In the summer of 2022, the California legislature and Governor Gavin Newsom successfully passed Senate Bill 846 to extend operations at the Diablo Canyon nuclear power plant in San Luis Obispo until at least 2030, avoiding the plant’s planned 2025 closure and preserving the state’s largest single source of clean electricity generation. Diablo Canyon provides around 9% of California’s annual electricity generation and around 17% of the state’s low-carbon electricity generation.

Despite the law’s passage, Diablo Canyon must clear several regulatory hurdles to continue operating to 2030 and beyond. Most importantly, the plant must secure an operating license renewal from the U.S. Nuclear Regulatory Commission (NRC), which would grant Diablo Canyon federal permission to continue operating for 20 additional years, not just five years. But before the NRC can consider Diablo Canyon’s license renewal application, the power plant must first secure state regulatory approvals from the California Coastal Commission and the Water Board. In the meantime, the plant has temporary permission to continue operating while it awaits its permit approvals.

Currently, the California Coastal Commission poses the most serious impediment to the state’s efforts to extend operations at Diablo Canyon—largely over the issue of fish larvae. Established in 1976, the California Coastal Commission is tasked with considering whether coastal developments align with the California Coastal Act’s policies for marine ecosystem protection. While the Commission is also considering other factors, a primary issue before the Commission is the power plant’s impact on small marine organisms that pass through the seawater cooling system’s intake filters. Changes in temperature and pressure over the five minutes of transit time required for “entrained” organisms to pass through the cooling system may kill a considerable fraction of the organisms unlucky enough to be drawn into the cooling system intake.

Yet the entire effort to assess marine ecosystem impacts represents a futile attempt to quantify the unquantifiable. Whether for zooplankton like copepods or krill or young salmon or the anchovies, saury, or rockfish eaten by albacore tuna, California fishery datasets dating back to 2000 or the early 1990s show no pronounced decline in fish or zooplankton populations. The Coastal Commission staff’s report offers no evidence whatsoever of declines in more local nearshore fish or marine life. In short, no data exists today that the Diablo Canyon plant’s annual intake of less than one cubic mile of seawater has had any measurable impact on any adult fish population.

Nevertheless, anti-nuclear groups and environmental groups have seized upon this opportunity to accuse Diablo Canyon of posing terrible and intolerable risks to California’s vibrant marine life, calling upon the Commission to overrule its own staff recommendation and deny permission for Diablo Canyon to continue operating.

While not necessarily swayed, the Commission may be showing some signs of indecision. Despite the clear public and environmental benefits of relicensing Diablo Canyon relative to the uncertain and minor impacts on marine life from the plant’s seawater cooling approach, the Coastal Commission decided last week to extend its deliberations, postponing a final vote on Diablo Canyon until December 2025 at the earliest. But from the perspective of a marine ecologist, the Commission frankly has no need to deliberate further. The Commission should make the obvious rational decision to support its own staff recommendation and grant Diablo Canyon’s extension as proposed.

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Missing the Forest for the Technocratic Trees

Much of this brow-furrowing scrutiny of Diablo Canyon’s impact on fish eggs and larvae is both excessively stringent and overly pessimistic, and may influence the Commission to make a decision that runs counter to the interests of the California public. The Commission’s fundamental scientific methodology for assessing seawater cooling system impacts is outdated, highly uncertain, and fails to take into account the broader context of the California Current ecosystem.

The issue before the Commission is a decision related to the continued operation of a single power plant, but any impacts on the coastal California Current marine ecosystem from seawater cooling withdrawals scale with total seawater entrainment. Yet, the retirement of other coastal power plants—mostly gas-fired turbines—has reduced total seawater entrainment from 17 billion gallons per day in 2007 to 4 billion gallons per day in 2025. Diablo Canyon presently uses seawater at a rate of 2.5 billion gallons a day.

Outrage by anti-nuclear and environmental groups over Diablo Canyon’s marine life entrainment impacts thus amounts to performative hand-wringing over unknown and likely negligible effects upon a California Current ecosystem that has remained one of the world’s most vibrantly productive and biodiverse coastal ocean regions over Diablo Canyon’s entire operational history. Regular National Oceanographic and Atmospheric Administration, academic reports, and grant proposals for future research make it clear that scientists see the dominant factors influencing this extensively-studied California coast ecosystem as fishing, climate change, and El Niño and La Niña variations, easily swamping any impacts from a single power plant.

At the same time, state regulators’ approach for assessing potential marine ecosystem impacts from seawater entrainment is also flawed. Specifically, the Commission’s scientific approach for estimating fish larvae entrainment—the Empirical Transport Model (ETM) using calculations of the Area of Production Foregone (APF)—is both highly uncertain for the Diablo Canyon coastal area specifically and clearly biased towards overestimation in general. This approach is not widely used to assess power plant cooling water intake impacts anywhere except California.

Indeed, this obscure entrainment marine impacts calculation may possess broader future implications for the state of California. In 2022, the Coastal Commission unanimously denied the Poseidon Huntington Beach desalination facility—a project supported by Governor Newsom—over the plant’s likely entrainment of marine organisms. Given that these ETM/APF calculations will likely influence permitting of future coastal facilities like desalination plants, the Commission should take decisive steps to significantly revise or replace the ETM/APF method for assessing entrainment impacts from proposed infrastructure projects.

Moving forward, an improved methodology could account for local ocean physics including at multiple depths, more accurately survey small marine organisms, and adopt average rather than maximum parameters for factors like entrainment mortality and larval development rates. Relative to a more reasonable scientific middle ground, overly conservative analyses add unnecessary costs and hold back infrastructure progress. Particularly when such assessments possess serious methodological shortcomings, the social costs of overactive environmental risk assessment likely far outweigh any marine conservation benefits.

When it comes to the imminent decision on Diablo Canyon’s permit application, the Commission must understand that the ETM/APF method itself subjects assessments of marine life entrainment impacts to considerable sources of error. Many of those sources of error, explained below, bias calculated metrics towards overestimation of ecosystem effects.

Some discharged cooling water is recirculated

First, the calculations do not account for the significant recirculation of discharged seawater from Diablo Canyon right back to the intake—2.5 billion gallons a day of output to match the 2.5 billion gallons a day taken in, with the cooling system outlet located just a couple hundred meters up the coast from the intake. Some volume of just-discharged water arguably ends up flowing back through the cooling system again. In practice, this recirculation likely reduces the volume of fresh seawater entrained over any given period of plant operation. However, the Commission’s impact assessments do not account for this factor at all.

Fish larvae may survive more than assumed

Second, the Commission staff pessimistically assume 100% mortality of all entrained organisms, despite themselves citing a 1983 study of the now-decommissioned Moss Landing power plant cooling system that observed mortality for some fish larvae species as low as 50%. In other words, for some species, the Commission might be overestimating impacts on entrained organisms by as much as a factor of two, based on an analysis at a totally different power plant whose operating practices 40 years ago may not resemble the characteristics of Diablo Canyon’s system. Furthermore, these analyses only studied larvae from a handful of species.

Additionally, the staff acknowledge that only a subset of marine life is even at risk of entrainment in the first place. Their past reports concede that “most abundant fishes in these studies had egg stages that were not likely to be entrained; they either have demersal/adhesive eggs or are internally fertilized and extrude free-swimming larvae. Squid paralarvae are also unlikely to be entrained because they are competent swimmers immediately after hatching.”

Sampling biased towards overestimation

A third set of issues relate to the ecological surveys that form the very basis for entrainment impact assessments in California over the past couple decades. The ETM/APF method strives to assess fish eggs, larvae, and plankton lost based on the furthest possible distance from which ocean currents could bring these organisms to the Diablo Canyon intake before they grow too large or become sufficiently strong swimmers to avoid entrainment by the seawater intake. This approach relies on local boat surveys of small marine organisms using fine mesh nets, paired with relatively simple assessment of local current speeds.

The problem is that the local boat sampling method used bottom-to-surface net casts at distances up to 3km offshore, creating a high risk of overestimating entrainment for larvae and eggs far offshore and at depths up to 250 feet. If clusters of fish larvae further from shore and at deeper depths account for a disproportionate weight of the small organisms sampled using nets, then this sampling approach may attribute Diablo Canyon with entrainment of organisms that are actually quite safe from the intake (Figure 1). Diablo Canyon’s seawater intake is located in a restricted shallow artificial bay less than 20 feet deep, at a point of the California coast where the water depth increases rapidly to 114 feet at 1000 yards and to 162 feet at 2000 yards. Such surveys may thus be predominantly sampling deeper organisms subject to slower current speeds that would not in fact place them at high risk of entrainment.

On a longer timescale, sampling uncertainty is skewed by the massive seasonal variability in fish larvae concentration as shown by the surveys themselves. Fish larvae populations predictably peak in the spring, when upwelling ocean nutrients coincide with better light conditions and warmer temperatures for phytoplankton and algal growth. Yet the entrainment study calculations appear to calculate ecosystem impacts using average or mean larval concentrations that are highly sensitive to peak values, when median values might more accurately reflect conditions outside of spring months. Such choices not only disproportionately influence entrainment calculations, but also neglect to consider the reduced real-world ecological impact of entrainment during springtime when overall larval concentrations are richest and regional food availability is superabundant. Insofar as larvae entrained by Diablo Canyon during spring removes some food matter from the ecosystem, this is inconsequential at a time of the year when the environment is hardly food-limited. The scientific analysis also implicitly assumes that dead larvae and plankton expelled by the cooling system possess no ecosystem value as a food source, when they most certainly do.

Ocean physics reduce the area at risk

The fourth set of issues relates to the methodology’s oversimplistic consideration of local physical currents. Importantly, the ETM/APF method doesn’t account for the known tendency of nearshore currents in this part of the California Coast to change speed and direction regularly. The California Current is a highly dynamic physical environment with strong seasonal and sub-seasonal variation, coupled with a rugged coast and islands in the immediate vicinity of Diablo Canyon that also affect local hydrodynamics. Such complexities likely significantly reduce the APF—the effective surrounding area from which marine organisms could be entrained—while giving larvae more time to become strong swimmers. Yet the studies the Commission references assume that currents in any direction towards Diablo Canyon remain steady for the several days over which new larvae are at greatest risk, effectively maximizing the calculated APF.

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Obvious Benefits Outweigh Undetectable Marine Impacts

Ultimately, the entire approach for estimating entrainment impacts on marine life is imprecise, attempting to assess effects that are essentially beyond our scientific ability to accurately isolate amidst far larger seasonal, interannual, and long-term changes in the region. Commission staff writings essentially admit as much: “We do understand generally that changes in marine life populations are affected by a wide range of factors—ocean temperatures, rates of upwelling and availability of nutrients, El Niño versus La Niña periods, etc., which makes it highly speculative to associate ETM/APF results with changes in population.” Indeed, Diablo Canyon surveys suggest that El Niño years reduce the size of the crudely-calculated affected ocean area by 25%. To speculate about the adult fish population effects of a marginal loss of larvae on top of typical expected losses from predators, disease, competition, and the harsh natural environment is to hunt for a needle in a haystack of needles.

For now the Commission has, based on their own discretion and interpretation of California statute, deliberately chosen to err on the side of pessimistic bias by utilizing the ETM/APF methodology. Meanwhile, the broader California context has seen decreasing marine impacts from seawater cooling entrainment over the past decade by a factor of more than four, with power plant seawater usage dropping from 17 billion gallons per day in 2007 to 4 billion gallons per day today. In any case, coastal seawater entrainment for cooling is a consideration whose ecological effects are utterly dwarfed within the vast variations in the California Current environment caused by factors like fishing, climate change, natural climate variability, agricultural runoff, and coastal ship traffic.

One can only hope that the California Coastal Commission makes the rational decision not to overfixate on uncertain impacts that are both small relative to other ecosystem factors and scientifically impossible to detect. In comparison, the clean energy, economic, and societal benefits of Diablo Canyon are quantifiable. Yielding to anti-nuclear activists’ demands that the plant close would sacrifice an amount of clean electricity generation greater than that lost by demolishing every wind turbine across California. The Commission should act on its own staff’s recommendation to approve PG&E’s coastal development permit to extend operations at Diablo Canyon. Despite adopting a relatively pessimistic approach to gauging potential impacts, the staff has favorably assessed PG&E’s “out-of-kind” mitigation proposal to compensate for the loss of marine organisms from cooling water intake operations. Overestimation of marine life impacts only shifts this calculus further in Diablo Canyon’s favor, making the staff’s recommendation to approve PG&E’s permit application all the more appropriate.

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Conflict between supporters and opponents of the Abundance movement has generated such energy that engineers might dream of harnessing it for society’s benefit. But in an intriguing coincidence, both proponents and critics of abundance may largely agree on the issue of energy itself, at least when it comes to solar power.

Sparring commentators of all stripes share a conviction that solar energy will flourish nationwide in their desired future. The text of Abundance by Ezra Klein and Derek Thompson hints at vast, cheap solar energy from coast to coast if government permitting barriers holding back commercial solar development can be alleviated. In response, critiques by Isabella Weber and Sandeep Vaheesan disagree with the means but not the ends, condemning “tax credits and other enticements” to “uncoordinated private companies” but endorsing the goal of solar power growth albeit with a focus on “public and nonprofit solar deployment.” Yet, ironically, both sides’ shared belief that “solarmaxxing” is the key to achieving their societal aspirations is at best incomplete and at worst overlooks the possibility of counterproductive effects.

