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.

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.

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.

The president of the United States is the only person in the country who can order the use of nuclear weapons, a power commonly known as “sole authority.” This power is granted to the president largely through policy tradition, but the president’s Constitutional role as Commander-in-Chief is often cited as the legal basis. Sole authority was first codified in 1948 when the National Security Council (NSC) adopted the conclusions of NSC-30, which read: “The decision as to the employment of atomic weapons in the event of war is to be made by the Chief Executive when he considers such decision to be required.” The policy has since been reaffirmed in numerous official documents, including, most recently, the Department of Defense’s 2024 Report to Congress on the Nuclear Employment Strategy of the United States, which states, “the Guidance reaffirms that the President remains the sole authority to direct U.S. nuclear employment.”

Despite its foundational place in U.S. nuclear policy, sole authority has for years come under heavy scrutiny by experts, journalists, and American citizens. Experts publish pieces warning of the dangers of such a system, people take to social media to remind their networks that “this is the guy with the nuclear codes” whenever the president acts in a concerning manner, and lawmakers even introduce legislation to try to constrain the president’s authority. Recent polling by the Chicago Council on Global Affairs and Carnegie Corporation of New York found that 61% of Americans are either somewhat or very uncomfortable with the president having sole authority over nuclear launch decisions.

Sole authority appears like a dangerous toy in the hands of unstable, unreliable, or erratic presidents. President Bill Clinton reportedly lost his nuclear authorization codes for months during his presidency. Jimmy Carter rumoredly sent his codes to the dry cleaners in the pocket of his suit jacket. Following the assassination attempt against Ronald Reagan in 1981, Reagan was separated from his military aide, and all of his clothes, including the pants in which the card carrying his nuclear codes sat, were stripped in the hospital and thrown away. His codes were later recovered by the FBI from a hospital trash can. Further, the mental and intellectual reliability of presidents has been questioned, with Reagan’s formal Alzheimer’s diagnosis coming just five years after he left office, John F. Kennedy’s known use of strong pain medications, Richard Nixon’s heavy drinking and erratic behavior leading up to his resignation, and Donald Trump’s history of making flippant remarks and threats of nuclear use, to name a few. 

Other concerns with presidential sole authority include the immense time and psychological pressure placed on presidents in crisis scenarios that hinders rational thinking, the challenge to democratic values posed by a system that places ultimate power in one individual’s hands, the ethical and legal burden placed on lower level military officials, and more. But before we can attempt to solve the broad “problem” of sole authority, a more thorough understanding of it is needed. 

This report investigates how we arrived at this system of launch authority in the United States today. It traces the origins of sole authority to the earliest days of the nuclear age and follows the history of trial and error — with new procedures and systems added or abandoned as vulnerabilities were detected and new technology emerged — culminating in an assumption that we have arrived today at the optimal system for nuclear launch authority. This report interrogates that assumption first by providing an in-depth understanding of how the policy of sole authority works today and how the nuclear enterprise in the United States is set up to enable it, then by evaluating the risks and vulnerabilities that remain. Finally, the report analyzes the merits and drawbacks of policy proposals that have been put forward by experts and lawmakers to answer a crucial question: is sole authority solvable, or is it truly the best system possible for nuclear launch authority? If the latter, should we accept that reality?

Every region in the U.S. is experiencing year after year of record-breaking heat. More households now require home cooling solutions to maintain safe and liveable indoor temperatures. Over the last two decades, U.S. consumers and the private sector have leaned heavily into purchasing and marketing conventional air conditioning (AC) systems, such as central air conditioning, window units and portable ACs, to cool down overheating homes. 

While AC can offer immediate relief, the rapid scaling of AC has created dangerous vulnerabilities: rising energy bills are straining people’s wallets and increasing utility debt, while surging electricity demand increases reliance on high-polluting power infrastructure and mounts pressure on an aging power grid increasingly prone to blackouts. There is also an increasing risk of elevated demand for electricity during a heat wave, overloading the grid and triggering prolonged blackouts, causing whole regions to lose their sole cooling strategy. This disruption could escalate into a public health emergency as homes and people overheat, leading to hundreds of deaths. 

What Americans need to be prepared for more extreme temperatures is a resilient cooling strategy. Resilient cooling is an approach that works across three interdependent systems — buildings, communities, and the electric grid — to affordably maintain safe indoor temperatures during extreme heat events and reduce power outage risks. 

This toolkit introduces a set of Policy Principles for Resilient Cooling and outlines a set of actionable policy options and levers for state and local governments to foster broader access to resilient cooling technologies and strategies. For example, states are the primary regulators of public utility commissions, architects of energy and building codes, and distributors of federal and state taxpayer dollars. Local governments are responsible for implementing building standards and zoning codes, enforcing housing and health codes, and operating public housing and retrofit programs that directly shape access to cooling. 

The Policy Principles for Resilient Cooling for a robust resilient cooling strategy are:

• Expand Cooling Access and Affordability. Ensuring that everyone can affordably access cooling will reduce the population-wide risk of heat-related illness and death in communities and the resulting strain on healthcare systems. Targeted financial support tools — such as subsidies, rebates, and incentives — can reduce both upfront and ongoing costs of cooling technologies, thereby lowering barriers and enabling broader adoption. 
• Incorporate Public Health Outcomes as a Driver of Resilience. Indoor heat exposure and heat-driven factors that reduce indoor air quality — such as pollutant accumulation and mold-promoting humidity  — are health risks. Policymakers should embed heat-related health risks into building codes, energy standards, and guidelines for energy system planning, including establishing minimum indoor temperature and air quality requirements, integrating health considerations into energy system planning standards, and investing in multi-solving community system interventions like green infrastructure.
• Advance Sustainability Across the Cooling Lifecycle. Rising demand for air conditioning is intensifying the problem it aims to solve by increasing electricity consumption, prolonging reliance on high-polluting power plants, and leaking refrigerants that release powerful greenhouse gases. Policymakers can adopt codes and standards that reduce reliance on high-emission energy sources and promote low-global warming potential (GWP) refrigerants and passive cooling strategies.
• Promote Solutions for Grid Resilience. The U.S. electric grid is struggling to keep up with rising demand for electricity, creating potential risks to communities’ cooling systems. Policymakers can proactively identify potential vulnerabilities in energy systems’ ability to sustain safe indoor temperatures. Demand-side management strategies, distributed energy resources, and grid-enhancing technologies can prepare the electric grid for increased energy demand and ensure its reliability during extreme heat events.
• Build a Skilled Workforce for Resilient Cooling. Resilient cooling provides an opportunity to create pathways to good-paying jobs, reduce critical workforce gaps, and bolster the broader economy. Investing in a workforce that can design, install, and maintain resilient cooling systems can strengthen local economies, ensure preparedness for all kinds of risks to the system, and bolster American innovation.

By adopting a resilient cooling strategy, state and local policymakers can address today’s overlapping energy, health, and affordability crises, advance American-made innovation, and ensure their communities are prepared for the hotter decades ahead.

In 1942, the United States formally began the Manhattan Project, which led to the production, testing, and use of nuclear weapons. In August 1945, the United States dropped two nuclear weapons on Japanese cities, killing around 200,000 people by the end of 1945 and leaving survivors with cancer, leukemia and other illnesses caused by radiation exposure. While this was their only use in wartime, states have detonated nuclear weapons many times since for testing purposes, producing radioactive fallout. Many U.S. nuclear weapons production activities, including the mining of uranium and testing of the weapons themselves, have occurred outside of the continental United States. Notably, explosive testing in the Pacific islands and ocean spread radioactive fallout to Marshallese, Japanese, and Gilbertese people, forcibly displacing entire communities and producing intergenerational illnesses. 

Much of the scholarship surrounding the effects of nuclear weapons on environmental and human health is framed within a potential detonation scenario. For example, studies have shown that even a regional nuclear war would cause millions of immediate deaths and trigger a “nuclear winter,” a shift in the climate that would disrupt agricultural production, thus killing hundreds of millions more through starvation. Additionally, in 2024, the United Nations General Assembly voted to create an independent scientific panel to study the health, environmental and economic consequences of nuclear war. While such research is crucial for understanding the consequences of nuclear weapons use, nuclear weapons are built, maintained, and deployed everyday, impacting communities at every stage even before detonation. Studying only the predictive futures of the use of a nuclear weapon in war is insufficient in understanding nuclear weapons’ holistic humanitarian impact. According to former Secretary of Defense Lloyd J. Austin III, “The heart of American deterrence is the people who protect us and our allies. Here at STRATCOM, you proudly stand up—day in and day out and around the clock—to defend us from catastrophe and to build a safer and more peaceful future. So let us always ensure that the most dangerous weapons ever produced by human science are managed with the greatest responsibility ever produced by human government.” Nuclear deterrence theory contends that a retaliatory nuclear strike is so threatening that an adversary will not attack in the first place. Thus, nuclear advocates often suggest that these weapons protect American citizens and the U.S. homeland. This report demonstrates, however, that the creation and sustainment of the nuclear deterrent harms members of the American public. As the United States continues nuclear modernization on all legs of its nuclear triad through the creation of new variants of warheads, missiles, and delivery platforms, examining the effects of nuclear weapons production on the public is ever more pressing.

‘Framework for a Heat-Ready Nation’ puts heat emergencies on the same footing as other natural disasters, reimagines how governments respond

Washington, D.C. – July 22, 2025 – Shattered heat records, heat domes, and prolonged heat waves cause thousands of deaths and hundreds of billions of dollars in lost productivity, damages, and economic disruptions. In 2023 alone, at least 2,300 people died from extreme heat, and true mortality could be greater than 10,000 annually. Workplaces are seeing $100 billion in lost productivity each year. Increased wear and tear on aging roads, bridges, and rail is increasing maintenance costs, with road maintenance costs expected to balloon to $26 billion annually by 2040. Extreme heat also puts roughly two-thirds of the country at risk of a blackout.

Extreme heat events that were uncommon in many places are becoming routine and longer lasting – and communities across the United States remain highly vulnerable.

To help prepare, the Federation of American Scientists has drawn upon experts from Sunbelt states to identify decisive actions to save lives during extreme heat events and prepare for longer heat seasons. The Framework for a Heat-Ready Nation, released today, calls for local, state, territory, Tribal, and federal governments to collaborate with community organizations, private sector partners and research institutions.

