward a very clear demand signal to the United States that they value the trilateral process consolidated during the Biden administration and would welcome efforts to expand the scope of their engagement. These dialogues should seek to adopt a heavier emphasis on crisis, coordination and scenario planning, to include both escalation and de-escalation scenarios, as well as to conduct exercises around unexpected or surprise events.

Consider tighter regional missile defense architectures. Missile defense is becoming an increasingly important element of deterrence by denial in the region. It is increasingly clear that effective missile defenses can play a significant role in deterring adversaries and reassuring allies. In this regard, developing tighter regional missile defense architectures should be considered. If coordinating and implementing regional missile defense architectures among the United States, South Korea, Japan, and Taiwan proves successful, it could have an important politically stabilizing effect by linking them together and reinforcing their relationships in the face of potential political challenges. However, several important issues must be kept in mind when considering regional cooperation on missile defenses, for example, concerns that such cooperation could further stimulate investment in ballistic missile capabilities by North Korea, China, and Russia (although they are already expanding their capabilities regardless), as well as rising costs of missile defense systems. Advancing cooperation between Japan and South Korea still remains politically fragile, posing a challenge to regional cooperation. Furthermore, if Taiwan is to be included in such a regional architecture, China will certainly react harshly both politically and militarily. While the delicate and complex nature of regional relations must be carefully weighed, developing tighter regional missile defense architectures is worth considering.

Promote broader dialogue on the utility and risks of reliance on nuclear deterrence. Nuclear weapons are clearly an important component of strategic deterrence, but they are not a panacea and because of their immense destructive power they should always and only be an option of last resort.  This tone needs to be routinely re-injected into alliance discussion to avoid over-reliance on nuclear options and to ensure that nuclear reliance does not become an adversary to prudent and more stabilizing conventional investments for both deterrence and combat.  Additional discussions should be pursued to determine when and how it would be possible to reduce or even eliminate the role for nuclear weapons in some contingencies in favor of conventional options that may increase the efficacy of conventional deterrence and escalation management.

Engage adversaries, in close consultation with allies, even if the prospects for progress are limited.  Its willingness to break with conventional wisdom and engage adversaries is one area where the current American administration may have a distinct advantage over its predecessors.  President Trump has demonstrated that he does not feel constrained in talking with U.S. adversaries, and is willing and even eager to engage with the leadership of foreign countries with historically adversarial or difficult relations with the United States. This high-level engagement provides an opportunity to breakthrough bureaucratic hurdles and achieve terrific strides, if effectively planned and managed.  President Trump could choose to reengage North Korea, has even after launching military strikes against Iran offered to pursue diplomacy with Tehran, and is reportedly eager to negotiate and engage directly with China’s president.  If any of these dialogues are pursued, then important crisis management and avoidance tools should be brought into these high-level dialogues by the United States.  In particular, as it was pointed out in the article of the J-PAND’s special issue  on “Nuclear Weapons and China’s National Security: Consistency, Evolvement and Risk Management”, there may be great value in establishing procedures for risk reduction that focus on the timeliness of the tools as well as standardization and maintenance activities to ensure that these tools are operable when needed.  At the same time while more complicated, it may be possible for the leaders of these countries or their designated technical teams to work on identifying potential flashpoints and reach task agreements on how the two sides can identify and possibly avoid what are seen as provocative actions.  It remains to be seen whether or not China or North Korea are interested in pursuing such high-level high stakes diplomacy, and if they do whether they will be open to areas that have traditionally been excluded from past dialogues. However, if in this new environment, China and North Korea are able to recognize the risks of nuclear escalation and agree that all states in the region would be better off reducing the risk of accidental or unintended nuclear use, then there are tools that all three countries, in close consultations with Japan and South Korea, could pursue to achieve those ends.

Conclusion

None of the steps including above alone or collectively will eliminate the risks of conflict among the multiple nuclear and nuclear dependent states in Northeast Asia.  The economic, political and security stakes and dynamics indicate that the region will remain one influenced by tension and increasing military risk until there are fundamental changes in the region, including the nature of leadership in multiple countries, or until there is a collective understanding about the benefits to be gained through political and security engagement and broader integration.  While those changes seem unlikely, history is filled with examples where previously insurmountable changes were achieved through unexpected developments.

That being said Northeast Asia looks to occupy in the 21^st century the same space Europe occupied the 20^th century as a potential flashpoint for military and political tensions among great powers and their partner states.  The fact that multiple countries possess nuclear weapons and are dependent on them ultimately for their security, makes the risks of accident, miscalculation, or escalation much more dangerous than the Cold War period. It will take consistent leadership and action to navigate the complex dangers in the region and to avoid what many analysts considered to be an increasingly possible outcome, a nuclear conflict in East Asia.