A significant risk thus exists in pronouncements like environmental writer Bill McKibben’s latest shorthand: “we're... used to thinking about [renewable energy] as the Whole Foods of energy. It's nice, but pricey. Actually, it's the Costco of energy. It's cheap, it's available in bulk, it's on the shelf ready to go.” Such messaging often leaves electricity sector practitioners shifting uncomfortably, well aware that delivering cheaper electricity for working-class Americans is not actually as simple as adding mass solar. In many possible futures, clumsy policy interventions on solar’s behalf could well make electricity more expensive for consumers.

This is neither a validation of anti-renewable smears nor a claim that solar poses an inherent threat to either abundance or its progressive alternative visions. Solar is assuredly a strategically vital sector for America—one that pursues self interest no more than any other slice of the energy world and can drive rapid progress if harnessed well. Solar’s modularity is genuinely revolutionary, delivering scale at both the Jeffersonian level of the rural homeowner and the Hamiltonian level of the gigawatt-scale “solar farm.”

But, make no mistake, political thinkers debating America’s future should avoid too narrowly conflating solar success with good energy policy. The political and technical messiness of the grid and the ways such factors may rebound onto national politics will pose complex challenges to their theories of change and power. Assuming that vastly more of one’s favorite flavors of solar will easily solve these problems is to take a risky shortcut in thinking.

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Reconciling solar and energy abundance

Among market-oriented proponents of abundance who are also interested in making progress on climate change, solar power seems to offer an all-in-one solution. Remove the regulatory and permitting obstacles standing in solar’s way, and a solar revolution will deliver cheap energy, economic growth, and political power via an approving electorate. In the very first paragraph of Abundance, Klein and Thompson promise “a cocoon of energy so clean it barely leaves a carbon trace and so cheap you can scarcely find it on your monthly bill.” As for how to get there, prominent solar prophet Jesse Peltan offers the prescription: “Cut the red tape, improve price signals, and you’ll see solar + storage EVERYWHERE.”

Many abundance thinkers will clarify that their energy vision isn’t purely deregulatory, but absolutely also includes stronger state capacity to deploy new renewables nationwide. The abundance movement at large is much more open to nuclear power, geothermal, carbon capture, hydroelectricity, and even gas-fired generation than are solar enthusiasts on the environmental left. But many in Camp Abundance gravitate towards solar, wind, and batteries based on a justifiable stance that these modular resources can deploy the fastest to meet growing energy needs over the next several years.

Meanwhile, progressive and socialist critics of abundance correctly note that government interventions and regulatory streamlining to renewables’ benefit orient government processes and capabilities in service of for-profit companies. This is hardly as nefarious in principle as puritanical Green New Deal advocates implied by disparaging tax credits from the Inflation Reduction Act and other abundance-coded policy ideas as handouts for corporations. But numerous voices have called upon Klein and Thompson to acknowledge that many private interests will not neatly align with political goals of clean, abundant energy for all.

A robust energy abundance plan must control the profit-seeking impulses of energy corporations insofar as they seek to rig market regulations and energy system operation in their favor. The ecosystem of relevant actors is large—private independent power producers and asset managers, energy project developers, electricity market traders, retail power companies, utilities, rooftop solar companies, grid service providers, large tech companies, and more. Some focus specifically on renewables, others on fossil thermal power, and some transact in all types of energy. All will play some role along the path to energy abundance, but each will also pursue narrow self-interests.

An asset manager owning forty solar farms prioritizes revenue from electricity sold with little incentive to prevent power grid failures unless public policy dictates otherwise. A solar developer prioritizes building projects fast and at low cost, and may oppose grid connection fees to pay for transmission upgrades even if that means higher electric bills for households. A real-time energy trader may welcome volatility and spikes in wholesale power prices and will pursue all opportunities for arbitrage that market rules allow.

Joe Weisenthal’s review of Abundance even points out the curious case of an oil and gas magnate calling for $1 trillion of public-private spending on wind turbines in 2008, potentially motivated by a recognition that natural gas power plants would benefit from a balancing role alongside wind power. Meanwhile Brett Christophers’s book on why cheap renewables have driven limited decarbonization progress discusses how such balancing by gas plants often leaves electricity prices exposed to high fuel price volatility despite growing wind and solar generation.

With grid costs necessarily socialized between generators, taxpayers, utilities, and customers, many outcomes are possible where working-class ratepayers wind up disappointed with political leaders’ promises that the solar revolution will lower their electric bills. Leaders like California governor Gavin Newsom, now prominently flirting with abundance, are playing with fire by trumpeting simplistic solar public benefits narratives while his voters’ electric bills rise.

First, “more supply means cheaper prices” is only true to a point for solar energy that saves fuel costs and generates during daytime with a midday peak. Electricity is not perfectly fungible across space and time, and battery storage is not omnipotent in its ability to solve solar oversaturation during peak sunlight that discourages further solar investment while leaving unresolved the need to rely on more expensive generation like gas during mornings, night, or cloudy weeks.

A resilient and cost-efficient power system will thus leverage a diversity of resources alongside solar. If abundance is to also pursue decarbonization long-term, this will require ambitious efforts now to elevate complementary energy technologies like nuclear, geothermal, and long-duration storage. Some of these technologies may pose competition to solar that solar interests may well even resist.

A solarmaxxing agenda must also choose between maximizing solar manufacturing versus solar deployment. Deployment maximalism remains predicated on mass solar and battery imports from China that carry trade dependence and human rights risks. This poses uncomfortable political questions around ethical sourcing and why solar can’t be manufactured domestically if it is so clearly the technology of the future. Alternatively, a manufactured-in-America solar deployment agenda demands ambitious efforts to protect and expand U.S. and allied solar manufacturing, imposing higher equipment costs on solar developers in the near term.

Then consider the important yet more technical realm of wires, which typically make up an increasingly large share of a user’s electricity bill. An energy system more reliant on large, far-flung solar farms requires a sizable network of additional wires with its own cost implications. And while a large ecosystem of distributed energy, vehicle-to-grid, and virtual power plant companies and enthusiasts vocally asserts that their solutions can obviate the need for new centralized generation or transmission and their associated costs, these claims remain untested in operational practice.

Progress will demand hard questions of both megasolar and roof solar proponents. Are today’s residential distribution networks equipped to export rooftop solar electricity back to the grid, and what would such upgrades really cost relative to large power plants? Would the behavior of a large pool of rooftop solar, home battery, and electric vehicle assets be predictable enough for a grid operator to rely upon them as a virtual power plant? If Las Vegas is to depend on a network of large solar farms, can the system avoid an outage if a landslide severs a transmission line carrying a gigawatt of solar into the city? These are mandatory questions to consider when contemplating the future of an electric grid that sustains the livelihoods and well-being of Americans every millisecond of the year.

Here, the budding abundance community would do well to embrace its expressed love of deep wonkery a little more. Abundance ideas have drawn growing attention from generalist policy pundits, and energy abundance seems deceptively accessible to many at first. But in practice, the complexities of electricity markets and systems make the puzzle of cheap power for the people unexpectedly difficult.

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Solar is not a shortcut for a left clean energy agenda

More left-leaning progressive and environmentalist critics of abundance must also reckon with the shortcomings of their own overoptimistic solar worldview and the limits of solar measures for providing cheap clean energy to all.

First, much of the mainstream environmental movement still operates under a longstanding mistaken conviction that variable renewables and energy storage can solve all problems at low cost. Misled by a feedback loop of biased and performative research and oversimplified activist narratives from ten to fifteen years ago, many have parroted the omnipotence of 100% wind, solar, and storage systems into a pseudoscientific axiom. Ecosocialists and environmentalists can thus reject uncomfortable technologies like nuclear power, carbon capture, large hydroelectric dams, and especially any continued reliance on the grid balancing services of gas power plants as wholly unnecessary.

Such convenient, ideologically-pure nonsense never possessed any rational basis. In fact, persistent reinforcement of 100% renewable myths has done more harm than good to the cause of affordable clean power for all by justifying opposition to energy and transmission projects of every stripe and counterproductive early shutdowns of many nuclear power plants. The final defeat of such technologically absolutist 100% renewable distractions in debates over energy policy cannot come a moment too soon.

Just as abundance stans may prove susceptible to solar-coded corporate talking points, progressive groups are similarly vulnerable to plucky community energy special interests who appeal to their small-is-beautiful political aesthetics. Rural electricity cooperatives now often resist cost contributions to interregional transmission plans. Community choice aggregation offers beguiling alternatives to utility electricity promising “energy sovereignty” for communities, while in reality letting localities symbolically procure renewable electricity to claim dubious climate credentials and creating unnecessary conflicts with utilities on how to split the cost of maintaining the steel and aluminum of the grid itself.

Another obvious example of this involves generous feed-in tariff subsidies for residential rooftop solar. A wide array of solar installation companies and NGOs will argue that sizable rooftop solar incentives will help increase U.S. households’ independence from the grid and lower system costs. But in reality, such incentives have rewarded disproportionately wealthy homeowners while raising electricity rates for less affluent utility customers. Small and beautiful and distributed and micro-gridded are often mental shortcuts that skate over many techno-economic difficulties and don’t always correlate with a fairer, more reliable, and affordable electricity system.

Conversely, private and public power utilities make for an easy target for activists and demagoguery. It is easy for commentators to fan the flames of existing public resentment and villainize private investor-owned monopolies like Pacific Gas and Electric, Dominion Energy, or Southern Company. But, at a certain point, automatic activist blame of utilities becomes a shortcut for dodging deeper challenges. Utilities are not entirely responsible for electric bill price hikes that reflect factors like wildfire risk reduction, infrastructure replacement, falling numbers of ratepayers, or boring old fuel costs. Nor is it entirely the fault of utilities that they cannot replace all the fossil generation in their portfolio as fast as activists demand. Should the revolution successfully dismantle all monopoly utilities, many of these challenges will not go away.

Just as it is misleading to automatically label monopoly utilities as enemies, left voices should also resist automatically opposing the idea that the state should seek to supply cheap power to energy-intensive industries. Affordable electricity rates that enable the development and survival of data centers or base metal refineries can unlock considerable benefits that revitalize local economies and create job opportunities for workers. Fair distribution of economic windfalls is never assured, but the grid’s big industrial customers often are—or could become—the linchpin of communities and blue-collar union locals.

Finally, critics like Isabella Weber are also wrong to strongly reject a “top-down model” for energy infrastructure buildout and energy transition. It is time to accept that the more urgent and large one’s project of electricity sector reform and society-wide power sector decarbonization, the more likely the need for heavy top-down planning.

At the end of the day, most agree that each region’s maze of transmission and distribution wires constitute a natural monopoly, impossible to devolve into competing mom-and-pop cooperatives and microgrids. Major changes to generation, wires, and power flows demand that a bunch of power systems electrical engineers analyze and run a battery of models on any future proposed grid, make sure that said grid is not liable to literally explode, and mandate changes based on their findings. Even the most “Jeffersonian” opponent of centralized energy governance should at least consider whether leaning into such inherently top-down structural factors might prove more worthwhile. Rooftop solar and community power may be useful assets, but they are not a manifesto.

Into the thicket of wires

Very few have remarked on the potential contradictions behind solar’s place of honor on opposing sides of the abundance debates. One recent essay by the left abundance-curious Fred Stafford, Matt Huber, and Leigh Phillips does call out both neoliberal underestimation of how vested interests goals’ may diverge from abundance as well as the socialist left’s counterproductive defenses of regulatory bureaucracy and small-is-beautiful energy visions. As the many such complexities of energy markets, the grid, and utility electricity rates make clear, the path to lowering household electric bills is far from easy.

Robust transmission networks will be crucial to solving this challenge, providing public electron highways that solar projects bear some responsibility to help pay for. Cracking the energy abundance problem long-term will also require developing future-proof substitutes—nuclear, geothermal, hydrogen—for the flexible fossil generators serving as solar’s essential complementary resource on the grid today. Policymakers will have to demand compromises from solar stakeholders to accommodate these priorities, even as solar power climbs to unprecedented heights.

It may be politically unwise to promise cheaper electricity to voters at all. Certainly the nuclear sector has received an earful of skepticism for decades now thanks to old 1950s boasts that abundant nuclear power would make electricity “too cheap to meter.” Given that much of America’s grid infrastructure is aging, combined with the vast construction challenge of meeting growing energy demands and shifting to cleaner forms of energy, a dangerously honest political message might be that voters should expect electricity to get more expensive before it gets cheaper in the future.

In any case, handwaving about solar using aspirational generalities will only go so far. Anyone who seriously believes that their political worldview offers energy abundance must be prepared to defend and reexamine those beliefs throughout a gauntlet of electricity grid, power market, and energy technology tests of faith. The long-term coherency of their politics will hinge upon it.

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Collectively, the countries of sub-Saharan Africa (SSA) hold an estimated 30% of the world’s critical minerals by tonnage. African leaders have long hoped to translate resource endowments into economic development by refining mineral assets into higher-value chemicals and metals upon which semiconductors, communications equipment, clean energy, and other modern technologies rely. Instead of high-value products, however, resource-rich countries in SSA still often ship minimally processed mineral intermediates overseas, failing to realize much of the economic value of their geologic assets.