“The cost of inaction is not merely economic; it is measured in preventable illness, deaths and diminished livelihoods,” the report authors say. “Governments can no longer afford to treat extreme heat as business as usual or a peripheral concern.”

The Framework for a Heat-Ready Nation focuses on five measures to protect people, their livelihoods, and their communities:

1. Establish leaders with responsibility and authority to address extreme heat. Leaders must coordinate actions across all relevant agencies and with non-governmental partners. 
   
2. Accurately assess extreme heat and its impacts in real time. Use the data to inform thresholds that trigger emergency response protocols, safeguards, and pathways to financial assistance.
   
3. Prepare for extreme heat as an acute emergency as well as a chronic risk. Local governments should consider developing heat-response plans and integrating extreme temperatures into their long-term capital planning and resilience planning.
   
4. When extreme heat thresholds are crossed, local, state, territory, Tribal and federal governments should activate response plans and consider emergency declarations. There should be a transparent and widely understood process for emergency responses to extreme heat that focus on protecting lives and livelihoods and safeguarding critical infrastructure.
   
5. Develop strategies to plan for and finance long-term extreme heat impact reduction. Subnational governments can incentivize or require risk-reduction measures like heat-smart building codes and land-use planning, and state, territory, Tribal and federal governments can dedicate funding to support local investments in long-term preparedness. 

Extreme heat in the Sunbelt region of the United States is a harbinger of what’s coming for the rest of the country. But the Sunbelt is also advancing solutions. In April 2025, representatives from states, cities, and regions across the U.S. Interstate 10 corridor from California to Florida, convened in Jacksonville, Florida for the Ten Across Sunbelt Cities Extreme Heat Exercise. Attendees worked to understand the available levers for government heat response, discussed their current efforts on extreme heat, and identified gaps that hinder both immediate response and long-term planning for future extreme heat events. 

Through an analysis of efforts to date in the Sunbelt, gaps in capabilities, and identified opportunities, and analysis of previous calls to action around extreme heat, the Federation of American Scientists developed the Framework for a Heat-Ready Nation. 

The report was produced with technical support from the Ten Across initiative associated with Arizona State University, and funding from the Natural Resources Defense Council.

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About FAS

The Federation of American Scientists (FAS) works to advance progress on a broad suite of contemporary issues where science, technology, and innovation policy can deliver transformative impact, and seeks to ensure that scientific and technical expertise have a seat at the policymaking table. Established in 1945 by scientists in response to the atomic bomb, FAS continues to bring scientific rigor and analysis to address national challenges. More information about FAS work at fas.org.

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

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

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

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

Key Findings & Recommendations

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

Federal Level Key Findings & Recommendations

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

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

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

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

Extend & Clarify Incentives

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

• Congress should amend the 45Z tax credit structure to differentiate between fuel types, such as SAF, e-fuels, biofuels, and renewable diesel, based on life cycle CI and production pathways. This would better reflect technology-specific costs and accelerate deployment across multiple clean fuel markets, adding specificity as to how to utilize and earn the credits based on the type of fuel. 
• Congress should extend the duration of the 45Z credit and other clean-fuel related incentives to provide long-term policy certainty. Multi-year extensions with a defined minimum value floor would reduce investment risk and enable financing of capital-intensive projects.
• Congress and the Department of Treasury should clarify eligibility to ensure inclusion of co-processing methods and hybrid production systems, which are currently in regulatory gray areas. This would ensure broader participation by innovative fuel producers.
• Federal agencies, including the Department of Energy (DOE), Department of Transportation (DOT), and the Department of Defense, should be directed to enter into long-term (more than 10 years) procurement agreements for low-carbon fuels, including electrofuels and SAF. These offtake mechanisms would complement tax incentives and send strong market signals to producers and investors.

Scale Biotech Commercialization Support

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

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

• Authorize and appropriate expanded funding to the DOE, particularly through Bioenergy Technologies Office (BETO) and to the Department of Agriculture (USDA) to support pilot, demonstration, and first-of-a-kind commercial scale projects that enable biotechnology applications across clean energy sectors.
• Direct and fund the DOE Loan Programs Office to establish a dedicated loan guarantee program focused on biotechnology commercialization, targeting platforms that can be integrated into the energy system, such as bio-based fuels, bioproducts, carbon utilization technologies, and electrification-enabling materials.
• Encourage DOE and USDA to enter into long-term offtake agreements or structured purchasing mechanisms with qualified bioenergy and biomanufacturing companies. These agreements would help de-risk early commercial projects, crowd in private investment, and provide market certainty during the critical scale-up phase. 
• Strengthen public-private coordination mechanisms, such as cross-sector working groups or interagency task forces, to align commercialization support with industry needs, improve program targeting, and reduce time-to-market for promising technologies. 

Design and Promote Next-Gen Biofuel Policies

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

• Congress should direct the Environmental Protection Agency (EPA) to modernize the Renewable Fuel Standard by incorporating life cycle carbon intensity as a core metric, moving beyond volume-based mandates. Legislative authority could also support the development of a national Low Carbon Fuel Standard, modeled on successful state-level programs to drive demand for fuels with demonstrable climate benefits.
• EPA should update its emissions accounting framework to reflect the latest science on life cycle greenhouse gas (GHG) emissions, enabling more accurate assessment of advanced biofuels and synthetic fuels. 
• DOE should expand R&D and demonstration funding for biofuel pathways that meet stringent carbon performance thresholds, with an emphasis on scalability and compatibility.

Regional Level Key Findings & Recommendations

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

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

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

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

Strengthen Regional Workforce Pipelines

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

• Federal agencies like the Department of Education and National Science Foundation should explore expanding support for STEM programs at community colleges and Minority Serving Institutions, with a focus on biosciences, engineering, and agricultural technologies relevant to the clean energy transition.
• Federally supported training and reskilling programs tailored to regional clean energy and biomanufacturing workforce needs could benefit new and existing cross-sector partnerships between state workforce agencies and regional employers. 
• State and local governments should consider implementing talent retention strategies, including local hiring incentives, relocation support, and career placement services, to ensure that skilled workers remain in and contribute to regional clean energy ecosystems.

Strengthen Regional Infrastructure and Foster Cross-Sector Collaboration

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

• Federal support for regional testbeds, prototyping sites, and grid modernization labs, coordinated by agencies such as DOE and EDA,  would support the demonstration and scaling of biologically enabled clean energy technologies.
• State and local governments, in coordination with federal agencies including DOT and DOC, explore investment in logistics infrastructure to enhance supply chain reliability and support distributed manufacturing.
• States should consider creating or expanding the use of innovation voucher programs that allow small and mid-sized enterprises to access national lab facilities, pilot-scale infrastructure, and technical expertise, fostering cross-sector collaboration between clean energy, biotech, and advanced manufacturing firms. 

Attract and De-Risk Private Capital

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

• State governments, in collaboration with the federal agencies such as DOE and Treasury, should consider implementing state-backed loan guarantees and co-investment models to attract private capital into high-risk clean energy and biotech projects. 
• Federal agencies like EDA, DOE, and the SBA should explore additional programs and partnerships to attract philanthropic and venture capital to emerging clean energy technologies, particularly in underserved regions.
• Federal agencies should increase efforts to facilitate connecting early-stage companies with potential investors, using federal initiatives to build investor confidence and reduce perceived risks in the clean energy sector.

Cross-Cutting Key Findings

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

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

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

Create a Federal–Regional Clean Energy Deployment Compact

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

• The White House Office of Science and Technology Policy (OSTP), in collaboration with the DOE and EPA, should establish formal intergovernmental councils or regional liaisons to facilitate ongoing dialogue between federal agencies and regional stakeholders. These councils would focus on aligning federal clean energy initiatives with regional needs, ensuring that local priorities, such as feedstock availability or infrastructure readiness, are considered in policy design.
• The DOE and EPA should treat tech hubs and regional clean energy initiatives as testbeds for policy innovation. These regions can pilot performance-based incentives, carbon standards, and other policy tools to assess their effectiveness before scaling them nationally. Successful models developed in these testbeds should be expanded to other regions, with lessons learned shared across state and local governments.
• Regional universities and innovation hubs should collaborate with federal and state agencies to develop pilot programs that test new policy tools and technologies. These institutions can serve as incubators for innovative clean energy solutions, providing valuable data on what policies work best in specific regional contexts.

Build a National Innovation-to-Deployment Pipeline

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

• DOE should facilitate the creation of a national network that connects federal labs, regional tech hubs and innovation consortia. This network would provide a clear pathway for the transition of technologies from research to commercialization, ensuring that innovations can be deployed across different regions based on local needs and capacities. 
• Regional Tech Hubs, in partnership with local universities and research institutions, should be integrated into the pipeline to provide localized innovation support and commercialization expertise. These hubs can act as nodes in the broader network, offering the infrastructure and expertise necessary for scaling up clean energy technologies.

Develop a Shared Metrics and Monitoring Platform

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

• The DOE, in partnership with the EPA, should lead the development of a centralized dashboard that integrates existing federal and regional data on SAF production, emissions reductions, workforce needs, and infrastructure gaps. This platform should be publicly accessible, allowing stakeholders at all levels to monitor progress and identify opportunities for improvement.
• State and local governments should contribute relevant data from regional initiatives, including workforce training programs, infrastructure development projects, and emissions reductions efforts. These contributions would help ensure that the platform reflects the full range of activities across different regions, providing a more accurate picture of national progress.
  The Department of Labor and the DOC should integrate workforce development and industrial capacity data into the platform. This would include information on training programs, regional workforce readiness, and skills gaps, helping policymakers align talent development efforts with regional needs.
  The DOT should ensure that transportation infrastructure data, particularly related to SAF production and distribution networks, is included in the platform. This would provide a comprehensive view of the supply chain and infrastructure readiness necessary to scale clean energy technologies across regions.

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

This report was produced with generous support from Norwegian People’s Aid.

The quantitative and qualitative enhancements to global nuclear arsenals in the past decade—particularly China’s nuclear buildup, Russia’s nuclear saber-rattling, and NATO’s response—have recently reinvigorated debates about how nuclear-armed states intend to use their nuclear weapons, and against which targets, in what some describe as a new Cold War. 