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Since 2020, China has dramatically expanded its nuclear arsenal. That year, the Pentagon estimated China’s stockpile of warheads in the low 200s and projected that it would “at least double in size.”¹ Two years later, the report warned that China would “likely field a stockpile of about 1500 warheads by its 2035 timeline.”² Both inside and outside government, the finding has transformed discourse on U.S. nuclear weapons policy.

Adm. Charles Richard, while Commander of U.S. Strategic Command, warned that changes in China’s nuclear forces would fundamentally alter how the United States practices strategic deterrence. In 2021, Richard told the Senate Armed Services Committee that “for the first time in history, the nation is facing two nuclear-capable, strategic peer adversaries at the same time.”³ In his view, China is pursuing “explosive growth and modernization of its nuclear and conventional forces” that will provide “the capability to execute any plausible nuclear employment strategy.”⁴ In Richard’s view, the United States is facing a “crisis” of deterrence that will require major shifts in U.S. nuclear strategy.⁵ “We’re rewriting deterrence theory,” he told an audience.⁶ For Richard, the danger is not just that the United States would face two separate major power, nuclear-armed adversaries but two nuclear peers that can coordinate their actions or act to exploit opportunities created by the other.

How the United States responds to China’s nuclear buildup will shape the global nuclear balance for the rest of the century. For many observers, the “two nuclear peer problem” presents an existential choice because existing U.S. nuclear force structure and strategy cannot maintain deterrence against two nuclear peers simultaneously. There are only three options: expand the capability of U.S. nuclear force structure; shift nuclear strategy to engage nonmilitary targets;⁷ or do nothing, which increases the risk of regional aggression and nuclear use.

Despite this growing wave of concern and commentary, there has been no systematic studies that define the nature of the “two nuclear peer problem” and the options available to the United States and its allies for responding to China’s nuclear buildup. An informed decision about how to respond to China’s buildup will depend on answering two additional questions.

First, what exactly is the threat posed by China’s expanding nuclear forces? What is a “two nuclear peer problem” and will the United States face one in the next decade? Specifically, will China’s nuclear buildup render U.S. nuclear forces incapable of attaining critical objectives for deterring nuclear attacks.

Second, what are the best options for responding to China’s expanding nuclear forces? What are the available options to modify U.S. nuclear force structure given existing constraints and will these options effectively correct vulnerabilities created by a “two nuclear peer problem?” Would these options create new risks to the interests of the United States and its allies? 

In the following chapters, we each consider a central aspect of the “two nuclear peer problem” and the options available to meet it. Though we have tried to coordinate our chapters so they do not overlap, and build on assumptions and data regarding U.S. and Chinese nuclear forces, each chapter is the work of a single author. We do not present a consensus perspective or set of recommendations and do not necessarily endorse the arguments made in neighboring chapters.

In chapter 2, Adam Mount surveys expert analysis and the statements of government officials to develop a more rigorous definition of the “two nuclear peer problem” than currently exists in the literature. Characterizing and categorizing the risks posed by a tripolar system leads to an unappreciated possibility: there is no “two nuclear peer problem” in the way that the problem is commonly presented. As it stands today, the prominent and influential discourse on the “two nuclear peer problem” does not clearly or accurately characterize the risks posed by China’s expanding nuclear forces, nor the range of options available to U.S. officials to respond. The need to deter two nuclear adversaries does not necessarily create a qualitatively new problem for U.S. strategic deterrence posture.

Subsequent chapters evaluate important pieces of the “two nuclear peer problem” in detail. In chapter 3, Hans Kristensen presents new estimates of U.S. and Chinese force structure to 2035. He provides correctives against excessive estimates of China’s current and future capability and argues it should not properly be considered a nuclear peer of the United States.

The final chapters consider two plausible ways that a tripolar system could present a qualitatively new threat to U.S. deterrence credibility. In chapter 4, Pranay Vaddi considers how China’s buildup will affect U.S. nuclear strategy. He surveys how U.S. planning has historically approached China and evaluates multiple courses of action for how the United States might adapt. In chapter 5, John Warden examines the prospects for Sino-Russian cooperation in peacetime, in crisis, in conventional conflict, and in a nuclear conflict. He argues that it is not only the material facts of China’s buildup that will drive U.S. planning, but the expectations and risk acceptance of U.S. officials with respect to Sino-Russian coordination and U.S. extended deterrence commitments. 

The authors are grateful to Carnegie Corporation of New York for their generous funding of the project, as well as innumerable colleagues, academics, and government officials for informative discussions. The authors each write in an independent capacity. Their chapters do not reflect the positions of any organization or government.