Conventional explanations as to why these countries have not been able to fully capitalize on their mineral holdings emphasize the same factors: financial uncertainty from political and social risks, limited access to regional markets, and inadequate buildout of clean energy. Attention towards these considerations seeks to advance common best practices for the nations of SSA and foster a more attractive environment for downstream industries relative to the business climates of wealthier, better-resourced countries.

But, development roadmaps entrenched in propositions of innovative financial vehicles, regional trade policy, and commodity market analyses overlook the fundamental need for fossil fuels to produce both the required thermal energy and industrial chemicals for value-additive mineral processing.

Competing with the United States or China in value-added processing is no simple task; hence, developmental economists and strategists wisely articulate solutions around sub-Saharan Africa’s resource strengths (e.g., abundant renewable electricity and mineral resources) to leverage the region’s comparative advantages. Many such strategies also focus heavily on improving SSA’s overall financing environment, emphasizing the need for greater mineral sector prioritization from multilateral national banks. Other common points include driving more integrated and regional growth via collaboration between SSA countries and continued efforts to expand electricity infrastructure as well as developing a trained local workforce by expanding technical collaboration with advanced economies. These suggestions are often accompanied by a mountain of analytical evidence, intending to communicate the enormity of the market opportunity available to Africa by processing its minerals to serve the clean energy economy.

These are vitally important priorities at a high level, but they often do not engage sufficiently with the granular engineering challenges of nurturing domestic chemical and metallurgical industries.

To illustrate the technical necessity of fossil fuels and industrial chemicals in real-world mineral processing, we explore the mineral industries of the Democratic Republic of the Congo (DRC), Guinea, and Mozambique with a quantitative, engineering-driven analysis. Each nation’s value-adding aspirations face unique hurdles linked to their different mineral resources and varying stages of development. But across the board, the need for increased petrochemical investment rings clear.

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Cobalt and Copper in the Democratic Republic of the Congo

The DRC is the world’s top producer of mined cobalt and the second-largest producer of both mined and refined copper. This corresponds to 220 ktpy (thousand tons per year) of mined cobalt (75% of global supply), 3,300 ktpy of mined copper (15% of global supply), and 2,500 ktpy of copper metal (9% of global supply). Despite its mineral wealth, the DRC is one of the poorest countries in the world; the World Bank estimates that the DRC is home to one in six people in sub-Saharan Africa living in extreme poverty. A recent large-scale offensive by the M23 armed militant group, allegedly aided by the neighboring Rwandan government, disrupted a large fraction of the DRC’s copper and cobalt mining. In many cases, mining has not yet resumed.

The DRC currently exports cobalt in minimally processed forms, such as cobalt ore concentrate and cobalt hydroxide, but exports copper as metal that sits at the end of the copper value chain. For cobalt, a value-adding strategy would target production of battery-grade cobalt sulfate; however, no additional mineralogical processing can increase the value of the refined copper metal that the DRC already exports.

Figure 1 depicts the additional processing stages needed to produce battery-grade cobalt sulfate from the DRC’s cobalt hydroxide: leaching followed by evaporation and crystallization.

Figure 1: Major supply chain processing stages for copper-cobalt ores found in the DRC. Current practices in the DRC are shown in navy blue; subsequent value-adding processes are shown in light blue-green.

The evaporation and crystallization stages of cobalt sulfate production require demanding heat inputs (see Figure 2) that far exceed the DRC’s current utilization of thermal energy for industry. Heat constitutes only 0.2% (1.4 MW-thermal) of the total energy used by DRC industries—not enough to fuel a standard cobalt sulfate facility for even half a year.

Figure 2: Energy inputs (electric and non-electric) required to produce one metric ton of cobalt or copper material from the previous stage in the supply chain. Supply chain stages were selected for their specific relevance to the DRC’s cobalt and copper industries and for the DRC’s sulfide/oxide ore deposits.

There is no practical way to generate sufficient heat for cobalt sulfate synthesis without fossil fuels. Yet, the DRC neither imports nor uses any natural gas or coal, and offshore oil rigs extract a modest 25,000 barrels per day of petroleum for export instead of domestic use. Of the petrofuels that the DRC does consume, 98% are used in the transportation sector.

Altogether, the DRC’s inability to supply thermal energy to industry appears to be among the most restrictive hurdles facing its critical mineral value addition goals. To this end, the DRC must develop fossil fuel infrastructure—like pipelines and port terminals—to reliably supply industrial heat and train a workforce in the engineering and operational control needed for downstream cobalt processing. Yet, in an export-driven economy powered by hydroelectricity, there is little existing demand to justify domestic investment in fossil fuel infrastructure.

Development finance institutions are equipped with access to capital and statutory aims that are well-suited to tackle this dilemma. But, first, many would need to reevaluate their current stances against fossil fuel investments. A natural gas import terminal co-located with a cobalt sulfate plant could be an effective pilot investment in the DRC. Nearby gas power plants could also ensure that the cobalt sulfate plant and potential future port developments have stable electricity access. Regardless of the specific provisions, withholding fossil fuel investments in the DRC places upper limits on economic development that no regional trade agreement or creative financing method can remedy as effectively.

Aluminum and Alumina in Guinea

Guinea’s deposits of bauxite—the geologic source of aluminum—are the largest in the world. Guinea also mines the most bauxite in the world—around 130,000 ktpy or almost 30% of global supply. Despite its fruitful bauxite mining enterprise, Guinea exports 99.75% of its bauxite for processing abroad, over 80% of which is purchased by China.

Bauxite is processed by refining it into alumina (aluminum oxide) via the Bayer process (Figure 3). Guinea is home to only one alumina refinery, the Friguia complex. Friguia has a recent history of inconsistent operation, but Guinea plans to open another far larger refinery in 2027 with backing from a Chinese firm.

Alumina is smelted into aluminum metal by electrolyzing alumina in a bath of molten cryolite salt. The required temperatures of over 1000℃ are achieved exclusively using electricity.

Figure 3: Major supply chain processing stages for bauxite ores found in Guinea. Current practices in Guinea are shown in navy blue; subsequent value-adding processes are shown in light blue-green.

As a whole, the aluminum supply chain is notoriously energy-intensive. Compared to Guinea's current bauxite mining practices, processing bauxite into alumina demands orders of magnitude more energy, and aluminum smelting requires even more (Figure 4).

Comparatively high thermal energy requirements for alumina refining indicates that refining may exceed Guinea’s capabilities. However, Guinea’s planned alumina refinery (with a capacity of 1,200 ktpy) would use 650 MWh-thermal/yr, about 10% of the country’s current industrial heat energy consumption. In the context of Guinea’s nascent industrial sector, this is a relatively reasonable value for an medium-sized alumina refinery. Thermal energy access, therefore, doesn’t appear to pose an immediate barrier to building another alumina refinery in Guinea. But more ambitious buildout beyond a single refinery would require substantially increasing industrial fossil fuel access.

In contrast, Guinea’s electrical generation capacity falls far short of supporting even a single aluminum smelter. After completion of the planned alumina refinery and assuming it has 50% average utilization, Guinea would produce around 875 ktpy of alumina. A theorized smelter handling half of this would consume 3.5 TWh-electric/yr—20% more electricity than all of Guinea generated in 2023, and 10x the electricity used by the industrial sector.

Beyond feasibility challenges, aluminum’s electricity demands would raise separate financial and environmental hurdles. Electricity makes up about 40% of smelters’ operating costs, and generating electricity for smelting released 600 Mt CO₂-e in 2023, roughly 4% of global CO₂ emissions from the power sector for that year. Major aluminum-producing nations like Russia, Canada, Norway, Iceland, and Brazil meet the high electricity demands for smelting, reduce electricity costs, and lower the carbon footprint of their aluminum by pairing smelters with hydropower. In the long-term, Guinea could adopt a similar strategy by leveraging its own substantial hydropower potential.

Even with such an arrangement, fossil fuels are still needed for a globally competitive aluminum smelter. Coal and petroleum are irreplaceable chemical precursors to the carbon anodes used by today’s smelters. Most smelters produce these fossil-derived anodes on-site, as importing them would balloon procurement costs that already make up 12-20% of smelters’ operating costs.

Guinea could also take advantage of the gallium content in their mined bauxite, as most of the world’s gallium is obtained as a byproduct during alumina refining. This has especially salient implications for Guinea’s bauxite industry, as raw material exports mean the industry loses out on the value of producing gallium, alumina, and aluminum. Very little gallium is made each year because it is found in extremely low concentrations (about 50 parts per million or 0.005%) and is exceedingly difficult to extract. However, even conservative estimates suggest that the bauxite Guinea mined in 2024 contained about 2,000 tons of recoverable gallium—over 2.5x as much as was produced globally that year (760 tons). Due to gallium’s strategic value, industry closely guards the process details needed to estimate the feasibility of gallium production in Guinea. From what little information can be inferred, gallium extraction would require the use of highly specialized resins in bauxite processing facilities much larger than the Friguia complex. It could prove fruitful for Guinea to leverage the strategic role of its gallium when pursuing alumina refinery investments, especially since China produces 99% of the world’s gallium and has recently banned gallium exports to the United States.

Gallium or not, a productive and vertically-integrated aluminum supply chain in Guinea’s future is possible but is contingent on increased fossil fuel access. Future expansions to alumina refining need fossil fuels to supply process heat, and an aluminum smelter uses fossil fuels as chemical feedstocks for carbon anodes. Moreover, the enormous electricity demands of aluminum smelting requires considerable expansions to Guinea’s generation of reliable electricity. A smelter’s electricity could be supplied using local hydropower, but a realistic plan to grow Guinean industry around clean electricity starts with using a non-negligible amount of petrochemicals.

Graphite in Mozambique

Mozambique was the second largest producer of natural graphite in 2023, yet it hosts only one active mine: the Balama mine, owned by Australian company Syrah Resources. The Balama mine broke ground in 2017 and processes graphite ore on-site to produce flake graphite concentrate. Syrah exports this intermediate product to its Vidalia facility in Louisiana which produces anode active material (AAM) for nearby U.S. battery manufacturers.

Figure 5: Major supply chain processing stages for graphite ores found in Mozambique. Current practices in Mozambique are shown in navy blue; subsequent value-adding processes are shown in light blue-green.

Unlike the chemical treatments for cobalt, copper, and aluminum, most value added to graphite is derived from the physical resizing or reshaping of graphite particles. The processing steps immediately following the Balama mine’s current operations are micronization and spheroidization which, respectively, entail grinding graphite particles into smaller sizes then pressing the particles into spheres. Though electricity use increases in these downstream steps, the total energy intensity is quite low compared to other minerals (Figure 6).

Figure 6: Energy inputs (electric and non-electric) required to produce one metric ton of graphite material from the previous stage in the supply chain. Supply chain stages were selected for their specific relevance to Mozambique’s graphite industry. For context, recall that cobalt sulfate production and alumina production require several MWh of electricity and/or thermal inputs per ton of output.

Producing unpurified spherical graphite from Mozambique’s graphite ore concentrate would require 19 GWh-electric/yr, less than 0.2% of Mozambique’s current industrial electricity consumption. Further, existing graphite ore concentrate processing requires more thermal energy per ton than spheroidization would. Unlike the DRC and Guinea, Mozambique’s potential to move up the graphite value chain is not limited by energy access .

Instead, non-energy factors have played an outsized role in deterring downstream graphite facilities. Most prominently, conflict with armed militant groups in the vicinity of the Balama mine in late 2024 forced Syrah to fully halt mining operations. A tentative restart is expected soon—but only after 6 months without production and with continued operational uncertainty moving forward.

Supply arrangements with customers also play an outsized role in determining where graphite value addition takes place. Syrah’s U.S.-based facility, for instance, contracted to supply battery-grade graphite to Tesla’s U.S.-based electric vehicle factories. This proximity to customers minimizes lead times, lowers transport costs, and reduces variability in supply—advantages that outweigh the benefits of processing near the mine itself.

To Compete, Sub-Saharan African Countries Need Abundant Energy

Most mines follow a similar procedure, regardless of the target mineral—excavating, crushing, then concentrating ores. As one moves further downstream in the mineral value chain, processing techniques increase in variety and complexity. Additional refining often demands applying orders of magnitude more electricity, process heat, and chemicals. Solutions to developmental barriers to downstream processing capacity in sub-Saharan Africa must move past blanket moratoriums on fossil fuel infrastructure to meet the heterogeneous needs of African economies.

Cobalt value addition in the DRC calls for enormous growth to domestic petrofuel supply chains, while Guinea needs to increase industrial access to both electrical and thermal energy if it hopes to refine more alumina and begin to smelt aluminum metal. Meanwhile, Mozambique’s graphite industry is exceptional in terms of the relative availability of both thermal and electrical energy, making the chief limitations to graphite value addition economic and political in nature rather than energy-related.

Certainly, Guinea and the DRC also face non-technical challenges like those in Mozambique. In all three countries, social and political instability discourages private investors, and there may not exist sufficient local labor with the proper experience to construct and operate chemical or metallurgical facilities. The comparative value proposition of developing projects in already-mature industrial environments partly explains why downstream processing continues to get sited abroad.