Details about who, what, where, when, why, and how countries target with their nuclear weapons are some of states’ most closely held secrets. Targeting information rarely reaches the public, and discussions almost exclusively take place behind closed doors—either in the depths of military headquarters and command posts, or in the halls of defense contractors and think tanks. The general public is, to a significant extent, excluded from those discussions. This is largely because nuclear weapons create unique expectations and requirements about secrecy and privileged access that, at times, can seem borderline undemocratic. Revealing targeting information could open up a country’s nuclear policies and intentions to intense scrutiny by its adversaries, its allies, and—crucially—its citizens. 

This presents a significant democratic challenge for nuclear-armed countries and the international community. Despite the profound implications for national and international security, the intense secrecy means that most individuals—not only including the citizens of nuclear-armed countries and others that would bear the consequences of nuclear use, but also lawmakers in nuclear-armed and nuclear umbrella states that vote on nuclear weapons programs and policies—do not have much understanding of how countries make fateful decisions about what to target during wartime, and how. When lawmakers in nuclear-armed countries approve military spending bills that enhance or increase nuclear and conventional forces, they often do so with little knowledge of how those bills could have implications for nuclear targeting plans. And individuals across the globe do not know whether they live in places that are likely to be nuclear targets, or what the consequences of a nuclear war would be.

While it is reasonable for governments to keep the most sensitive aspects of nuclear policies secret, the rights of their citizens to have access to general knowledge about these issues is equally valid so they may know about the consequences to themselves and their country, and so that they can make informed assessments and decisions about their respective government’s nuclear policies. Under ideal conditions, individuals should reasonably be able to know whether their cities or nearby military bases are nuclear targets and whether their government’s policies make it more or less likely that nuclear weapons will be used.

As an organization that seeks to empower individuals, lawmakers, and journalists with factual information about critical topics that most affect them, the Federation of American Scientists—through this report—aims to help fill some of these significant knowledge gaps. This report illuminates what we know and do not know about each country’s nuclear targeting policies and practices, and considers how they are formulated, how they have changed in recent decades, whether allies play a role in influencing them, and why some countries are more open about their policies than others. The report does not claim to be comprehensive or complete, but rather should be considered as a primer to help inform the public, policymakers, and other stakeholders. This report may be updated as more information becomes available.

Given the secrecy associated with nuclear targeting information, it is important at the outset to acknowledge the limitations of using exclusively open sources to conduct analysis on this topic. Information in and about different nuclear-armed states varies significantly. For countries like the United States—where nuclear targeting policies have been publicly described and are regularly debated inside and outside of government among subject matter experts—official sources can be used to obtain a basic understanding of how nuclear targets are nominated, vetted, and ultimately selected, as well as how targeting fits into the military strategy. However, there is very little publicly available information about the nuclear strike plans themselves or the specific methodology and assumptions that underpin them. For less transparent countries like Russia and China—where targeting strategy and plans are rarely discussed in public—media sources, third-country intelligence estimates, and nuclear force structure analysis can be used, in conjunction with official statements or statements from retired officials, to make educated assumptions about targeting policies and strategies. 

It is important to note that a country’s relative level of transparency regarding its nuclear targeting policies does not necessarily echo its level of transparency regarding other aspects of its governance structure. Ironically, some of the most secretive and authoritarian nuclear-armed states are remarkably vocal about what they would target in a nuclear war. This is typically because those same countries use nuclear rhetoric as a means to communicate deterrence signals to their respective adversaries and to demonstrate to their own population that they are standing up to foreign threats. For example, while North Korea keeps many aspects of its nuclear program secret, it has occasionally stated precisely which high-profile targets in South Korea and across the Indo-Pacific region it would strike with nuclear weapons. In contrast, some other countries might consider that frequently issuing nuclear threats or openly discussing targeting policies could potentially undermine their strategic deterrent and even lower the threshold for nuclear use.

Nearly one year after the Pentagon certified the Sentinel intercontinental ballistic missile program to continue after it incurred critical cost and schedule overruns, the new nuclear missile could once again be in trouble.¹

An April 16th article from Defense Daily broke the news that the Air Force will have to dig new holes for the Sentinel silos.² The service had been planning to refurbish the existing 450 Minuteman silos but recently discovered, as noted in a follow-up article from Breaking Defense, that the silos will “largely not be reusable after all.”³ Brig. Gen. William Rogers, the Air Force’s director of the ICBM Systems Directorate, cited asbestos, lead paint, and other issues with the existing silos that make refurbishment difficult.⁴ Air Force officials also stated that an ongoing study into missileer cancer rates played a role in the decision to build new silos.⁵ 

This news comes shortly after reports that the Air Force is planning to extend the life of the currently deployed Minuteman III ICBMs until “at least” 2050—roughly 20 years beyond their intended service lives—due to delays in the Sentinel program.⁶ 

For those who have been tracking the Sentinel development since the Air Force first conceptualized a new ICBM in the early 2010s, the reports of Minuteman life-extension likely made them pause and recall the common refrain from Sentinel proponents over the years that life-extending Minuteman III missiles would be too expensive or even impossible. “You cannot life-extend Minuteman III,” then-commander of US Strategic Command Adm. Charles Richard told reporters in 2021.⁷ In 2016, the Air Force told Congress that the Minuteman III was aging out, therefore the “GBSD solution” was necessary to ensure the future viability of the ICBM force (GBSD is short for Ground-Based Strategic Deterrent, the programmatic name for the ICBM before Sentinel was chosen in 2022). Air Force officials still maintain that a life-extension program for Minuteman is not possible. In their words, Minuteman will be “sustain[ed] to keep it viable until Sentinel is delivered.”⁸ Regardless of how the Air Force refers to the effort, it appears that Minuteman III will be made to operate well beyond its planned service life.

For some, like our team at the Federation of American Scientists’ Nuclear Information Project, Sentinel’s newest struggles came as no surprise at all. For years, it has been clear to observers that this program has suffered from chronic unaccountability, overconfidence, poor performance, and mismanagement. Project benchmarks were cherry-picked, viable alternatives were prematurely dismissed, competition was discouraged, and goalposts were continuously moved. Ultimately, it will be U.S. taxpayers who pay the increasingly rising costs, and other—more critical—priorities will suffer as Sentinel continuously sucks money away from other programs. 

It comes as no surprise that Sentinel was specifically named in the White House’s recent memo requiring all Major Defense Acquisition Programs more than 15% over-budget or behind schedule to be “reviewed for cancellation;” Sentinel is the poster-child for inefficiency, which the administration claims to be obsessed with eliminating.⁹ In order to prevent this type of mismanagement for future programs, we must first understand how Sentinel went so wrong. 

How We Got Here

The Federation of American Scientists has been intensively tracking the progress of the Sentinel program for years. Throughout the acquisition process, the Air Force clung to its fundamental and counterintuitive assumption that building an entirely new ICBM from scratch would be cheaper than life-extending the current system. We now know that this assumption was wildly incorrect, but how did it reach this point? 

Cherry-picked project benchmarks

When seeking to plug a capability gap, the Pentagon is required to consider a range of procurement options before proceeding with its acquisition. This process takes place over several years and culminates in an “Analysis of Alternatives”—a comparative evaluation of the operational effectiveness, suitability, risk, and life-cycle costs of the various options under consideration. This assessment can have tremendous implications for an acquisition program, as it documents the rationale for recommending a particular course of action. 

The Air Force’s Analysis of Alternatives for the program that would eventually become Sentinel was conducted between 2013 and 2014, and concluded that the costs of pursuing a Minuteman III life-extension would be nearly the same as those projected for Sentinel.¹⁰ Crucially, this cost comparison was pegged to a predetermined requirement to continue deploying the same number of missiles until the year 2075.¹¹ 

These benchmarks, despite having no apparent inalterable national security imperative, appear to have played a significant role in shaping perceptions of the two options. While it is now clear that Minuteman III could be—and likely will be—life-extended for several more decades, the Air Force does not have enough airframes to keep at least 400 of them in service through 2075 and maintain the testing campaign needed to ensure reliability. As a result, in order to push the ICBM force beyond 2075, the Air Force would need to life-extend Minuteman III and pursue a follow-on system after that point. 

This was reportedly reflected in the Air Force’s cost analysis, which explains why the cost of the Minuteman III life-extension option was estimated by the Air Force to be roughly the same as the cost of building an entirely new ICBM.¹² The service was not simply comparing the costs of a life-extension and a brand-new system; it was instead comparing the costs of pursuing Sentinel immediately on the one hand, versus a Minuteman III life-extension and development of a follow-on system on the other hand. 

Of course, policymakers require benchmarks in order to make estimates: it would not be reasonable to analyze the feasibility of a particular system without considering how long and at what level that system needs to perform. However, in the case of the Sentinel, selecting those particular benchmarks at the beginning of the process essentially pre-baked the analysis before it even began in earnest. 

Let’s say a different evaluation benchmark had been selected—2050, for example, rather than 2075. 

In January 2025, Defense Daily reported that the Air Force would likely have to keep portions of the Minuteman III fleet in service until 2050 or later.¹³ This may require altering certain aspects of the Minuteman III’s deployment—such as reducing the number of deployed ICBMs or annual test launches in order to preserve airframes. While no final decisions have been made, the Air Force is clearly evaluating continued reliance on Minuteman III as a potential option, despite years of high-ranking military and political officials stating that doing so was impossible.¹⁴ 

Benchmarking the cost analysis at 2050 rather than 2075 would have thus yielded wildly different results. In 2012, the Air Force admitted that it cost only $7 billion to modernize its Minuteman III ICBMs into “basically new missiles except for the shell.”¹⁵ While getting those same missiles past 2050 would certainly add additional cost and complexity—particularly to replace parts whose manufacturers no longer exist—it is unfathomable that the costs would come anywhere close to those of the Sentinel program, which was estimated by the Pentagon’s Director of Cost Assessment and Program Evaluation (CAPE) in 2020 (before the critical cost overrun) to have a total lifecycle cost of $264 billion in then-year dollars.