China’s market dominance—which spans the entirety of the downstream minerals supply chain—has created close business and logistical linkages between Chinese processing facilities and end-use battery and car manufacturers, further limiting competition from countries like DRC, Guinea, and Mozambique. To provide perspective on the sheer scale of integration between Chinese firms, China is the world’s largest producer of every value-added product downstream from the covered industries in all three countries: copper, cobalt chemicals, cobalt battery cathodes, alumina, aluminum, graphite ore concentrate, spherical graphite, and graphite anodes.

Downstream facilities sited amidst such a developed industrial ecosystem also benefit from proximity to suppliers of chemicals needed for advanced processing. In contrast, the DRC struggles with high transportation costs and logistical challenges to import sulfur and sulfuric acid, which are both necessary for cobalt ore mining and processing. Alumina refineries in Guinea would have to import caustic soda and quicklime at a considerable scale to operate, while Chinese refineries can source from nearby Chinese suppliers at lower costs and with greater reliability. Mozambique is less impacted by process chemical supply chains because graphite micronization and spheroidization are mostly mechanical; however, one can assume that facilities based in Mozambique would have to import the unique machinery needed for these processes from China, given Chinese production of 99% of the world’s spherical graphite.

Bringing value-added processing to sub-Saharan Africa will require local facilities able to compete with existing facilities in places like China and the United States. Observers have devoted considerable attention to the financial and political barriers involved, often assuming that once they can be overcome, co-location with raw minerals and access to clean electricity are ample incentives to attract firms. But technical analysis emphasizes that these widely extolled factors represent just a small fraction of industry’s needs that remain under addressed in most minerals strategies—the most salient of which is the need for fossil fuels in chemical and metallurgical manufacturing.

To be sure, African countries should endeavor to substitute fossil fuels with clean alternatives wherever possible. Already, the continent is poised to develop industries using far cleaner pathways than those taken by existing industry in developed countries today. But there are immutable technological and economic limitations on the extent to which petrochemical substitutions can occur, especially amidst the intense competition of commodity markets. Both electrical and thermal energy infrastructure are vital prerequisites for countries in sub-Saharan Africa to truly take advantage of their mineral resources. And failure to pragmatically acknowledge the need for fossil fuels for modern economic growth risks jeopardizing both African development and the clean energy transition at large.

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It’s official, coal is now a ‘mineral’, at least according to an executive order, announced in April. The Trump administration established the ‘mineral’ designation, at least in part, to be able to extend critical mineral benefits—priority attention for permitting facilities, financial aid, and more—to coal, and other pet commodities like gold and potash.

But the Trump administration is not alone in trying to game the critical mineral system. Before the last critical mineral list was set in 2022, stakeholders clamored to get their commodities included, encouraging policymakers to pay more attention to what makes it onto the list and less on actually designing policies that can properly support critical mineral supply chains. The third critical mineral list is overdue and now the prospect of some backdoor route through the Oval Office will only make things worse.

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Industry stakeholders and policymakers alike have long-perceived a critical mineral designation as a shortcut to special treatment. This is unsurprising since bipartisan interest has materialized federal support for critical minerals while the minerals sector as a whole has seen less attention. The Trump administration first attached benefits to a critical mineral designation in 2017, calling to increase supply chain activity for any mineral commodities that made the list. As a result, both the 2018 and 2022 critical mineral lists inspired countless comments advocating the inclusion of one mineral commodity or another to secure favorable treatments like streamlined permitting and access to geologic data. Members of Congress themselves have called to include certain minerals and have even attempted to force potash and phosphate onto the list through legislation.

But, continually adding to the critical minerals list in response to stakeholder lobbying only dilutes limited federal resources intended to prioritize minerals of greater concern. Effective U.S. critical mineral policy arguably needs to be more targeted, not less.

Critical mineral supply chains pose unique challenges that require unique solutions. Critical mineral policy must reflect the underlying, statutory understanding that critical minerals are import-dependent mineral commodities at higher risk of supply chain disruption—not simply any mineral commodity considered important at a given political moment. The criteria for designating critical minerals considers specific metrics such as net import reliance, concentration of global production in relatively few countries, and supply chain vulnerabilities, looking beyond the general volatility that all mineral markets inevitably experience.

Ultimately, the goal of critical mineral policy should be to remove critical minerals from the list—not designate mineral commodities for special treatment in perpetuity. Policymakers should be tailoring critical mineral policy specifically to reduce U.S. strategic risks. Meaningfully securing the supply chain for a critical mineral means that the targeted policies meant to address supply risks have succeeded. Ideally, that critical mineral would eventually fail to qualify when the Department of the Interior develops a future U.S. critical minerals list.

Policymakers should apply support precisely to where supply chains are most susceptible to disruption. Attention to even just a single facility can greatly reduce nationwide vulnerability. As a prime example, a series of project grants and tax credits expanded the Mountain Pass rare earth operation to process mined carbonatite ore that Mountain Pass previously had to ship to China. The facilities these incentives helped construct not only completed the domestic rare earth magnet supply chain, but also reduced the global concentration of rare earth processing in China.

Strategic initiatives like the expansion of the Mountain Pass operation become less viable if a limited pool of resources must support irrational increases in the number of covered mineral supply chains. Nevertheless, policymakers have attempted to secure critical mineral benefits like mapping campaigns, financial assistance, or even just the prospect of future policy support for politically-favored mineral commodities. Such shortsighted actions risk perpetuating supply chain risks merely to support already established commodities.

Legislative proposals, for instance, have attempted to amend the Infrastructure Investment and Jobs Act to prioritize permitting of all mining projects where the law specifically directs priority to critical mineral projects. Pressure from legislators already resulted in the Permitting Council abandoning rulemakings aiming to limit FAST-41 mining project eligibility to just mines that would produce critical minerals.

The Trump administration’s Executive Order 14241 further deprioritized permitting critical mineral projects by establishing so-called ‘Transparency Projects’ in the FAST-41 program for critical minerals plus the selection of other commodities dubbed ‘minerals’ like gold, potash, and, later, coal. The exact nature of this new project designation remains unclear, but it appears to pressure the Permitting Council into unofficially prioritizing pet projects of the administration while declaring them critical mineral projects. This order not only draws limited permitting attention from critical mineral projects, but also dilutes other forms of policy assistance such as a newly dedicated fund executed by the Development Finance Corporation.

Applicable critical minerals also receive tax credits equal to 10% of production costs under the 45X provision of the Inflation Reduction Act. Analogous frivolous additions to this list would raise the cost of the credit considerably, illustrating the quantitative impact of carelessly expanding critical mineral designations. Adding coal to the 45X applicable critical mineral list alone, for example, would imply over $1 billion in lost federal tax revenue each year.

Meanwhile, recent proposals have called for the creation of a government entity that can use tools like price supports to prevent domestic facilities from closing when prices crash due to disruptive trade practices. Estimates indicate that such a program would require a standing budget of roughly $1.3 billion just to cover 8 critical minerals during low prices for 1 year. Expanding coverage to all of the 30 critical minerals produced domestically may itself prove too costly let alone supporting all domestic mineral supply chains of any kind.

Stakeholders may see a critical mineral designation as a means of growing the economies of their favored mineral commodities. However, successfully reducing critical mineral risks does not always require building new mines or even increasing domestic production. The U.S. simply does not possess sufficient quantities of some critical minerals geologically speaking. In these cases, research into manufacturing processes could lower the material intensity of critical minerals used in finished products like chromium or manganese in steel or find substitutes altogether like synthetic graphite from coal waste. Improved recycling efficiencies can also make the most out of critical minerals that the U.S. must import like tantalum, tin, and tungsten. Ultimately, the U.S. may need to employ these types of initiatives in addition to establishing trade agreements with foreign partners for many critical minerals.

If policymakers want to grow mineral supply chains for general economic purposes, then they should pursue sector-wide policies. Attempting instead to use critical mineral benefits for this may distract critical mineral policy from its priority of reducing risks. Note too that even though sector-wide policies can benefit critical minerals, they may not address the unique vulnerabilities a critical mineral faces. So policymakers should not solely pursue support for the minerals sector overall and expect that it will sufficiently stabilize critical mineral supply chains.

Seeking a critical mineral designation to pursue unrelated goals discourages policymakers from designing separate policies that can more appropriately address non-critical mineral issues. The Trump administration's interest in coal, for example, may reflect legitimate concerns over the economic future of the dwindling coal mining communities in the U.S., but adding coal to the critical minerals list would not really solve those problems. Conflating coal with critical minerals only distracts from more effective ways of managing a resource with increasingly obsolete energy applications like focusing on coking coal or synthetic graphite production instead. Indeed, maintaining the integrity of critical mineral policy does not exclude support for non-critical minerals. It does, however, require separate policies appropriate for their intended purposes even if that means forgoing quick access to critical mineral benefits in the near term.

Meanwhile, U.S. critical mineral policy must grow much further beyond a mere list. As we have previously written, a coherent U.S. critical minerals strategy must decide upon concrete goals for each priority mineral then allocate targeted policy efforts towards achieving these goals. To succeed in this, policymakers must understand that their ultimate objective is a shrinking, ever-smaller critical minerals list, not an ever-growing one.

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Following major power outages in Spain and Portugal—probably the largest blackout in Europe’s history—many are already rushing to exonerate Spain’s wind and solar generation from culpability. Many commentators have already consolidated around a unified stance: it is far too early to blame the blackouts on the renewables supplying two-thirds of the Iberian peninsula’s power at the time. And even if renewables are partly to blame, such grid risks are purportedly of little concern because grid-enhancing technologies are already poised to solve them. But while a total grid collapse at this scale will be multifactorial, it is a simple statement of fact to observe that most of Spain’s solar and wind capacity was wholly unequipped to weather grid fluctuations, possessing none of those shiny new supporting technologies.

Moreover, the parties most guilty of jumping to conclusions are the Spanish political leaders who have driven the expansion of renewable energy in the region. Both the Prime Minister and the Environment Minister summarily rejected any explanation for the blackout that implicated Spain’s solar and wind resources, which at the time of the outage were generating 59% and 12% of total electricity, respectively.

Now, this blackout is not the inevitable outcome of running an electricity system with substantial amounts of wind and solar power. But it is, frankly, exactly what one would expect from the type of energy transition attempted by the Spanish government: breakneck deployment of renewables, a failure to ensure enough spinning generator capacity to maintain stabilizing grid inertia despite widespread understandings of these risks and vocal warnings from grid operators, and underinvestment in grid capabilities that could compensate for renewable energy’s unique technical risks to reliability. It is a testament to the gravity of such risks that an outage has already occurred, two years prior to the start of Spain’s planned phaseout of nuclear energy.

Wind and solar power can contribute meaningfully to large, modern electric grids. But their benefits to the power system—modularity and low marginal costs—have to be balanced against their shortcomings—intermittency, large land area, and transmission requirements. Additionally, most solar and wind farms operating today use simpler equipment that are vulnerable to unexpected shifts in frequency and do not provide spinning or synthetic inertia that can compensate for grid frequency fluctuations. The Iberian outage emphasizes the non-negotiable importance of large-scale investments in grid-enhancing equipment and reliability that occur alongside—if not in advance of—significant penetration of wind and solar onto the power grid. As a 2021 IEA report put it, “to achieve a high share of renewables, the first step is to develop a new way for [inverters] to operate when they start dominating the system.” Spanish policymakers have clearly procrastinated on this first step.

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The Iberian Peninsula could have been, and may still become, a global model for a portfolio approach to low-carbon electricity systems. As one of us wrote ten years ago with Princeton’s Jesse Jenkins, the peninsula's balance of wind, nuclear, hydroelectric, and solar, all on a grid relatively isolated from the rest of Europe, made it "the world leader for grid-wide variable renewable energy penetration.” But since then, Spain’s political leadership has ignored the many warning signs of integrating larger and larger capacities of wind and solar, even while resolving to gradually shift the nation’s electricity generation away from its nuclear power plants.

In 2019, the Spanish government approved a plan to retire all the nation’s operating nuclear power plants by 2035, with the first reactor scheduled for shutdown in 2027. In that year, nuclear accounted for 22% of Spain’s electricity generation, compared to 21% from wind, 9% from hydroelectric, and 6% from solar. Then in 2021 the government passed the Climate Change and Energy Transition Act of 2021, which targeted 74% renewable energy by 2030. Experts warned that this shift towards renewables alongside nuclear phaseout was risky and warranted reconsideration. At minimum such a policy strategy would require more smart inverter capacity to compensate for fewer spinning generators, more grid-scale storage, and more interconnection to continental Europe.

This week’s blackout, though complicated and still uncertain in its exact origin, appears to have been exacerbated by exactly what these experts worried about. Large unexpected frequency anomalies likely triggered a protective automated shutdown of a sizable fraction of Spain’s solar plants, aggravating a large-scale supply-demand imbalance, a worsening frequency excursion, and a total grid collapse. Inertia from spinning turbines usually helps resist sudden grid frequency fluctuations, but relatively little spinning generator capacity was operating at the time of the worsening grid disruption.