It is particularly troubling that very few public or independent government-sponsored analyses were conducted to look into the Sentinel program’s flawed assumptions, nor the realistic possibility of a Minuteman III life-extension. Countless congressional and non-governmental attempts to push for one were stymied at every turn. In 2019, for example, dozens of lobbyists from the Sentinel contract bidders successfully helped to eliminate a proposed amendment to the National Defense Authorization Act calling for an independent study on a Minuteman III life-extension program.¹⁶ 

The most comprehensive public study on this issue was a 2022 report published by the Carnegie Endowment for International Peace under contract from the Pentagon; however, the study noted that “the iterative process through which we received information, the unclassified nature of our study, and the limited time available for investigating DOD conclusions left us unable to assess the DOD’s position regarding the technical and cost feasibility of an extended Minuteman III alternative to GBSD;” the authors ultimately concluded that a more detailed technical analysis was required in order to answer these questions.¹⁷ 

While the findings of such a study will never be known, it is likely that they would have supported what was clear to government watchdogs at the time and has been validated in spades since then: the assumptions baked into this program were flawed from the start, and the system’s costs would be significantly larger than initially expected. Given that the Pentagon ultimately went in the opposite direction, taxpayers are now on the hook for both a de facto Minuteman III life-extension program as well as the substantial costs associated with acquiring Sentinel—with limited further possibilities for near-term cost mitigation. 

Failure to predict the true costs and needs of the program

In addition to the cherry-picked benchmarks that tipped the scales towards a brand-new ICBM, when comparing costs the Air Force made a key error in its assumptions: it assumed that the Sentinel would be able to reuse much of the original Minuteman launch infrastructure. 

Some level of infrastructure modernization for the Sentinel was always planned, including building entirely new launch control centers and additional infrastructure for the launch facilities.¹⁸ However, the original plans called for reusing existing copper command and control cabling and the refurbishment—not reconstruction—of 450 silos. Both assumptions have proven incorrect, and perhaps more than anything else, now represent the single greatest driver of Sentinel’s skyrocketing costs. 

While both the current cabling and launch facilities work fine for the existing Minuteman III and would presumably function similarly following a life-extension, they are apparently incompatible with Sentinel’s increasingly complex design. 

The Air Force must now dig up and replace 7,500 miles of cabling with the latest fiber optic cables. Much of these cables are buried underneath private property, meaning that local landowners must lease 100-foot-wide lines on their property to the Pentagon to be dug up for multi-year periods.¹⁹ 

In addition, both the Air Force and Northrop Grumman have now recognized that it will take more than simple refurbishments to make the existing Minuteman III launch facilities compatible with Sentinel. Both the service and the contractor have stated that several of the assumptions regarding the conversion process that went into the 2020 baseline review have now proved to be incorrect.²⁰ 

As a result, the Air Force is apparently now planning to build entirely new launch facilities to house the Sentinel, most of which will require digging new holes in the ground.²¹ As one Northrop Grumman official explained, “When you multiply that by 450, if every silo is a little bit bigger or has an extra component, that actually drives a lot of cost because of the sheer number of them that are being updated.”²² It is unclear whether the costs will increase beyond the new estimate released with the Nunn-McCurdy decision, but the program is clearly trending in the wrong direction.

The Air Force had been publicly teasing the prospect of digging new holes for nearly a year. At the Triad Symposium in Washington, D.C., in September 2024, Maj. Gen. Colin Connor, director of ICBM Modernization at Barksdale Air Force Base, responded to an audience question about the new silos rumor by saying, “we’re looking at all of our options.” Despite the noncommittal answer, the decision to dig new silos seems to have already been made by the time of Connor’s statement. 

Firstly, it has since been revealed that the estimated costs of the new silos were included in the Nunn-McCurdy review process which concluded in July 2024. Additionally, although the decision was not made public until the April 16 Defense News article, Northrop Grumman may have inadvertently revealed the news much earlier. Included in the gallery of images of the Sentinel program on Northrop’s website is a digital mockup of a Sentinel launch facility. The first version of the image (see Figure A below) illustrates the Air Force’s original plan to refurbish the Minuteman III silos for Sentinel, with a key indicating the silo and silo lid as “Reclaimed MMIII Facilities.” A newer version of the image (see Figure B below) was uploaded to the gallery as early as February 2024 and shows the entire launch facility—including the silo and silo lid—as “New Sentinel Facilities.”

Figure A

Original rendering of Sentinel launch facility. (Source: Northrop Grumman)

Figure B

New rendering of Sentinel launch facility. (Source: Northrop Grumman)

Unwarranted overconfidence 

Despite the clear concerns outlined above, the Pentagon was remarkably confident in its and Northrop Grumman’s abilities to deliver the Sentinel on-time and on-budget. 

In September 2020, the Pentagon delivered its Milestone B summary report to Congress—a key decision point at which acquisition programs are authorized to enter the Engineering and Manufacturing Development phase, considered to be the official start of a program. The Milestone B report included an estimate of $95.8 billion in then-year dollars to acquire the Sentinel—a significant increase from previous estimates, but not yet the dire situation that we find ourselves in today (Figure C). 

Figure C

The above table from the Congressional Budget Office shows the cost growth for the Sentinel’s acquisition program between the Sentinel’s Milestone B assessment in 2020 and the post-Nunn-McCurdy review process in 2025. All costs are reflected in FY2020 dollars to allow for an accurate comparison between years.

We now know, however, based on recent statements from Pentagon and Air Force officials, that there were “some gaps in maturity” in the Milestone B report.²³ Specifically, “in September of 2020, the knowledge of the ground-based segment of this program was insufficient in hindsight to have a high-quality cost estimate.” What this means is that at the most consequential stage of the program to-date, it was approved without a comprehensive understanding of the likely cost growth. 

Furthermore, the Air Force was heavily delayed in creating an integrated master schedule for the Sentinel program. An integrated master schedule includes the planned work, the resources necessary to accomplish that work, and the associated budget; from the government’s perspective, it is considered to be the keystone for program management.²⁴ Although the Under Secretary of Defense for Acquisition and Sustainment testified to Congress that “By the time you’re six months after Milestone B, you should have an integrated master schedule,” the Air Force had not met this mark.²⁵ If the Air Force did manage to create such a schedule, it became obsolete with the Nunn-McCurdy Act’s requirement to restructure the program and rescind its Milestone B approval.

During that same hearing, the Air Force’s Deputy Chief of Staff for Strategic Deterrence and Nuclear Integration also admitted that at that time, the service had been experiencing poor communication with Northrop Grumman, the primary contractor for the ICBM. 

Performance issues also appear to have had an impact on the program. In June 2024, the Air Force removed the colonel in charge of its Sentinel program—reportedly for a “failure to follow operational procedures”—and replaced him with a two-star general, with the rank change indicating a need for greater high-level attention.²⁶ 

Throughout this time, the Air Force remained overconfident in its abilities to deliver the program; in December 2020, the Assistant Secretary of the Air Force for Acquisition, Technology, and Logistics told reporters that the Air Force had “godlike insight into all things GBSD.”²⁷ And in September 2022, the Air Force Major General responsible for Sentinel’s strategic planning and requirements said in a Breaking Defense interview that the program was “on cost, on schedule, and the acquisition program baseline is being met.”²⁸ 

Given everything we now know about the state of the Sentinel program, these statements were either clear obfuscations or just pure fantasy. 

Non-competitive disadvantages

When addressing concerns about the rising projected costs of the Sentinel program, Air Force leaders were confident that a competitive and healthy industrial base would be able to keep the overall price tag down. As Gen. Timothy Ray, then-Commander of Air Force Global Strike Command, told reporters in 2019, “our estimates are in the billions of savings over the lifespan of the weapon.”²⁹ 

These expected savings clearly never materialized, however, nor did the Pentagon help facilitate the conditions for them to be realized. In March 2018, the Air Force Nuclear Weapons Center submitted a document justifying its intention to restrict competition for the Sentinel contract to just two suppliers—Boeing and Northrop Grumman—stating that this limitation would still constrain costs because the two companies would be in competition with one another.³⁰ 

However, this specter of competition evaporated when Boeing withdrew from the competition following Northrop Grumman’s acquisition of Orbital ATK—one of two independent producers of large solid rocket motors left in the US market.³¹ As these motors are necessary to make ICBMs fly, the merger put Northrop Grumman in the driver’s seat: it could restrict access to those motors from Boeing, thus tanking its competitor’s chances at the Sentinel bid. 

Doing so would not have been allowed by the terms of the Federal Trade Commission, which permitted the merger in 2018 but subsequently investigated it in 2022 under the Biden administration, and also subsequently blocked a similar attempted merger between Lockheed Martin and Aerojet Rocketdyne that same year.³² However, the Pentagon, which had initially included non-exclusionary and pro-competition language in its requirements for an earlier phase of the Sentinel contract, removed that language from future phases.³³ By refusing to wield its own power to preserve competition—initially a key driver for promoting Sentinel over a Minuteman III life-extension—the Air Force essentially left the state of the competition in Northrop Grumman’s hands. According to Boeing’s CEO, Northrop Grumman subsequently slow-walked the process of hammering out a competition arrangement with Boeing—apparently not leaving enough time for Boeing to negotiate a competitive price for solid rocket motors before the Sentinel deadline.³⁴ 

As a result, Boeing pulled out of the competition altogether, and the Air Force awarded the Sentinel engineering and manufacturing development contract to Northrop Grumman through an unprecedented single-source bidding process. As the Under Secretary of Defense for Acquisition and Sustainment admitted during 2024 testimony to Congress, what this amounted to was that “effectively there was not, at the end of the day, competition in this program.”³⁵ 

Reflecting on the Sentinel procurement process, House Armed Services Committee chairman Adam Smith—who has a sizable Boeing presence in his home state of Washington—suggested in October 2019 that the Air Force is “way too close to the contractors they are working with,” and implied that the service was biased towards Northrop Grumman.³⁶ 

Predictably, the evaporation of competition has coincided with skyrocketing Sentinel acquisition costs. In July 2024, the Air Force’s acquisition chief Andrew Hunter reportedly told reporters that the Air Force was considering reopening parts of the Sentinel contract to bids. “I think there are elements of the ground infrastructure where there may be opportunities for competition that we can add to the acquisition strategy for Sentinel,” Hunter said.³⁷

The Nunn-McCurdy Saga

In January 2024, the Air Force notified Congress that the Sentinel program had incurred a critical breach of the Nunn-McCurdy Act, legislation designed to keep expensive programs in check.³⁸ One week after notifying Congress of the breach, the Air Force fired the head of the Sentinel program, but said the move was “not directly related” to the Nunn-McCurdy breach.³⁹

At the time of the notification, the Air Force stated that the program was 37% over budget and two years behind schedule. Six months later, after conducting the cost reassessment mandated by Nunn-McCurdy, the Pentagon announced that the Sentinel program would cost 81% more than projected and be delayed by several years.⁴⁰ Nevertheless, the Secretary of Defense certified the program to continue. 