It is still unclear how well Spain’s nuclear, hydroelectric, and fossil thermal plants responded to the disruption, either disconnecting instantaneously in the initial wave of lost generation alongside solar or microseconds later upon loss of outside power or once grid frequency passed beyond safety limits. Available data and early commentary suggests only three of Spain’s seven operational reactors may have been online, while a sizable fraction of the country’s hydroelectric capacity may have been under maintenance.

Running a power system mostly on wind and solar may be theoretically possible, but has yet to be demonstrated on any large grid in the world. Doing so would require a number of “grid-enhancing” solutions that are only just beginning to enter operational service at scale today. Installing “grid-forming” inverters that let solar, wind, and batteries regulate grid frequency and voltage strengthens the grid compared to currently common “grid-following” inverters that cannot adjust to grid fluctuations. A sufficiently large fleet of charged battery systems can also automatically release power in response to loss of generation from one or more power plants, maintaining grid frequency and the balance of supply and demand until reserve generators can come online. Ancillary supporting equipment such as synchronous condensers and static synchronous compensators can similarly provide necessary frequency support to correct for grid fluctuations. Engineers are also devoting increasing attention towards optimizing the parameter tolerances for grid-following inverters and other systems so assets don’t disconnect from the power grid unless truly necessary.

Such solutions involve added costs that renewables proponents have often minimized or entirely neglected to discuss. Spain, clearly, has yet to devote adequate effort to such measures. While some of these optimizing and mitigating technologies may not have existed over much of the last two decades as Spain pursued a renewables-dominated grid, their commercial unavailability hardly excuses inattention to reliability concerns.

What’s more, the unique vulnerabilities of wind and solar scale with deployment. Greater wind and solar capacity also require correspondingly larger investments in grid management solutions, and in maintaining sufficient reserve generation to operate when the sun isn’t shining and the wind isn’t blowing.

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Both Spanish officials and some mainstream media coverage have been quick to dismiss any explanations that implicate wind and solar in the blackouts. “Reliance on renewables is not to blame,” wrote Reuters’ Ron Buosso. "Rather, the issue appears to be the management of renewables in the modern grid.” This dismisses the inherent risks that unaugmented wind and solar can pose to grid operation, and shifts accompanying blame away from the renewables sector and onto utilities and grid operators.

In a recent interview for Heatmap, Bri-Mathias Hodge captured the essence of the problem, arguing that “the entire stability paradigm of the power grid was built around this idea of synchronous machines. And we’re moving toward one that’s more based on the inverters, but we’re not there yet.” Indeed, we have personally heard more than one renewables developer criticize what they saw as an outdated “Westinghouse grid paradigm” built around spinning inertia. Yet this recent Spanish episode—alongside other major incidents such as Winter Storm Uri and the Odessa disturbance in Texas in 2021—have certainly emphasized the enduring value in the “Westinghouse” reliability standards and exhaustive contingency planning that engineers traditionally have enforced on grid operation.

European politics have long rewarded public commitments to renewable energy and the accelerated phaseout of nuclear energy. Meanwhile, independent renewable power producers often choose to minimize investments in reliability-enhancing equipment to lower costs. Grid operators, caught in the middle, warned that renewable energy expansion was testing the limits of the transmission infrastructure’s reliability tolerances. And it may well ultimately be everyone that pays the price—politically, and economically.

Grid-forming inverters, grid-scale storage, synchronous condensers, expanded transmission infrastructure, and greater interconnections between different grid regions can mitigate the marginal risk associated with increased wind and solar penetration. But in most places a more resilient, least-cost future low-carbon grid will almost certainly leverage a diverse portfolio of generation resources, including dispatchable resources like nuclear, geothermal, and gas turbines with carbon capture that not only generate power during inevitable wind and solar lulls but provide supporting grid inertia during inevitable disrupting events. Uninitiated pundits might fantasize that relaxing reliability standards might enable even faster and cheaper grid decarbonization, but engineers understand from experience that a system set up to repeatedly fail will impose significant operational and economic costs.

The recent Iberian experience offers valuable insights that can help materially accelerate energy transition efforts, provided that we have the humility to learn the needed lessons. Inertia from spinning generators and their synthetic equivalents is useful. Policymakers should move heaven and earth to keep operating the nuclear power plants that generate 20% of Spain’s electric power, and perhaps consider adding more. Mitigating risks of cascading failure from solar and wind farms through adoption of grid-enhancing equipment is possible, but demands targeted and intentional investment at scale.

Importantly, renewable independent power producers may well advocate for additional market incentives for wind and solar developers to also provide stability and reliability services. However, policymakers should resist the temptation to further tip competitive electricity markets in renewables’ favor and instead consider making reliability-enhancing capabilities obligatory for at least a subset of new and retrofitted projects—either as a condition for receiving public subsidies or as a basic requirement. Given the clear potential consequences cascading generation failures pose to the public interest, governments should rightfully insist on adequacy of grid-enhancing technologies as a basic expectation rather than as a premium private market generator service paid for by the public dime.

The lesson that single-minded focus on adding unassisted, grid-following wind and solar to the grid comes with risks may apply even more powerfully to the broader world. A nationwide power outage for 24 hours is an international news event in southwestern Europe. Similar events in places like Puerto Rico and Cuba, or developing countries where rolling blackouts are the normal state of grid operation, certainly ought to remind the climate community not to assume that leapfrogging to entirely renewable power grids will be cheap or easy. If we are serious about deploying cleaner electricity globally at scale, we must confront such realities head-on.

For too long, climate and clean energy advocates have conditioned themselves to roll their eyes at any commentary suggesting that grid-following wind, solar, and storage cannot do literally everything, everywhere, at all times. Even basic and fundamentally true observations like “the sun doesn’t always shine and the wind doesn’t always blow” have drawn dismissive mockery from some climate hawks. That the Spanish grid collapsed under a bright sun just a half hour past midday fundamentally challenges platitudes that we have already solved the integration challenges of wind and solar power. It is not only okay to admit that wind and solar cannot do everything—it is precisely what this moment needs.

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In a fresh blow to a liberal international order that once viewed multilateral institutions with great hope, the Trump administration has issued an executive order expediting U.S. permitting for companies to explore and exploit seafloor minerals in international waters, leveraging National Oceanic and Atmospheric Administration (NOAA) mining regulations from the 1980s.

International seafloor mineral resource development supervised by NOAA would bypass an ongoing process by the International Seabed Authority (ISA)—of which the United States is not a member—to develop a standardized set of regulations for mineral collection on the international seabed beyond countries’ sovereign waters.

Yet the eventuality of such a seafloor minerals grab was no surprise considering the ISA’s longstanding paralysis. A prolonged status quo where members and NGO stakeholders sought to block even sluggish progress towards an international seabed mineral collection framework was always bound to produce an eventual challenge to the ISA’s legitimacy. Despite drawing condemnation from governments, environmental groups, and scientists, U.S. actions to unilaterally permit seabed mineral resource production serve as an important reminder that, in practice, the ISA framework was always competing against more self-centered alternative models for mineral development.

A bitter lesson of the current moment is that an international framework for environmental governance of a global common resource must allow for resource utilization if the framework is to survive. If policymakers and environmental advocates truly prefer systems of accountability enforced by international institutions as opposed to a free-for-all rush for seafloor minerals, they must recognize that a credible alternative regulatory framework must offer a viable path for seafloor mineral projects to move forward.

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A crossroads for the International Seabed Authority and its courtiers

Intergovernmental organizations already face plenty of growing cynicism over their ability to execute their intended missions and uphold related international norms. UN institutions have impotently looked on as countries like Azerbaijan, Russia, Israel, and Rwanda engaged in blatant territorial conquest and armed interference in neighboring states. Economists might argue for the comparable severity of the World Trade Organization’s incapacity, with the “dead” Doha Development Round’s negotiations having failed to substantively advance since their commencement in 2001. International climate diplomacy has endured considerable turbulence of its own, with the Paris Agreement succeeding two decades of the Kyoto Protocol’s relative ineffectiveness only to confront an increasing deadlock over questions of climate lending and damage awards to poor countries.

President Trump has eagerly poured salt into many of these wounds. His administration blocked the appointment of WTO officials in his first term, and moved to pause all U.S. contributions to the WTO a few months into his second. On his first day in office, Trump directed his administration to start the process of U.S. withdrawal from both the Paris Agreement and the World Health Organization.

Such actions make it easy for environmentalists and international officials to simply dismiss Trump’s seafloor minerals grab as yet another irreverent middle finger to international cooperation and laws. The damage Trump is inflicting not only to U.S. foreign policy interests but to these valuable, if flawed, international organizations indeed deserves withering criticism. Since cracks in these multilateral institutions were emerging well before the Trump era, flaws within the ISA and similar international efforts to regulate the global environmental commons may have made it more likely than not that they would confront such challenges to their legitimacy eventually.

Now is the time for the governmental, scientific, industry, and advocacy stakeholders engaging with the ISA to reckon openly with the powerlessness of a multilateral institution inherently designed to favor bureaucratic process over effective outcomes. The UN Convention on the Law of the Sea (UNCLOS) erred in structuring the ISA to require universal consensus to execute important decisions—a negotiation hurdle that imposes fundamental structural weaknesses on the organization rather than strengths. Armed with the credible threat that a single dissenting member state could block codification of policy, many countries and nongovernmental organizations have exploited this structure to continually delay drafting and approval of an international code for seafloor mineral development, even while claiming that the ISA was shamefully in bed with industry and pro-development. The ISA’s resulting difficulties in making progress towards a final regulatory code for seafloor minerals collection has, if anything, reinforced longstanding U.S. conservative critiques that ratifying UNCLOS would only obstruct U.S.-led efforts to explore seabed minerals.

Trump’s reminder that nothing fundamentally stops nations from unilaterally claiming international seabed resources ought to remind ISA members that they must always compete against this implicit alternative. An internationally-governed regulatory system for seafloor minerals collection with high environmental standards is not only a worthy framework to strive for in principle but could serve as a positive example for global mining writ large. Considering all of the environmental, labor, human rights, and public health impacts imposed by past and present mining, many would welcome greater accountability guided by high quality, internationally harmonized standards.

A valuable opportunity still remains for the ISA to—for the first time in history—codify best practices for mineral development before an industry has commenced commercial operations. Development of an international framework for seafloor mineral collection represents the strongest possible leverage that advocates could bring to bear against companies that would otherwise move projects forward with the unilateral backing of a single country’s government. The Trump administration’s seafloor minerals declaration must be understood as a call to action for international stakeholders to finalize the ISA mining code as quickly as possible.

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How should the United States and engaged seafloor mineral companies proceed?

From the perspective of seafloor mineral operators, the ISA has clearly failed to meet its past deadlines for finalizing and enacting its draft mining code. At the same time, the current moment is a curious time for firms to be throwing up their hands at the ISA process and turning to the newly-reinaugurated Trump administration.

The ISA only recently underwent a major leadership change, with newly-elected Secretary-General Carvalho having held her office for mere months. Carvahlho has expressed a public commitment to maintaining the ISA as a neutral regulatory and decision-making body, and to making efficient progress towards a complete mining code. Some rumors have suggested that Carvalho has encountered difficulties filling staff roles at the ISA following the change in administration, affecting the ISA’s ongoing activities. Yet given the recency of this leadership change, one would expect corporate actors to extend good faith towards the ISA’s new direction and evaluate the organization’s forward momentum at the 30th session of the ISA Council and ISA Assembly this summer. But companies are obligated to produce returns for investors, and private sector interest in Trump’s move to establish a U.S. route to seabed mineral development may well intend to put new pressure on this summer’s ISA proceedings.

At the same time, commentators should not assume that seafloor mineral development under a U.S. federal framework would be irresponsibly regulated in comparison to a mining code developed by the ISA. Under the Deep Sea Hard Mineral Resources Act’s (DSHMRA) existing framework, a NOAA process for issuing mineral exploration and exploitation would hardly be a no-holds-barred free-for-all and would likely impose a wide array of regulatory requirements upon prospective operators. First, operators would have to demonstrate that they possess the full financial and technological capability to explore or recover seafloor minerals. Requirements would also include advance federal environmental impact assessment of any mineral recovery plan, environmental protective measures, alignment with standards such as the Clean Water Act, use of best available technologies to reduce impacts, and compliance with regular monitoring including the placement of federal officials on any vessels conducting activities.

Moreover, U.S. presidential leadership will change within four years—either before any commercial-scale seafloor mineral operations begin, or during the industry’s earliest commercial stages. Even if the Trump administration adopts a laissez-faire approach to environmental standards and best practices for seafloor mineral collection, subsequent administrations may take a different, stricter approach—a risk that operators must weigh and are likely proactively accounting for. The DSHMRA even authorizes the President and the Administrator of NOAA to issue an emergency order immediately suspending mineral exploration activities. In general, the NOAA Administrator enjoys considerable latitude to decide the outcome of license applications and even impose special terms upon how operations proceed. A controversial and rapid move to permit seabed mineral recovery at NOAA could provoke overcompensating stringency when political tides shift.