Per the requirements of the Nunn-McCurdy Act, the Under Secretary of Defense for Acquisition and Sustainment, who serves as the Milestone Decision Authority for the program, rescinded Sentinel’s Milestone B approval, which is needed for a program to enter the engineering and manufacturing development phase.⁴¹ The Air Force must restructure the program to address the root cause of the cost growth before receiving a new milestone approval, a process the service has said will take approximately 18 to 24 months.⁴² 

Where Sentinel Stands Now

Work on the Sentinel program has continued while the Air Force carries out the restructuring effort, but the government can’t seem to decide whether things are going well or not.  

On February 10, the Air Force told Defense One that parts of the Sentinel program had been “suspended.”⁴³ Due to “evolving” requirements related to Sentinel launch facilities, the Air Force instructed Northrop Grumman to halt “design, testing, and construction work related to the Command & Launch Segment.” There has been no indication of when the stop work order will be lifted. Nevertheless, during an April 10 Air Force town hall on Sentinel in Kimball, Nebraska, Wing Commander of F.E. Warren AFB Col. Johnny Galbert told attendees that Sentinel “is not on hold; it is moving forward.”⁴⁴

Just under one month after the stop work order was made, the Air Force announced that the Sentinel program had achieved a “modernization milestone” with the successful static fire test of Sentinel’s stage-one solid rocket motor.⁴⁵ The test marked the successful test firing of each stage of Sentinel’s rocket motor after the second and third stages were tested in 2024. 

On March 27, the same day Bloomberg reported that the Air Force was considering a life-extension program for Minuteman III missiles, President Trump’s nominee for Secretary of the Air Force (confirmed by the Senate on May 13), Troy Meinke, committed in his testimony to pushing Sentinel over the finish line, calling the program “foundational to strategic deterrence and defense of the homeland.”⁴⁶ During the same hearing, Trump’s nominee for undersecretary of Defense for acquisition and sustainment, Michael P. Duffey, also shared his support for the Sentinel program, saying “nuclear modernization is the backbone of our strategic deterrent,” and endorsing Sentinel as “critical.” Yet, two weeks later, on April 9, President Trump signed an executive order to address defense acquisition programs that mandates, “any program more than 15% behind schedule or 15% over cost will be scrutinized for cancellation.”⁴⁷ This places Sentinel well beyond the threshold for potential cancellation, and the White House fact sheet detailing the order explicitly called out Sentinel’s cost and schedule overruns.

The next day, the Air Force announced that another “key milestone” for the Sentinel program had been met with the stand-up of Detachment 11 at Malmstrom AFB, which will oversee implementation of the Sentinel program at the base.⁴⁸ But of course, less than thirty days later, Sentinel took a major blow with the Air Force’s admittance that hundreds of new silos would have to be dug up and constructed for the new ICBM. 

The Government Accountability Office’s (GAO) latest Weapon Systems Annual Assessment from June 11 reports that Sentinel’s costs “could swell further” as the Air Force “continues to evaluate its options and develop a new schedule as part of restructuring efforts.” The assessment also notes that the Sentinel program alone accounted for over $36 billion of the $49.3 billion increase from 2024 to 2025 in GAO’s combined total estimate of major defense acquisition program costs, and noted that the first flight test now would not take place until March 2028.⁴⁹ In a sweeping criticism of the program, the GAO report notes that the continued immaturity of the program’s critical technologies more than 4 years into its development phase “calls into question the level of work required to mature these technologies and the validity of the cost estimate used to certify the program.”⁵⁰

450 Money Pits

We probably will never know how much money could have been saved if the Air Force had elected from the beginning to life-extend the existing ICBMs rather than build an entirely new system from scratch. The opportunity to have a proactive, independent cost comparison and corresponding public debate was eliminated through intense rounds of Pentagon and industry lobbying. But we certainly now know that the Air Force’s assertion—that the Sentinel would be cheaper and easier than a life-extension—was wrong, and that the suppression of an independent review contributed to these rising costs. 

The Sentinel saga, with its seemingly unending series of setbacks and continued uncertainties, begs a crucial question: what incentives exist for the Air Force to get it right? That the program, along with numerous other nuclear modernization programs, was green-lighted to continue despite ever-increasing cost and schedule delays exposes a major flaw in U.S. nuclear weapons acquisition programs – they are too big to fail. The government, evidently, will always write a bigger check, will always move the goalposts, because the alternative is either failing to maintain the U.S. strategic deterrent or admitting that U.S. nuclear strategy and force structure is not as immutable and unquestionable as the public has been made to believe. In such a system of blank checks and industry lobbying, what incentivizes the Pentagon to ensure programs are as cost efficient as possible? The only mechanism for oversight and accountability is Congress. Congress must increase oversight of nuclear modernization programs like Sentinel to ensure a limit is placed on how much taxpayer money can be spent on failing programs in the name of national security.

Executive Summary

The clean energy transition is not just about technology — it is about trust, timing, and transaction models. As federal uncertainty grows and climate goals face political headwinds, a new coalition of subnational actors is rising to stabilize markets, accelerate permitting, and finance a more inclusive green economy. This white paper, developed by the Federation of American Scientists (FAS) in collaboration with Climate Group and the Center for Public Enterprise (CPE), outlines a bold vision: one in which state and local governments – working hand-in-hand with mission-aligned investors and other stakeholders – lead a new wave of public-private clean energy deployment.

Drawing on insights from the closed-door session “De-Risking the Clean Energy Transition” and subsequent permitting discussions at the 2025 U.S. Leaders Forum, this paper offers strategic principles and practical pathways to scale subnational climate finance, break down permitting barriers, and protect high-potential projects from political volatility. This paper presents both a roadmap and an invitation for continued collaboration. FAS and its partners will facilitate further development and implementation of approaches and ideas described herein, with the goals of (1) directing bridge funding towards valuable and investable, yet at-risk, clean energy projects, and (2) building and demonstrating the capacity of subnational actors to drive continued growth of an equitable clean economy in the United States.

We invite government agencies, green banks and other financial institutions, philanthropic entities, project developers, and others to formally express interest in learning more and joining this work. To do so, contact Zoe Brouns (zbrouns@fas.org).

The Moment: Opportunity Meets Urgency

We are in the complex middle of a global energy transition. Clean energy and technology are growing around the world, and geopolitical competition to consolidate advantage in these sectors is intensifying. The United States has the potential to lead, but that leadership is being tested by erratic federal environmental policies and economic signals. Meanwhile, efforts to chart a lasting domestic clean energy path that resonates with the full American public have fallen short. Demand is rising — fueled by AI, electrification, and industrial onshoring – yet opposition to clean energy buildout is growing, permitting systems are gridlocked, and legacy regulatory frameworks are failing to keep up. This moment calls for new leadership rooted in local and regional capacity and needs. Subnational governments, green and infrastructure banks, and other funders have a critical opportunity to stabilize clean energy investment and sustain progress amid federal uncertainty. Thanks to underlying market trends favoring clean energy and clean technology, and to concerted efforts over the past several years to spur U.S. growth in these sectors, there is now a pipeline of clean projects across the country that are shovel-ready, relatively de-risked and developed, and investable (Box 1). Subnational actors can work together to identify these projects, and to mobilize capital and policy to sustain them in the near term.

Box 1. Streamlining administrative procedure to unleash clean energy in New York.

The New York Power Authority used a simple, quick Request for Information (RFI) to identify readily investible clean energy projects in New York, and was then able to financially back many of the identified projects thanks to its strong bond rating and ability to access capital. As Paul Williams, CEO of the Center for Public Enterprise, noted, this powerful approach allowed the Authority to “essentially [pull] a 3.5-gigawatt pipeline out of thin air in less than a year.”

States, cities, and financial institutions are already beginning to provide the support and sustained leadership that federal agencies can no longer guarantee. They’re developing bond-backed financing, joint procurement schemes, rapid permitting pilot zones, and revolving loan funds — not just to fill gaps, but to reimagine what clean energy governance looks like in an era of fragmentation. One compelling example is the Connecticut Green Bank, which has successfully blended public and private capital to deploy over $2 billion in clean energy investments since its founding. Through programs like its Commercial Property Assessed Clean Energy (C-PACE) financing and Solar for All initiative, the bank has reduced emissions, created jobs, and delivered energy savings to underserved communities.

Indeed, this kind of mission-oriented strategy – one that harnesses finance and policy towards societally beneficial outcomes, and that entrepreneurially blends public and private capacities – is in the best American tradition. Key infrastructure and permitting decisions are made at the state and local levels, after all. And state and local governments have always been central to creating and shaping markets and underwriting innovation that ultimately powers new economic engines. The upshot is clear and striking: subnational climate finance isn’t just a workaround. It may be the most politically durable and economically inclusive way to future-proof the clean energy transition.

The Role of Subnational Finance in the Clean Energy Transition

Recent years saw heavy reliance on technocratic federal rules to spur a clean energy transition. But a new political climate has forced a reevaluation of where and how federal regulation works best. While some level of regulation is important for creating certainty, demand, and market and investment structures, it is undeniable that the efficacy and durability of traditional environmental regulatory approaches has waned. There is an acute need to articulate and test new strategies for actually delivering clean energy progress (and a renewed economic paradigm for the country) in an ever-more complex society and dynamic energy landscape.

Affirmatively wedding finance with larger public goals will be a key component of this more expansive, holistic approach. Finance is a powerful tool for policymakers and others working in the public interest to shape the forward course of the green economy in a fair and effective way. In the near term, opportunities for subnational investments are ripe because the now partially paused boom in potential firms and projects generated by recent U.S. industrial policy has generated a rich set of already underwritten, due-diligenced projects for re-investment. In the longer term, the success of redesigned regulatory schema will almost certainly depend on creating profitable firms that can carry forward the energy transition. Public entities can assume an entrepreneurial role in ensuring these new economic entities, to the degree they benefit from public support, advance the public interest. Indeed, financial strategies that connect economic growth to shared prosperity will be important guardrails for an “abundance” approach to environmental policy – an approach that holds significant promise to accelerate necessary societal shifts, but also presents risk that those shifts further enrich and empower concentrated economic interests.