It remains to be seen whether NOAA is sufficiently capable of governing a U.S.-led seafloor minerals industry at all. DSHMRA and its related federal regulations for deep seabed exploration and commercial recovery are all products of the 1980s and require modernization to reflect today’s technologies and scientific knowledge. More crucially, these regulations only intended to provide a skeleton for further refinement, and generally lack the specificity needed to govern maritime mineral activities in practice. Furthermore NOAA has suffered grievous cuts to its workforce while already facing a burdensome breadth of official responsibilities from fisheries management to coastal development to aquaculture to storm early warning to maritime research. As with the ISA, a major question is whether NOAA actually possesses the institutional capacity to oversee effective permitting and to enforce accountability upon a nascent seafloor minerals industry.

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The high stakes of international global commons governance

There is a reason some branches of international relations theory describe relations between states as a form of anarchy. You can just do things, after all—like declare that minerals-rich nodules on the seabed thousands of kilometers away from the coastline of any nation belong to your country.

Ultimately, international institutions wield influence only insofar as international actors believe that those organizations can carry out their mission effectively and impartially–and that the consequences of defying them outweigh the benefits of acting unilaterally. If shared governance of a global commons seeks only to bar development of that commons in perpetuity, it should come as no surprise when international actors tire of obstructionary processes and break ranks to kick down the fence. Only one defecting or non-participatory actor may suffice to call the entire institution’s value into question.

Yet the uniqueness of seafloor minerals on the high seas as a non-sovereign resource, if anything, highlights a more general dynamic regarding how different strategies for governing mineral resource development can often lead to unintended consequences. If “high standards” mining means no mining at all, then impacted actors will seek alternative pathways to source the minerals that society so vigorously demands. In the far more ubiquitous case of conventional terrestrial mining, mineral resources are clearly subject to the laws and regulations of the country hosting those deposits. In practice, we can observe today how highly restrictive mining policies and robust environmental opposition in some jurisdictions have funneled significant mineral production into regions subject to lower standards.

A uniform global standard for recovering seafloor minerals would mark a valuable achievement and dissuade countries from taking the alternative route of unilaterally claiming resources on the international seabed. If the ISA places genuine value on collective management of the seafloor, it must rapidly and aggressively reform institutional decision-making processes and finalize an alternative mining code. Only an enacted, functional international mining code provides any leverage and social license pressure to persuade aspiring operators like the Metals Company to continue engaging with the ISA. The burden is now on the ISA to justify its own continued relevance and existence.

Meanwhile, environmental advocacy groups must similarly recognize the misguidedness of strategies oriented around process obstruction and categorical opposition to any forms of seafloor mineral collection. Advocates should pivot towards supporting a good faith effort to progress regulatory development at the ISA and help build robust mechanisms for oversight. The alternative is to spark a resource scramble with little regard for cooperation or standardized industry practices.

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By Seaver Wang

“If you’re into whales, you don’t want windmills,” Trump asserted in an Inauguration Day speech before supporters in Washington D.C.. The same day, Trump issued an executive order withdrawing all areas of the outer continental shelf from offshore wind leasing.

This dramatic reversal for the U.S. offshore wind sector marks a clear victory for offshore wind critics who have long warned that wind projects would devastate Atlantic whale populations. Such arguments have amassed surprising popularity. Earlier this month for example, controversial commentator and self-described journalist Michael Shellenberger—once affiliated with BTI—published a tweet thread to viral acclaim claiming that offshore wind projects off the East Coast of the U.S. threaten the North Atlantic right whale with extinction and calling upon the new Trump administration to “end the slaughter.” In his post, Shellenberger shared Thrown to the Wind, a September 2023 movie produced by his organization Environmental Progress that allegedly investigates the links between wind farm construction and whale deaths.

But upon cursory examination, Thrown to the Wind commits numerous factual errors on critical points, systematically omits contextualizing information, neglects to discuss the many other threats that whales currently face, and generally dresses up uncritical sensationalism with vigorous hand waving and worn appeals to science. In 29 minutes of runtime, Shellenberger’s “documentary” presents only tenuous circumstantial evidence that no credible researcher would deem sufficient to support his bombastic, confident claims that offshore wind projects are killing and will kill endangered whales en masse.

When placed in context of the total sum of human shipping, surveying, and construction activities and broader human impacts upon the sea, a conclusive assertion that wind projects represent the existential threat to right whales rightly appears ridiculous. Moreover, Shellenberger appears wholly uninterested in discussing any technical, operational, or policy solutions that could ameliorate or even eliminate any impacts that offshore wind might pose to whales.

Yet this forgettable cinema project actually highlights a broader long standing problem—the boomer environmental movement’s endemic reliance upon appeals to emotion and simplistic tropes to resist new technology and construction. Despite paying reverent lip service to science, old-school conservationists now routinely eschew evidence-based inquiry in favor of such run-of-the-mill indie documentaries. All of this video content borrows from the same playbook—suggestive tricks of cinematography, hamfisted appeals to emotion, grave sermons on the inviolability of the “precautionary principle”, vague claims about the “fragility of intertwined ecosystems” and the certainty of collapse should the objectionable project of the day move forward. Unfortunately, such misleading messaging is often as effective as it is ubiquitous, as evidenced by the social media splash made by Shellenberger’s posts—20,000 retweets, 48,000 likes, and over a million views.

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What this all highlights is how commentators of all stripes readily invoke marine wildlife protection for their own purposes. Shellenberger and others attack the offshore wind sector by spinning a whale slaughter narrative while ignoring far more impactful threats whales face from fishing gear and boat strikes. Yet their tactics parallel those of ocean conservation groups catastrophizing about how seafloor minerals exploration will destroy the ocean carbon cycle—with an equal passion for flashy claims that contradict evidence-based reasoning. Meanwhile mainstream environmentalists lament the miniscule quantities of fish eggs and plankton ingested by a nuclear power plant’s cooling system while simultaneously calling for offshore wind development on the same patch of coast.

All of this agenda-driven messaging suffers from the same lack of holistic perspective. Human civilization already interacts profoundly with the ocean through ship traffic, dredging, transoceanic cables, fishing, naval activity, aquaculture, coastal construction, and countless other activities. All of this meanwhile takes place against a larger backdrop of human impacts from nutrient pollution, plastic waste, ocean acidification, noise, and ocean warming. We already have no choice but to balance new activities like wind farm development, now and forever, within this larger landscape of ubiquitous human activities at sea and human impacts on oceans. If we want to work seriously to advance infrastructure development with well-managed impacts on the ocean environment, then we simply must let go of the traditional environmentalist reliance on selective narratives.

What does Thrown to the Wind get wrong?

From the very start, Shellenberger’s brazen tweet makes a sweeping causal conflation. He claims that all 12 whale deaths off the U.S. East Coast throughout December 2024 occurred because of wind turbines, and that the North Atlantic right whale will go extinct unless Trump puts a stop to wind project development.

Having reviewed the film Thrown to the Wind in detail, such gyrating leaps of illogic accurately describe Shellenberger’s work on the subject.

Thrown to the Wind’s glaring sin is that it noticeably sidesteps discussion of any other possible causes of whale deaths, particularly the two consistent top known causes of death—entanglement in discarded fishing nets and gear, and collisions with boats of all kinds. These two factors accounted for 25 out of 41 known right whale deaths between 2017 and 2024. If a film were really centering whale welfare, one would expect it to touch at least briefly upon all the varied threats that whales face in practice.

It only gets worse from there. None of 12 East Coast whale deaths in December 2024 were right whales, contrary to what a casual reader might take Shellenberger’s tweet to imply. One of these dead whales washed ashore far away in North Carolina, where no wind construction is ongoing. Several of the dead whales appeared on beaches along the north side of Cape Cod, the side opposite from early-stage wind project development off Martha’s Vineyard south of Cape Cod’s southern coast. And while whale autopsy work on most of these dead whales is still in progress, initial findings so far have already ruled out offshore wind as the clear culprit in a couple cases—a Minke whale dead of disease, and a young humpback whale found on Cape Cod’s north side struck head-on by a boat.

Skating over such inconvenient details, Shellenberger and colleagues pin the blame for whale deaths squarely upon underwater noise pollution from offshore wind development. They claim to have shadowed ships performing preliminary work at the Vineyard Winds offshore wind site and to have taken damning measurements of noise emitted from such work.

A trailer clip Shellenberger shared prominently includes an off-the-cuff statement by a boat crew member recording noise from a survey vessel, who remarks “it sounds like somebody is pile driving.” This alludes to the process of pounding monopile structures into the offshore continental shelf, upon which developers later place the wind turbines themselves. Yet the fast-paced chirping sounds recorded from the small boat clearly do not originate from pile driving, which exhibits much longer intervals between strikes. Robert Rand, who the film credits as an acoustics expert, does correctly identify the noise as scanning sonar shortly thereafter in the film. This clarification is left out of the shorter promotional clip. Yet in any case, multibeam and sidescan sonar typically operate at frequencies above what humpback whales can hear and dissipate over short distances, and are used across oceanic industries like fishing, dredging, and scientific surveys. If sonar systems posed an existential threat to large whales, culpability would extend far beyond the offshore wind sector.

The film’s commentary on underwater sound levels also neglects context regarding the volume of the sounds measured. The film crew claims to have measured 150 decibels of sonar sound at a good distance from a specific seafloor surveying vessel in the Vineyard Wind development area, MISS EMMA MCCALL, then around 90 dB of sonar noise at a distance of 0.5 nautical miles in a separate instance. In comparison, the underwater noise from a moving cargo ship can be 190 dB at the source, while some research papers report that whale watching boats can produce 138-169 dB at the source (all decibel measurements are with respect to 1 μPa at 1 m). Coastal dredging to maintain harbor channels for ships and boats generates 180 dB.

How noisy does underwater sound have to be to bother marine life? Natural “ambient noise levels experienced in gentle weather conditions”, as it turns out, typically reach 94 dB. The U.S. National Marine Fisheries Service defines a continuous noise threshold of 120 dB beyond which there is a “possibility of behavioral impacts, generically, to marine mammals.” In other words, not all of the wind farm zone noise measured by the film crew was even particularly distinguishable from background ocean noise let alone harmful, while offshore wind operations are far from the only potentially loud noise sources in the coastal marine environment.

MISS EMMA MCCALL also uses exactly the same gear to survey across the U.S. East and Gulf coasts for offshore cables, underwater pipelines, offshore oil and gas drilling, dredging, government and scientific research, and other seafloor surface characterization activities. As of time of this writing, MISS EMMA MCCALL is docked in the Gulf of Mexico.

At another key point, the film shows charts comparing regional ship traffic in the mid-Atlantic and New England against the locations of reported whale deaths over different time frames. Predictably, the charts do show an increase in ship activity in the Martha’s Vineyard region in 2022 and 2023, while the number and location of whale deaths seems to fluctuate wildly between periods. Shellenberger quips in response to a colleague: “I appreciate your caveat about not suggesting causality, but it’s impossible not to look at these correlations and imagine there’s some connection.” His comment unintentionally reveals the skew characterizing the whole documentary project—a deliberate disinterest in alternative hypotheses, uncertainties, and sources of error.

The film, for example, does not seem particularly concerned with comparing its ship traffic and whale deaths narrative against the actual timeline of wind farm construction. Before 2022, the US built just 7 offshore wind turbines. Five turbines near Block Island, Rhode Island constructed between 2015-2016, and two turbines off Virginia constructed in 2020. This calls into question the significance of the ship traffic imagery shown from December 2016 through the end of 2021.

The film team’s presentation of ship traffic in inconsistent time periods does not account for seasonal patterns of boat traffic around the Martha’s Vineyard, Nantucket, Cape Cod regions during the summer months. Nor do they consider the seasonal pattern of whale activity, in which whales are present year-round but concentrate off New England largely in the winter and spring months. In response, federal agencies and wind farm developers have also explicitly agreed that developers will concentrate onsite activity during summer months—another factor that the superficial commentary does not consider.

Meanwhile, dead whales washing ashore do not exactly offer the clear narrative that Shellenberger and company would like. Dead whales appearing on beaches are obviously decoupled in time and place from where and when they died, and researchers often require months of autopsy work to investigate the cause of death. ​​Whale strandings, by nature, are a metric carrying considerable error—an inherently incomplete picture of whale mortality with a lot of chance thrown in that could create illusions of trends. The time needed to detect robust trends in whale deaths in response to a new stressor may be quite long. Simultaneously, one can easily imagine other explanations for increasing whale deaths on the U.S. East Coast since 2016, such as infectious disease, marine pollution, climate shifts, or significant shifts in boat traffic during and after the COVID-19 pandemic.

As the film’s final piece of evidence, activist Lisa Linowes claims that a letter to the Bureau of Ocean Energy Management by NOAA Chief of Protected Species Sean Hayes warns that wind turbine turbulence will destroy the plankton that whales feed on. This assertion utterly butchers the actual scientific concern the letter by NOAA scientists highlights—a far more mundane risk that turbines could change local patterns of water circulation and stratification, shifting where zooplankton occur. Many anti-wind activist groups regularly cite this NOAA letter, but few groups draw attention to the NOAA scientists’ proposed solution to protect whales from negative impacts—an incremental 20 kilometer shift of the wind farm development zone. This policy suggestion stands in sharp contrast to how Shellenberger’s film frames the threat to whales from offshore wind projects as a yes or no binary, as opposed to any interest in exploring solutions throughout the whole spectrum of impacts and countermeasures.