To be sure, subnational actors generally cannot fund at the scale of the federal government. However, they can mobilize existing revenue and debt resources, including via state green and infrastructure banks, bonding tools, and direct investment financing strategies, to seed capital for key projects and to provide a basis for larger capital stacks for key endeavors. They are also particularly well suited to provide “pre-development” support to help projects move through start-up phases and reach construction and development. Subnational entities can engage sectorally and in coalition to scale up financing, to draw in private actors, and to support projects along the whole supply and value chain (including, for instance, multi-state transmission and grid projects, multi-state freight and transportation network improvements, and multi-state industrial hubs for key technologies).

A wide range of financing strategies for clean energy projects already exist. For instance:

• Revolving loan funds can help public entities provide lower-cost debt financing to draw in additional private capital.
• Joint procurements or bundled financing can set technological standards, provide pricing power, and reduce the cost of capital for smaller businesses and make it easier for them to break into the clean energy economy. 
• Financing programs for projects with public benefits can be designed in ways that allow government investors to take a small equity stake, sharing both risk and revenue over time.

Strategies like these empower states and other subnational actors to de-risk and drive the clean energy transition. The expanding green banking industry in the United States, and similar institutions globally, further augment subnational capacity. What is needed is rapid scaling and ready capitalization.

There is presently tremendous need and opportunity to deploy flexible financing strategies across projects that are shovel-ready or in progress but may need bridge funding or other investments in the wake of federal cuts. The critical path involves quickly identifying valuable, vetted projects in need of support, followed by targeted provision of financing that leverages the superior capital access of public institutions.

Projects could be identified through simple, quick Requests for Information (RFIs) like the one recently used to great effect by the New York Power Authority to build a multi-gigawatt clean energy pipeline (see Box 1, above). This model, which requires no new legislation, could be adopted by other public entities with bonding authority. Projects could also be identified through existing databases, e.g., of projects funded by, or proposed for funding under, the Inflation Reduction Act (IRA) or Infrastructure Investment and Jobs Act (IIJA). 

There is even the possibility of establishing a matchmaking platform that connects projects in need of financing with entities prepared to supply it. Projects could be grouped sectorally (e.g., freight or power sector projects) or by potential to address cross-cutting issues (e.g., cutting pollution burdens or managing increasing power grid load and its potential to electrify new economic areas). As economic mobilization around clean energy gains steam and familiarity with flexible financing strategies grows, such strategies can be extended to new projects in ways that are tailored to community interests, capacity, and needs.

Principles for Effective, Equitable Investment

The path outlined above is open now but will substantially narrow in the coming months without concerted, coordinated action. The following principles can help subnational actors capitalize on the moment effectively and equitably. It is worth emphasizing that equitable investment is not only a moral imperative – it is a strategic necessity for maintaining political legitimacy, ensuring community buy-in, and delivering long-term economic resilience across regions.

Funders must clearly state goals and be proactive in pursuing them – starting now to address near-term instability. Rather than waiting for projects to come to them, subnational governments, financial institutions, and other funders should use their platforms and convening power to lay out a “mission” for their investments – with goals like electrifying the industrial sector, modernizing freight terminals and ports, and accelerating transmission infrastructure with storage for renewables. Funders should then use tools like simple RFIs to actively seek out potential participants in that mission.

Public equity is a key part of the capital stack, and targeted investments are needed now. With significant federal climate investments under litigation and Congressional debates on the Inflation Reduction Act ongoing, other participants in the domestic funding ecosystem must step up. Though not all federal capital can (or should) be replaced, targeted near-term investments coupled with multi-year policy and funding roadmaps by these actors can help stabilize projects that might not otherwise proceed and provide reassurance on the long-term direction of travel.

Information is a surprisingly powerful tool. Deep, shared, information architectures and clarity on policy goals are key for institutional investors and patient capital. Shared information on costs, barriers, and rates of return would substantially help facilitate the clean energy transition – and could be gathered and released by current investors in compiled form. Sharing transparent goals, needs, and financial targets will be especially critical in the coming months. Simple RFIs targeted at businesses and developers can also function as dual-purpose information-gathering and outreach tools for these investors. By asking basic questions through these RFIs (which need not be more than a page!), investors can build the knowledge base for shaping their clean technology and energy plans while simultaneously drawing more potential participants into their investment networks.

States should invest to grow long-term businesses. The clean energy transition can only be self-sustaining if it is profitable and generates firms that can stand on their own. Designing state incentive and investment projects for long-term business growth, and aligning complementary policy, is critical – including by designing incentive programs to partner well with other financing tools, and to produce long-term affordability and deployment gains, especially for entities which may otherwise lack capital access. State strategies, like the one New Mexico recently published, that outline energy-transition and economic plans and timelines are crucial to build certainty and align action across the investment and development ecosystem. Metrics for green programs should assess prospects for long-term business sustainability as well as tons of emissions reduced.

States can finance the clean energy transition while securing long-term returns and other benefits. Many clean technology projects may have higher upfront costs balanced by long-term savings. Debt equity, provided through revolving loan funds, can play a large role in accelerating deployment of these technologies by buying down entry costs and paying back the public investor over time. Moreover, the superior bond ratings of state institutions substantially reduce borrowing costs; sharing these benefits is an important role for public finance. State financial institutions can explore taking equity stakes in some projects they fund that provide substantial public benefits (e.g., mega-charging stations, large-scale battery storage, etc.) and securing a rate of return over time in exchange for buying down upfront risk. Diversified subnational institutions can use cash flows from higher-return portions of their portfolios to de-risk lower-return or higher-risk projects that are ultimately in the public interest. Finally, states with operating carbon market programs can consider expanding their funding abilities by bonding against some portion of carbon market revenues, converting immediate returns to long-term collateral for the green economy.

Financing policy can be usefully combined with procurement policy. As electrification reaches individual communities and smaller businesses, many face capital-access problems. Subnational actors should consider packaging similar businesses together to provide financing for multiple projects at once, and can also consider complementary public procurement policies to pull forward market demand for projects and products (Box 2).

Explore contract mechanisms to protect public benefits. Distributive equity is as important as large-scale investment to ensure a durable economic transition. The Biden-Harris Administration substantially conditioned some investments on the existence of binding community benefit plans to ensure that project benefits were broadly shared and possible harms to communities mitigated. Subnational investors could develop parallel contractual agreements. There may also be potential to use contracts to enable revenue sharing between private and public institutions, partially addressing any impacts of changes to the IRA’s current elective pay and transferability provisions by shifting realized income to the public entities that currently use those programs from the private entities that realize revenue from projects.

Box 2. Combining financing and procurement policy to electrify bus systems.

Joint procurements, whereby two or more purchasers enter into a single contract with a vendor, can bring down prices of emerging clean technologies by increasing purchase volume, and can streamline technology acquisition by sharing contracting workload across partners. Joint procurement and other innovative procurement policies have been used successfully to drive deployment of zero-emission buses in Europe and, more recently, the United States. Procurement strategies can be coupled with public financing. For instance, the Federal Transit Agency’s Low or No Emission Grant Program for clean buses preferences applications that utilize joint procurement, thereby helping public grant dollars go further.

The rising importance of the electrical grid across sectors creates new financial product opportunities. As the economy decarbonizes, more previously independent sectors are being linked to the electric grid, with load increasing (AI developments exacerbate this trend). That means that project developers in the green economy can offer a broader set of services, such as providing battery storage for renewables at vehicle charging points, distributed generation of power to supply new demand, and potential access to utility rate-making. Financial institutions should closely track rate-making and grid policy and explore avenues to accelerate beneficial electrification. There is a surprising but potent opportunity to market and finance clean energy and grid upgrades as a national security imperative, in response to the growing threat of foreign cyberattacks that are exploiting “seams” in fragile legacy energy systems.

Global markets can provide ballast against domestic volatility. The United States has an innovative financial services sector. Even though federal institutions may retreat from clean energy finance globally over the next few years, there remains a substantial opportunity for U.S. companies to provide financing and investment to projects globally, generate trade credit, and to bring some of those revenues back into the U.S. economy.

Financial products and strategies for adaptation and resilience must not be overlooked. Growing climate-linked disasters, and associated adaptation costs, impose substantial revenue burdens on state and local governments as well as on insurers and businesses. Competition for funds between adaptation and mitigation (not to mention other government services) may increase with proposed federal cuts. Financial institutions that design products that reduce risk and strengthen resilience (e.g., by helping relocate or strengthen vulnerable buildings and infrastructure) can help reduce these revenue competitions and provide long-term benefits by tapping into the $1.4 trillion market for adaptation and resilience solutions. Improved cost-benefit estimates and valuation frameworks for these interacting systems are critical priorities.

Conclusion: A Defining Window for Subnational Leadership

Leaders from across the country agree: clean energy and clean technology are investable, profitable, and vital to community prosperity. And there is a compelling lane for innovative subnational finance as not just a stopgap or replacement for federal action, but as a central area of policy in its own right.

The federal regulatory state is, increasingly, just a component of a larger economic transition that subnational actors can help drive, and shape for public benefit. Designing financial strategies for the United States to deftly navigate that transition can buffer against regulatory uncertainty and create a conducive environment for improved regulatory designs going forward. Immediate responses to stabilize climate finance, moreover, can build a foundation for a more engaged, and innovative, coalition of subnational financial actors working jointly for the public good.

Active state and private planning is the key to moving down these paths, with governments setting a clear direction of travel and marshaling their convening powers, capital access, and complementary policy tools to rapidly stabilize key projects and de-risk future capital choices.

There is much to do and no time to lose as governments and investors across the country seek to maintain clean technology progress. The Federation of American Scientists (FAS) and its partners will facilitate further development and implementation of approaches and ideas described above, with the goals of (1) directing bridge funding towards valuable and investable, yet at-risk, clean energy projects, and (2) building and demonstrating the capacity of subnational actors to drive continued growth of an equitable clean economy in the United States.