Make no mistake—this critique of Shellenberger’s film does not seek to dismiss the real concerns regarding possible negative impacts upon whales from offshore wind development. As evidenced by federal regulations, industry countermeasures, and academic research and oversight, such concerns do demand serious study and attention. But members of the public worried about whale welfare are far better off reading the actual NOAA letter and related scientific work themselves rather than wasting time on this “documentary”.

On the future of humans, the ocean, and the Earth

Overall society would benefit by drawing some much-needed lessons from this silly film. Likely, many clean energy advocates and climate hawks have nodded along so far with this critique of Thrown to the Wind.

Yet members of the broader environmental coalition should consider how this film is actually representative of the highly unscientific, typical documentary often celebrated by the environmental movement. Thrown to the Wind’s distorted narrative echoes that of films like the widely-panned Seaspiracy, which spun similarly superficial and unscientific narratives about fishing and ecological collapse. The ranks of junk food movies on nuclear power include examples like Meltdown: Three Mile Island, which earned a Netflix release despite wildly mischaracterizing numerous technical and historical facts and leaning heavily on appeals to emotion.

One could literally shoot the same kind of documentary speculating about how geothermal power will poison the flamingos, complete with an eerie musical score, camera angles lingering melancholically on a flamingo chick, and sermonizing over the sins of industrializing nature. This is a mirror image of classical environmentalist doco-dramas, just mobilized for different ideological purposes. Shellenberger, after proclaiming the “Death of Environmentalism” just two decades ago, has now essentially chosen to leap into the same grave.

Critics do not need to make up arguments against offshore wind. Shellenberger is likely grossly overstating the impacts of offshore wind development on Atlantic whale populations so far, but neither is it reasonable to argue that the old Biden administration goal of expanding offshore wind capacity from 42 megawatts to 30,000 megawatts by 2030 would have zero impacts upon whales. A more rational discussion of impacts management can appreciate the full spectrum of tradeoffs between building many wind farms speedily and cheaply versus slower, limited construction with obligations to implement a whole suite of high-cost mitigative measures.

From a big picture perspective, one can easily imagine that in a techno-economic future where nuclear power or advanced geothermal scale with great commercial success, the entire case for offshore wind could weaken to the point of non-viability. But the future technological breakthroughs are hard to predict and society needs more clean energy tools, not less.

Meanwhile, one thing is certain: the fate of Atlantic whales will depend upon a far richer set of factors—ranging from fishing to navy sonar to climate shifts—than just offshore wind turbines alone.

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The year 2032 is now the earliest date by which a U.S. president might next secure re-election to a consecutive second term of office. This rubber-banding poses challenges for efforts to craft durable strategic policies, particularly for complex industries like critical minerals and metals.

On one hand, critical minerals security has strong enough bipartisan support to enable some continuity throughout—and beyond—the incoming Trump administration. On the other hand, successfully fostering a growing domestic critical minerals sector depends on more than broadly-supported initiatives like Department of Defense grants for mines or R&D efforts into next-generation mining and recycling techniques. It also depends upon downstream demand generated heavily by a clean technology sector now squarely in the crosshairs of major policy changes.

While shifts in policy are inevitable in any democratic society, some level of policy consistency is crucial for efforts to develop secure domestic critical mineral supply chains. The United States already confronts a difficult uphill challenge when it comes to developing alternative mineral sources in the face of dominant Chinese producers. Republicans should therefore carefully consider the unintended effects of eliminating subsidies for certain key downstream technologies, downsizing federal programs, or excessively cutting staff at minerals-relevant agencies. Downstream demand for critical minerals is key for strengthening the investment case in upstream capacity, while now is hardly the time to pare down the federal government’s capacity to support new project development.

Similarly, Democratic policymakers and environmental advocates now on the defensive during a second Trump term should think more open-mindedly about future changes to mine permitting processes or federal land management that might significantly benefit critical minerals development and clean energy efforts, even if Republican majorities pursue such reforms in ways that are different from what they might ideally prefer. The past Democratic approach of paying lip service to critical minerals while walling off federal lands from mineral development and erecting new administrative obstacles was neither coherent nor compatible long-term with either U.S. interests or the global energy transition.

Across both sides of the aisle, policymakers interested in critical minerals must pragmatically and non-ideologically evaluate the implications, benefits, and drawbacks of policy changes for mineral industries that may exhibit strong if indirect links to seemingly unrelated legislative provisions. Sustained development of a strong U.S. critical minerals sector will depend on such a rational approach.

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Everyone agrees the unobtanium is important

Fortunately, the importance of critical minerals security resonates with Americans across the political spectrum, motivating a number of proposed bipartisan bills with good potential to move forward in the new Congress. Even with Republicans focused on budget tightening to support extension of the 2017 Tax Cuts and Jobs Act, critical minerals remain something that Congress appears quite willing to spend on.

One could group the various new critical minerals policy proposals currently floating around Congress by several key themes. First, a number of bills seek to strengthen coordination on natural resources across the federal government, in some cases establishing new entities tasked with overseeing national strategy. Some examples include the National Critical Minerals Council Act and the Intergovernmental Critical Minerals Task Force Act. Initiatives to better coordinate innovative critical minerals related research and development across government and with U.S. universities, such as the Unearth Innovation Act, similarly strengthen the cohesion of federal technology policy.

At the same time, international partnerships can help address other important U.S. critical mineral needs that our country’s geologic resources alone cannot adequately meet. The STRATEGIC Minerals Act, Global Strategy for Securing Critical Minerals Act, and the Earth Sciences and Cooperation Enhancement Act of 2024, for example, aim to bolster supply chain efforts with U.S. allies and partners.

The second broad category of policy ideas involves direct interventions in critical mineral markets and trade. One promising approach gaining traction involves the use of financial tools to help de-risk domestic critical mineral activities facing price volatility by using price support mechanisms like contract-for-differences, forward contracts, or backstop offtake agreements. Related proposals include the Critical Materials Future Act and the Securing Essential and Critical U.S. Resources and Elements (SECURE) Minerals Act of 2024.

At first blush, trade policy might not necessarily connote a strong intrinsic link with critical minerals strategy. Yet measures to correct for differing standards in the fairness, humaneness, or sustainability of goods in international markets clearly pose meaningful implications for critical metals and materials. The already-enacted Uyghur Forced Labor Prevention Act, for instance, is already significantly influencing global industry due diligence regarding the procurement of battery and automotive raw materials.

A range of recent proposals have also explored border adjustments that charge fees on excessive pollution generated by foreign producers of aluminum or other critical minerals. Recent draft legislation includes the Foreign Pollution Fee Act, FAIR Transition and Competition Act, and Clean Competition Act. Indeed, such policies could help significantly level the playing field for domestic critical minerals producers, correcting advantages that Chinese industry enjoys thanks to low-cost coal-fired electricity and heat.

More controversially, policies such as anti-dumping and countervailing duties seek to correct for overseas industrial policies that establish “unfair” competitive advantages by maintaining unreasonably low commodity prices. The incoming Trump administration has signaled a strong interest in tariffs, targeting not only China in particular but also potentially a broad spectrum of longstanding U.S. trade partners. Such measures could seriously influence the price of not only imported critical metals, but also relevant inputs to the industry such as equipment, chemical feedstocks, mined ores, and intermediate supply chain commodities. Federal policymakers should therefore seriously weigh the possibility that blanket direct tariffs could produce unforeseen and unpredictable consequences for national critical mineral efforts.

What happens to the clean energy and critical minerals nexus?

Yet the prospects for secure, expanded national critical mineral supply chains will also hinge centrally upon the incoming federal government’s attitude towards various energy and industry-related policies contained within the Inflation Reduction Act. The future of the U.S. energy landscape possesses important connections to the nation’s critical mineral security, forming a broader nexus of critical minerals and alternative energy superiority key to competing in tomorrow’s global economy.

In late September, our team released a major report quantifying how electric vehicles and clean energy infrastructure powerfully drive future national demand for many categories of critical minerals. This means that the supply of defense and semiconductor-related minerals often depends upon market trends for advanced energy technologies. For example, we calculated that a long-term full national shift to electric vehicles would require the equivalent of 150% of current U.S. nationwide production of heavy rare earth elements and 1 to 1.5 million tons of battery graphite annually—amounts that vastly exceed rare earth and graphite usage in defense applications like radar systems and aerial drone batteries. Deployment of new electricity generation, transmission, and EVs could similarly demand as much aluminum and nickel as the whole U.S. economy uses today. In many cases, national security uses of critical minerals therefore rely upon and benefit from energy sector supply chains.

Meeting such projected increases in national critical minerals consumption is already far from an easy challenge. But repeal or significant revisions to IRA could significantly weaken the business case for new critical mineral projects both domestically and in allied and partner countries, even further frustrating efforts to expand mineral supplies. Eligibility for the IRA’s Section 30D electric vehicle tax credits, for example, requires manufacturers to source battery critical minerals from the U.S. or from producers based in free trade partner countries, effectively creating a strong and positive incentive for alternative, expanded battery critical mineral supply chains. Many individual mineral projects, from the Talon Metals nickel-copper-cobalt mine in Minnesota to the Syrah Resources graphite processing plant in Louisiana, have leveraged this tax credit to help secure offtake purchase agreements with auto manufacturers.

Similarly, the 10% production cost tax credit for a broad list of applicable domestic critical minerals offered through the Section 45X Advanced Manufacturing Production Tax Credit directly rewards firms that supply materials of strategic national interest. Other important initiatives such as the Department of Energy’s support of promising domestic projects through the Qualifying Advanced Energy Project Credit (48C) and the Loan Programs Office may also depend upon Congress’s approach to statutory tax code changes during the next administration.

The current overconcentration of critical minerals supplies globally stems from muscular Chinese industrial and trade policies, wielded with the express intent to maintain a large share of supply chain control. Beijing’s policies have established a risky market environment that poses barriers to competition too great for free market forces to overcome on their own. Ambitious federal government shifts on trade policy, national minerals strategy, diplomacy, and permitting reforms will not suffice to level the playing field with overseas state-owned enterprises benefiting from powerful subsidy support. U.S. critical minerals security cannot materialize without a backbone of strong public investment and public-private partnerships in both mineral projects and the downstream technologies they support.

Meanwhile, U.S. competitiveness in alternative energy technologies benefits critical mineral efforts as well. Many mineral supply chain processes from graphite refining to metallurgical smelting consume considerable quantities of electricity and industrial heat, with supply and reliability requirements that rival data centers. U.S. producers can never hope to compete on cost with Chinese industries leveraging cheap, polluting coal by using exactly the same technologies. Instead, efforts to expand domestic, economically-viable critical mineral production will necessitate an energy landscape optimized to add new sources of electricity and heat generation easily and at low cost. This reality underscores the importance of a robust national energy strategy that pursues leadership in a broad range of next-generation technologies from nuclear to geothermal to renewables to carbon capture to energy storage. Cheap, abundant energy will vastly bolster development of new critical mineral projects and ensure their resiliency in the face of energy and mineral market volatility.

If it is to succeed, the federal government’s strategic framework on critical minerals must therefore consider critical mineral security and energy abundance as tightly connected, parallel goals. Advanced energy technologies create large-scale downstream demand necessary for upstream mineral supply chain projects to proceed. Meanwhile, mastery of tomorrow’s energy landscape will impart powerful market advantages upon those same critical mineral industries, helping enable supply chain expansion and diversification at far lower cost. As the new Congress deliberates tweaks to the federal tax code and technology-related tax credits in the new year, lawmakers must consistently consider how each change could affect the strategic environment for the critical mineral sector.

Towards a more pro-development federal land policy?

Finally, Republican willingness to pursue policies that reduce unproductive and burdensome regulations on mining on federal land may likely give the Trump administration an upper hand over the outgoing Biden administration when it comes to expanding domestic mining.

In place of deregulation, Democrats under the previous government favored policies such as mine project grants, resource mapping campaigns, and additional permitting agency staff. These types of initiatives certainly help expand domestic mining. However, successfully meeting future critical mineral demand requires considering all forms of industry support. Democrats justified their resistance to permitting process improvements by misrepresenting U.S. mining regulations as outdated despite being among the most stringent in the world. Environmental contingents insisted that, if anything, anticipated increases in mineral demand warranted additional safeguards and flooded policy discussions with unnecessary or lower priority proposals. This false premise ensured that any changes to public land management would have at best produced toothless compromises that added new regulatory burdens for each one removed, as proposed in the Biden administration’s recommendations for mine permitting reform.

The incoming Republican trifecta will have the opportunity to support and expand domestic mining under a more realistic understanding of public land management practices. Least of all, the Trump administration will attempt to undo Biden administration blunders such as revoking the Twin Metals Minnesota lease before completing the project’s environmental review or promulgating the BLM Public Lands Rule which directed land management agencies to overemphasize conservation to preempt mine development. Meanwhile, Republicans in Congress will hopefully continue to pursue nuanced regulatory efficiencies that maintain strong existing standards such as ideas outlined in the Mining Regulatory Clarity Act or Energy Permitting Reform Act, and avoid largely symbolic measures such as the harsher NEPA review deadlines and page limits specified in the Fiscal Responsibility Act.