We invite government agencies, green banks and other financial institutions, philanthropic entities, project developers, and others to formally express interest in learning more and joining this work. To do so, contact Zoe Brouns (zbrouns@fas.org).

Acknowledgements 

Thank you to the many partners who contributed to this report, including: Dr. Jedidah Isler and Zoë Brouns at the Federation of American Scientists, Sydney Snow at Climate Group, Yakov Feigin, Chirag Lala, and Advait Arun at the Center for Public Enterprise, and Jayni Hein at Covington and Burling LLP.

In the spring of 2022, researchers at the Federation of American Scientists began reading newly released U.S. Defense Department budget documents to look for updates concerning the Pentagon’s priorities for the next fiscal year. As the researchers poured over hundreds of pages, two words suddenly captured their attention: the Biden administration’s Fiscal Year (FY) 2023 budget request had added “the UK” to a list of countries receiving upgrades to their “special weapons” storage sites under a 13-year NATO investment program. The term “special weapons” is often used by the U.S. government when referring to nuclear weapons. However, the United States has not deployed nuclear weapons in the United Kingdom for nearly two decades. Those two words sparked dozens of questions, years of continued research, and a new local movement of protests against the return of a potential nuclear mission to RAF Lakenheath.

This new report provides an account of the nuclear history of RAF Lakenheath and the role it played in the US nuclear mission until nuclear weapons were withdrawn in 2008. The report then explains the mounting evidence from three years of collection of documentation and observations that show the United States Air Force is re-establishing its nuclear mission on UK soil for the first time in nearly two decades.

As of February 2025, there are no known public indications that nuclear weapons have been deployed to RAF Lakenheath – we assess that the return of the nuclear mission is intended primarily as a backup rather than to deploy weapons now. However, if this were to happen, it would break with decades of policy and planning and reverse the southern focus of the European nuclear deployment that emerged after the end of the Cold War. Even without weapons present, the addition of a large nuclear air base in northern Europe is a significant new development that would have been inconceivable just a decade-and-a-half ago.

The authors would like to thank Matt Korda and Kate Kohn for their invaluable contributions to this report, as well as the Joseph Rowntree Charitable Trust for their support.

The United States faces urgent challenges related to aging infrastructure, vulnerable energy systems, and economic competitiveness. Improving American competitiveness, security, and prosperity depends on private and public stakeholders’ ability to responsibly site, build, and deploy critical energy and infrastructure. Unfortunately, these projects face one common bottleneck: permitting. 

Permits and authorizations are required for the use of land and other resources under a series of laws, such as the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and National Historic Preservation Act of 1966. However, recent court rulings and the Trump Administration’s executive actions have brought uncertainty and promise major disruption to the status quo. The Executive Order (EO) on Unleashing American Energy mandates guidance to agencies on permitting processes be expedited and simplified within 30 days, requires agencies prioritize efficiency and certainty over any other objectives, and revokes the Council of Environmental Quality’s (CEQ) authority to issue binding NEPA regulations. While these changes aim to advance the speed, efficiency, and certainty of permitting, the impact will ultimately depend on implementation by the permitting workforce.

Unfortunately, the permitting workforce is unprepared to swiftly implement changes following shifts in environmental policy and regulations. Teams responsible for permitting have historically been understaffed, overworked, and unable to complete their project backlogs, while demands for permits have increased significantly in recent years. Building workforce capacity is critical for efficient and effective federal permitting. 

Project Overview

Our team at the Federation of American Scientists (FAS) has spent 18 months studying and working to build government capacity for permitting talent. The Inflation Reduction Act (IRA) provided resources to expand the federal permitting workforce, and we partnered with the Permitting Council, which serves as a central body to improve the transparency, predictability, and accountability of the federal environmental review and authorization process, to gain a cross-agency understanding of the hiring challenges experienced in permitting agencies and prioritize key challenges to address. Through two co-hosted webinars for hiring managers, HR specialists, HR leaders, and program leaders within permitting agencies, we shared tactical solutions to improve the hiring process.

We complemented this understanding with voices from agencies (i.e., hiring managers, HR specialists, HR teams, and leaders) by conducting interviews to identify new issues, best practices, and successful strategies for building talent capacity. With this understanding, we developed long-term solutions to build a sustainable, federal permitting workforce for the future. While many of our recommendations are focused on permitting talent specifically, our work naturally uncovered challenges within the broader federal talent ecosystem. As such, we’ve included recommendations to advance federal talent systems and improve federal hiring.

Problem

Building permitting talent capacity across the federal government is not an easy endeavor. There are many stakeholders involved across different agencies with varying levels of influence who need to play a role: the Permitting Council staff, the Permitting Council members-represented by Deputy Secretaries (Deputy Secretaries) of permitting agencies, the Chief Environmental Review and Permitting Officers (CERPOs) in each agency, the Office of Personnel and Management (OPM), the Chief Human Capital Officer (CHCO) in each permitting agency, agency HR teams, agency permitting teams, hiring managers, and HR specialists. Permitting teams and roles are widely dispersed across agencies, regions, states, and programs. The role each agency plays in permitting varies based on their mission and responsibilities, and there are many silos within the broader ecosystem. Few have a holistic view of permitting activities and the permitting workforce across the federal government.

With this complex network of actors, one challenge that arises is a lack of standardization and consistency in both roles and teams across agencies. If agencies are looking to fill specialized roles unique to one permitting need, it means that there will be less opportunity for collaboration and for building efficiencies across the ecosystem. The federal hiring process is challenging, and there are many known bottlenecks that cause delays. If agencies don’t leverage opportunities to work together, these bottlenecks will multiply, impacting staff who need to hire and especially permitting and/or HR teams who are understaffed, which is not uncommon. Additionally, building applicant pools to have access to highly qualified candidates is time consuming and not scalable without more consistency.

Tracking workforce metrics and hiring progress is critical to informing these talent decisions. Yet, the tools available today are insufficient for understanding and identifying gaps in the federal permitting workforce. The uncertainty of long-term, sustainable funding for permitting talent only adds more complexity into these talent decisions. While there are many challenges, we have identified solutions that stakeholders within this ecosystem can take to build the permitting workforce for the future.

There are six key recommendations for addressing permitting workforce capacity outlined in the table below. Each is described in detail with corresponding actions in the Solutions section that follows. Our recommendations are for the Permitting Council staff, Deputy Secretaries, CERPOs, OPM, CHCOs, OMB, and Congress.

Solutions

The six solutions described below include an explanation of the problem and key actions our signal stakeholders (Permitting Council staff, Deputy Secretaries, CERPOs, OPM, CHCOs, OMB, and Congress) can take to build permitting workforce capacity. The table in the appendix specifies the stakeholders responsible for each recommendation.

Enhance the Permitting Council’s Authority to Improve Permitting Processes and Workforce Collaboration 

Permitting process, performance, and talent management cut across agencies and their bureaus—but their work is often disaggregated by agency and sub-agency, leading to inefficient and unnecessarily discrete practices. While the Permitting Council plays a critical coordinating role, it lacks the authority and accountability to direct and guide better permitting outcomes and staffing. There is no central authority for influencing and mandating permitting performance. Agency-level CERPOs vary widely in their authority, whereas the Permitting Council is uniquely positioned for this role. Choosing to overlook this entity will lead to another interagency workaround. Congress needs to give the Permitting Council staff greater authority to improve permitting processes and workforce collaboration. 

1. Enhance Permitting Council Authority for Improved Performance: Enhance provisions in FAST-41 and IRA by passing legislation that empowers the Permitting Council staff to create and enforce consistent performance criteria for permitting outcomes, permitting process metrics, permitting talent acquisition, talent management, and permitting teams KPIs.
2. Enhance Permitting Council Authority for Interagency Coordination: Empower the Permitting Council staff to manage interagency coordination and collaboration for defining permitting best practices, establishing frameworks for permitting, and reinforcing those frameworks across agencies. Clarify the roles and responsibilities between Permitting Council staff, Deputy Secretaries, CERPOs, and the Council on Environmental Quality (CEQ).
3. Assign Responsibility for Tracking Changes and Providing Guidance for Permitting Practices: Assign the Permitting Council staff in coordination with OMB responsibility for tracking changes and providing guidance on permitting practices in response to recent and ongoing court rulings that change how permitting outcomes are determined (e.g., Loper Bright/Chevron Deference, CEQ policies, etc.).
4. Provide Permitting Council staff with Consistent Funding: Either renew components of IRA and/or IIJA funding that enables the Council to invest in agency technologies, hiring, and workforce development, or provide consistent appropriations for this.
5. Enhance CERPO Authority and Position CERPOs for Agency-Wide and Cross-Agency Permitting Actions: Expand CERPO authority beyond the FAST-41 Act to include all permitting work within their agency. Through legislation, policy, and agency-level reporting relationships (e.g., CERPO roles assigned to the Secretary’s office), provide CERPOs with clear authority and accountability for permitting performance. 

Build Efficient Permitting Teams and Standardize Roles

In our research, we interviewed one program manager who restructured their team to drive efficiency and support continuous improvement. However, this is not common. Rather, there is a lack of standardization in roles engaged in permitting teams within and across agencies, which hinders collaboration and prevents efficiencies. This is likely driven by the different roles played by agencies in permitting processes. These variances are in opposition to shared certifications and standardized job descriptions, complicate workforce planning, hinder staff training and development, and impact report consistency. The Permitting Council staff, Deputy Secretaries, CERPOs, OMB, and the CHCO Council should improve the performance and consistency of permitting processes by establishing standards in permitting team roles and configurations to support cross-agency collaboration and drive continuous improvements.

1. Characterize Types of Permitting Processes: Permitting Council staff should work with Deputy Secretaries, CERPOs, and Permitting Program Team leaders to categorize types of permitting processes based on project “footprint”, complexity, regulatory reach (i.e., regulations activated), populations affected and other criteria. Identify the range of team configurations in use for the categories of processes.  
2. Map Agency Permitting Roles: Permitting Council staff should map and clarify the roles played by each agency in permitting processes (e.g., sponsoring agency, contributing agency) to provide a foundation for understanding the types of teams employed to execute permitting processes.
3. Research and Analyze Agency Permitting Staffing: Permitting Council staff should collaborate with OMB to conduct or refine a data call on permitting staffing. Analyze the data to compare the roles and team structures that exist between and across agencies. Conduct focus groups with cross agency teams to identify consistent talent needs, team functions, and opportunities for standardization.
4. Develop Permitting Team Case Studies: Permitting Council staff should conduct research to develop a series of case studies that highlight efficient and high performing permitting team structures and processes.
5. Develop Permitting Team Models: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop team models for different agency roles (i.e., sponsor, lead agency, coordinating agency) that focus on driving efficiencies through process improvements and technology, and develop guidelines for forming new permitting teams.
6. Create Permitting Job Personas: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop personas to showcase the roles needed on each type of permitting team and roles, recognizing that some variance will always remain, and the type of hiring authority that should be used to acquire those roles (e.g., IPA for highly specialized needs). This should also include new roles focused on process improvements; technology and data acquisition, use, and development; and product management for efficiency, improved customer experience, and effectiveness.
7. Define Standardized Permitting Roles and Job Analyses: With the support of Deputy Secretaries and CERPOs, Permitting Council staff should identify roles that can be standardized across agencies based on the personas, and collaborate with permitting agencies to develop standard job descriptions and job analyses.
8. Develop Permitting Practice Guide: In collaboration with Deputy Secretaries and CERPOs, Permitting Council staff should develop a primer on federal permitting practices that explains how to efficiently and effectively complete permitting activities.
9. Place Organizational Strategy Fellows: Permitting Council staff should hire at least one fellow to their staff to lead this effort and coordinate/liaise between permitting teams at different agencies.
10. Mandate Permitting Hiring Forecasts: Permitting Council staff should collaborate with the CHCO Council to mandate permitting hiring forecasts annually with quarterly updates.
11. Revise Permitting Funding Requirements: Permitting Council staff should include requirements for the adoption of new team models and roles in the resources and coordination provided to permitting agencies to drive process efficiencies.

Improve Workforce Strategy, Planning, and Decisions through Quality Workforce Metrics

Agency permitting leaders and those working across agencies do not have the information to make informed workforce decisions on hiring, deployment, or workload sharing. Attempts to access accurate permitting workforce data highlighted inefficient methods for collecting, tracking, and reporting on workforce metrics across agencies. This results in a lack of transparency into the permitting workforce, data quality issues, and an opaque hiring progress. With these unknowns, it becomes difficult to prioritize agency needs and support. Permitting provided a purview into this challenge, but it is not unique to the permitting domain. OPM, OMB, the CHCO Council, and Permitting Council staff need to accurately gather and report on hiring metrics for talent surges and workforce metrics by domain.

1. Establish Permitting Workforce Data Standards: OPM should create minimum data standards for hiring and expand existing data standards to include permitting roles in employee records, starting with the Request for Personnel Action that initiates hiring (SF52). Permitting Council staff should be consulted in defining standards for the permitting workforce.
2. Mandate Agency Data Sharing: OPM and OMB should require agencies share personnel action data; this should be done automatically through APIs or a weekly data pull between existing HR systems. To enable this sharing, agencies must centralize and standardize their personnel action data from their components.
3. Create Workforce Dashboards: OPM should create domain-specific workforce dashboards based on most recent agency data and make it accessible to the relevant agencies. This should be done for the permitting workforce.
4. Mandate Permitting Hiring Forecasts: The CHCO Council should mandate permitting hiring forecasts annually with quarterly updates. This data should feed into existing agency talent management/acquisition systems to track workforce needs and support adaptive decision making.

Invest in Professional Development and Early Career Pathways

There are few early career pathways and development opportunities for personnel who engage in permitting activities. This limits agencies’ workforce capacity and extends learning curves for new staff. This results in limited applicant pools for hiring, understaffed permitting teams, and limited access to expertise. More recently, many of the roles permitting teams hired for were higher level GS positions. With a greater focus on early career pathways and development, future openings could be filled with more internal personnel. In our research, one hiring manager shared how they established an apprenticeship program for early career staff, which has led 12 interns to continue into permanent federal service positions. The Permitting Council staff, Deputy Secretaries, and CERPOs should create more development opportunities and early career pathways for civil servants.

1. Invest in Training to Upskill and Reskill Staff: The Permitting Council staff should continue investing in training and development programs (i.e., Permitting University) to upskill and reskill federal employees in critical permitting skills and knowledge. Leveraging the knowledge gained through creating standard permitting team roles and collaborating with permitting leaders, the Permitting Council staff should define critical knowledge and skills needed for permitting and offer additional training to support existing staff in building their expertise and new employees in shortening their learning curve.
2. Allocate Permitting Staff Across Offices and Regions: CERPOs and Deputy Secretaries should implement a flexible staffing model to reallocate staff to projects in different offices and regions to build their experience and skill set in key areas, where permitting work is anticipated to grow. This can also help alleviate capacity constraints on projects or in specific locations.
3. Invest in Flexible Hiring Opportunities: CERPOs and Deputy Secretaries should invest in a range of flexible hiring options, including 10-year STEM term appointments and other temporary positions, to provide staffing flexibility depending on budget and program needs. Additionally, OPM needs to redefine STEM to include technology positions that do not require a degree (e.g., Environmental Protection Specialists).
4. Establish a Permitting Apprenticeship: The Permitting Council staff should establish a 1-year apprenticeship program for early career professionals to gain on-the-job experience and learn about permitting activities. The apprenticeship should focus on common roles shared across agencies and place talent into agency positions. A rotational component could benefit participants in experiencing different types of work.

Improve and Invest in Pooled Hiring for Common Positions

Outdated and inaccurate job descriptions slow down and delay the hiring process. Further delays are often caused by the use of non-skills-based assessments, often self-assessments, which reduce the quality of the certificate list, or the list of eligible candidates given to the hiring manager. HR leaders confront barriers in the authority they have to share job announcements, position descriptions (PDs), classification determinations, and certificate lists of eligible candidates (Certs). Coupled with the above ideas on creating consistency in permitting teams and roles and better workforce data, OPM, CHCOs, OMB, Permitting Council staff, Deputy Secretaries, and CERPOs should improve and make joint announcements, shared position descriptions, assessments, and certificates of eligibles for common positions a standard practice.

1. Provide CHCOs the Delegated Authority to Share Announcements, PDs, Assessments, and Certs: OPM and OMB should lower the barriers for agencies to share key hiring elements and jointly act on common permitting positions by delegating the authority for CHCOs to work together within and across their agencies, including with the Permitting Council staff.
2. Revise Shared Certificate Policies: OPM and OMB should revise shared certificate policies to allow agencies to share certificates regardless of locations designated in the original announcement and the type of hire (temporary or permanent). They should require skills-based assessments in all pooled hiring. Additionally, OPM should streamline and clarify the process for sharing certificates across agencies. Agencies need to understand and agree to the process for selecting candidates off the certificate list.
3. Create a Government-wide Platform for Permitting Hiring Collaboration: OPM should create a platform to gather and disseminate permitting job announcements, PDs, classification determinations, job/competency evaluations, and cert. lists to support the development of consistent permitting teams and roles.
4. Pilot Sharing of Announcements, PDs, Assessments, and Certs for Common Permitting Positions: OPM and the CHCO Council should collaborate with the Permitting Council staff to select most common and consistent permitting team roles (e.g., Environmental Protection Specialist) to pilot sharing within and across agencies.
5. Track Permitting Hiring and Workforce Performance through Data Sharing and Dashboards: Permitting Council staff, Deputy Secretaries, and CERPOs should leverage the metrics (see Improve Workforce Decisions Through Quality Workforce Metrics) and data actions above to track progress and make adjustments for sharing permitting hiring actions.
6. Incorporate Shared Certificates into Performance: OPM and the CHCO Council should incorporate the use of shared certificates into the performance evaluations of HR teams within agencies.

Improve Human Resources Support for Hiring Managers

Hiring managers lack sufficient support in navigating the hiring and recruiting process due to capacity constraints. This causes delays in the hiring process, restricts the agency’s recruiting capabilities, limits the size of the applicant pools, produces low quality candidate assessments, and leads to offer declinations. The CHCO Council, OPM, CERPOs, and the Permitting Council staff need to test new HR resourcing models to implement hiring best practices and offer additional support to hiring managers.

1. Develop HR Best Practice Case Studies: OPM should conduct research to develop a series of case studies that highlight HR best practices for recruitment, performance management, hiring, and training to share with CHCOs and provide guidance for implementation.
2. Document Surge Hiring Capabilities: In collaboration, the Permitting Council staff and CERPOs should document successful surge hiring structures (e.g., strike teams), including how they are formed, how they operate, what funding is required, and where they sit within an organization, and plan to replicate them for future surge hiring.
3. Create Hiring Manager Community of Practice: In collaboration, the Permitting Council staff and Permitting Agency HR Teams with support from the CHCO Council should convene a permitting hiring manager community of practice  to share best practices, lessons learned, and opportunities for collaboration across agencies. Participants should include those who engage in hiring, specifically permitting hiring managers, HR specialists, and HR leaders.
4. Develop Permitting Talent Training for HR: OPM should collaborate with CERPOs to create a centralized training for HR professionals to learn how to hire permitting staff. This training could be embedded in the Federal HR Institute.
5. Contract HR Support for Permitting: The Permitting Council staff should create an omnibus contract for HR support across permitting agencies and coordinate with OPM to ensure the resources are allocated based on capacity needs.
6. Establish HR Strike Teams: OPM should create a strike team of HR personnel that can be detailed to agencies to support surge hiring and provide supplemental support to hiring managers.
7. Place a Permitting Council HR Fellow: The Permitting Council should place an HR professional fellow on their staff to assist permitting agencies in shared certifications and build out talent pipelines for the key roles needed in permitting teams.
8. Establish Talent Centers of Excellence: The CHCO Council should mandate the formation of a Talent Center of Excellence in each agency, which is responsible for providing training, support, and tools to hiring managers across the agency. This could include training on hiring, hiring authorities, and hiring incentives; recruitment network development; career fair support; and the development of a system to track potential candidates.

Next Steps

These recommendations aim to address talent challenges within the federal permitting ecosystem. As you can see, these issues cannot be addressed by one stakeholder, or even one agency, rather it requires effort from stakeholders across government. Collaboration between these stakeholder groups will be key to realizing sustainable permitting workforce capacity.