A Republican government still faces the risk of undermining pragmatic policies with polarized partisan politics that subsequent governments can simply reverse. Namely, general interest in supporting industry may encourage policies that do not specifically target critical minerals and dilute or even threaten support for projects that stand to benefit supply chains the most. Incoming policymakers may, for example, halt the current rulemaking to reduce eligibility for the FAST 41 expedited permitting program from the entire mining sector to just critical minerals projects. Republican preferences for small government may also work counterproductively by cutting regulatory agency staff, reducing their ability to efficiently complete environmental reviews.

Nevertheless, Republican willingness to deregulate provides a better opportunity to expand domestic mine production than Democratic perspectives have allowed. The incoming government, therefore, stands poised to drive important progress in developing a coherent federal critical minerals strategy—one that encourages policymakers to draw from the full suite of tools available, including more open-minded public land management.

Critical minerals coherence, or incoherence?

The new Republican-led federal government is likely to extend targeted policy support to domestic critical mineral supply chain projects while developing a more coordinated overall national critical minerals strategy. Simultaneously, Republicans will likely adjust federal land policies to better facilitate development of domestic mineral resources. Parallel efforts to shrink federal agencies and eliminate spending on key related downstream technologies like batteries, however, could erode or counteract the gains realized through such new policies.

Ultimately, effective federal efforts towards critical minerals security require two factors: persistence and continuity. These are not the same—persistence requires that the federal government show grit and determinedly advance its critical minerals industrial policy even in the face of inevitable setbacks. Tepid resolve that falters quickly at the first sign of discouraging results will not produce more diversified, secure supply chains. Meanwhile, continuity requires that critical minerals strategy not change wildly from Congress to Congress, administration to administration. All of which is to say that critical mineral policy ideas in this new Congress and federal administration will only advance meaningfully—and survive long term—if they can muster at least grudging bipartisan support.

Beyond Washington, legislative proposals and federal agency approaches need to ensure healthy popular support for supply chain projects across a sufficient cross-section of American society. Strategic mineral industries can only flourish with the requisite support of local communities, tribes, and organized labor. Forging such necessary political support is not as difficult as it may sound.

Americans broadly understand that strategic commodities serve the greater national interest, and often show interest in how related economic projects can create opportunities for them and their communities to benefit. They expect operations to follow the law, conduct themselves well, and pay back meaningfully into their host communities. These are reasonable expectations that policymakers can easily reconcile with all of the policy ideas currently circulating across government.

In previous eras of recent American politics, national leaders too often procrastinated critical minerals strategy and pinned their hopes too heavily upon commodity markets easily cowed by muscular Chinese industries and state policies. With such supply chains increasingly wielded for geopolitical leverage in ways that harm global innovation, environmental outcomes, and national interests, U.S. policymakers can no longer afford to punt such responsibilities to their successors. Under these circumstances, one hopes that Republicans inheriting control of the federal government and Democrats in the legislative minority can work pragmatically together to overcome national mineral supply challenges.

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By Seaver Wang, Peter Cook, and Lauren Teixeira

Following the Biden administration’s recent expansion of restrictions on the sale of advanced semiconductor chip and manufacturing technologies to China, Chinese policymakers have responded rapidly by restricting exports of the critical minerals germanium, gallium, and antimony to the United States. Other new provisions, whose specifics remain unclear at the time of writing, may target additional materials like tungsten and graphite. This announcement comes in the wake of recent moves by Beijing to establish stricter export permit frameworks for a range of critical commodities including tungsten, graphite, magnesium, and aluminum alloys.

With U.S.-China trade tensions only likely to intensify in coming months, such raw material supply chain risks are becoming increasingly relevant for energy transition efforts as a whole. Other critical mineral export restrictions relevant for clean energy technologies could conceivably soon follow, with effects that may not be limited to the United States.

In Myanmar, for instance, resistance fighters from the Kachin Independence Organisation recently captured much of Pang War township, shutting down Myanmar’s largest rare earth mining hub and prompting Chinese authorities to close the nearby border crossing. Virtually unregulated mining in Myanmar contributes an unknown but large fraction of global rare earth element (REE) mining, with all of Myanmar’s production shipped to neighboring China, the world’s dominant refiner of rare earth materials. This latest development in a civil war turning increasingly in favor of anti-junta resistance groups has begun to send shivers through critical mineral markets, with industry observers speculating about a future rare earth shortage and price spikes.

If REEs become scarce, Chinese policymakers may clamp down on REE exports next to reserve more of these valuable critical minerals for domestic high-tech industries. Such restrictions could impose constraints upon the rest of the world, including overseas efforts to nurture clean technology sectors like wind power and electric vehicles that rely upon REEs for permanent magnet drives.

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In response to critiques that clean energy sectors depend overly on key commodities imported from China, climate advocates and climate policy hawks have often argued that a country only needs to import battery minerals, solar panels, or electric cars once, at which point they escape the control of the exporting trade partner while operating for decades. This contrasts with continuous flows of fossil fuels whose interruption can immediately catapult energy supplies into a crisis. This reasoning is correct in principle, but supply chain disruptions would nevertheless stall acquisition—or manufacturing—of subsequent batches of low-carbon technologies. Such supply vulnerabilities can certainly freeze energy transition efforts in their tracks and force factories producing energy technologies to go idle.

The preeminent and most-invoked example of supply chain coercion remains China’s disruption of rare earth exports to Japan during the 2010 Senkaku Islands incident. A critical reexamination of this incident reveals a few useful insights that may help observers better understand these newest limits on critical mineral exports from China. The de-facto embargo in 2010 was likely opportunistic rather than planned—an impromptu exploitation of an issue prominent in preceding China-Japan negotiations rather than the culmination of some grand industrial geostrategic conspiracy. Yet this incident certainly cemented the perception that Chinese policymakers have and will wield control of strategic supply chains for geopolitical leverage—a concern that Beijing itself has reinforced since. These latest developments emphasize that policymakers and clean technology companies should be taking immediate steps to reduce supply chain vulnerabilities, if necessary even at what may seem like uneconomically high cost.

When Geopolitical Tensions Spill over into Supply Chains

According to conventional retellings, a number of Japanese companies reported a halt to expected rare earth ore shipments from China beginning Tuesday, September 21, 2010. This coincided with more overt political pressure tactics that had begun days prior, including a cessation of ministerial and provincial exchanges, a popular campaign to limit tourist visits to Japan, the detainment of four Japanese nationals in China, and an exclusion of Japanese companies from bidding on Chinese public projects. Many of these actions followed a Japanese government decision on September 19 to extend the detention of a Chinese fishing boat captain involved in collisions with two Japanese Coast Guard vessels near the Senkaku Islands on September 7.

Japan released the captain on September 25, and Chinese customs offices partially resumed clearing some REE shipments for export several days later. However, international traders, companies, and government officials continued to report systematic interruptions and delays for shipments to Japan as well as some U.S. and Europe-bound exports throughout October and the first half of November.

Following initial reports of blocked shipments by the New York Times and Nikkei on 23 September, Japanese government press conferences the next day on the matter produced a flurry of attention in Japanese and English-language press, at minimum including four Nikkei articles, three Asahi articles, and coverage in Reuters, France24, the New York Times, the Wall Street Journal, Bloomberg, the Japan Times, and the Atlantic—all within a 24-hour period.

Asahi reporting from September 24 already described the situation as “appearing to be an effective embargo”, quoting a China-based REE manufacturing executive as having received instructions from Chinese customs officials to “stop exports until the 29th”. International customers including representatives of Australian, Canadian, Chinese, and Japanese firms all confirmed the suspension of shipments. Japanese government surveys of industry stakeholders in late September 2010 reported a clear consensus that export problems had increased after 21 September, driven by numerous sudden changes in Chinese customs enforcement. Out of 31 responding firms that confirmed their involvement in rare earths trade, all 31 reported encountering export obstacles. By Tuesday 28 September, Japan’s Minister for Economic and Fiscal Policy Banri Kaieda described the situation accordingly at a press conference: “Right now, the de-facto export prohibition that China has adopted is causing profoundly great impacts on Japan’s economy.”.

Notably, contemporary commentary showed a clear understanding that China had already slashed their REE export quotas a few months earlier, observing that the disruptions beginning in late September seemed separate and distinct from this earlier policy change. Articles by Toyo Keizai and Mitsubishi’s think tank MUFC published just days before the export halt very matter-of-factly articulated that China was reducing export quotas to nurture domestic industries, regulate foreign investment in the sector, and limit expansion of new mining for environmental reasons. Reporting from September 25 highlighted arguments by industry observers that they wouldn’t expect producers to exhaust their export quotas until late October at the earliest, with traders noting that even Chinese producers with ample spare export quotas had “been dissuaded” from exporting. In subsequent interviews with researchers, Japanese officials confirmed an internal understanding at the time that the central Chinese government had issued an order, and that the Japanese government interpreted the incident as an economic sanction.

These contemporaneous official government statements, media reporting, comments from industry, and policy responses across English, Japanese, and Chinese-language sources shared a clear understanding that Chinese officials had implemented a de-facto export ban, prompting many governments worldwide to lodge protests while urgently pursuing supply chain alternatives and countermeasures. Even a Chinese People’s Daily article from late 2012 more or less stated: “Even though China did not publicly admit to employing economic sanctions, China did in reality halt export shipments, subjecting Japan to some difficulties at the time”.

How Real Were the Impacts on Rare Earth Element Trade?

Some work in late 2010 and since has challenged this prevailing storyline, arguing that this period of scarce supply and price spikes beginning in late 2010 did stem mostly from China’s stricter export quotas imposed in July—a policy action well predating the diplomatic dispute. Such commentators argue China’s export policies sought only favorable domestic economic outcomes—more stringent environmental regulation of the REE sector and better capture of value-added downstream industries. Revisionist retellings at times go even further, arguing that any resulting supply shortages in late 2010 did not explicitly target Japan and warning against invented narratives of Chinese mineral supply chain coercion. However, such interpretations stray from the historical record and often overstate their case.

Commentators arguing that China’s undeclared interference in rare earth trade in late 2010 is exaggerated “folklore” have often cited a few articles that analyzed monthly Japanese customs or UN data on value of trade in various goods, claiming that overall, broad categories of rare earths traded with Japan do not seem to exhibit quantitative disruptions during this period. However, such low-resolution, indirect data does not distinguish between far more valuable heavy rare earth elements important for high-tech applications versus more abundant light rare earths like cerium that primarily see use in more mundane industrial processes.

Overall, the cited data don’t contain enough detail to draw a clear conclusion that no significant disruptions occurred. Summary data on total rare earth shipment arrivals in Japan might conceal a decline in imports from China compensated by urgently redirected materials sourced from Southeast Asia, Europe, or North America. Similarly, indirect metrics like the monthly value of rare earth shipments from China to Japan may not accurately capture simultaneously evolving variables, like a decline in import tonnage offset by a corresponding spike in rare earth prices. Moreover, monthly-scale data may not confidently capture shorter-term disruptions and delays that began towards the end of September 2010 and varied from week to week thereafter. Finally, such sterile retrospective analyses of trade data in isolation ignores a vast weight of contemporaneous, corroborating testimony and reporting, such as the official surveys of affected industries.

One should also recall that broader Chinese economic coercion aimed at Japan in late September 2010 was not seeking to damage Japan materially so much as to accomplish a specific goal: the successful release of the detained fishing boat captain.

It is true however that China did dramatically alter export and industrial policies for the rare earths sector earlier in 2010. These changes indeed stemmed in part from domestic environmental considerations and aspirations to further develop downstream value-added industries like rare earth permanent magnet manufacturing. And while the particularly sharp reduction in export quotas in July 2010 generated significant international attention and discussion for months predating the Senkaku islands dispute, Chinese national policy had long treated REEs as a strategic commodity and regularly revised regulations and export practices over the years.

While rare earth elements are widely distributed globally, southern China hosts a notable concentration of ion adsorption clay (IAC) deposits, located at relatively shallow depths and mineable using simpler methods in small-scale operations. These deposits tend to form in temperate or tropical climates with higher temperatures and rainfall that can leach REEs from bedrock and concentrate them in clay soils. IAC deposits typically contain higher grades of heavy REEs relative to hardrock REE deposits, may not require onsite milling, and allow for initial processing onsite using pit leaching, often using ammonium sulfates. Such low-cost IAC mining operations have driven much of the growth in China’s rare earth sector over recent decades, albeit with considerable environmental impacts that have prompted stricter regulations since the mid-2010s.

Starting in 1985, the Chinese government began offering an export rebate to REE enterprises to encourage rare earth exports, refunding the value-added tax that producers paid on exported products. Following China’s overtaking of the United States as the world’s largest REE producer in the late 1980s, Chinese policymakers designated REEs as strategic minerals as early as 1990, with national production ramping up dramatically through the 1990s thanks largely to growth in small-scale projects targeting IAC deposits. By 2000, in light of increasing domestic industry demand for rare earths, the central government reduced export rebates before eliminating them altogether in 2005. With the subsequent introduction of export duties for rare earths in 2007, China’s export strategy had entirely reversed. Policymakers had already implemented export quotas years earlier in 1999 to control total national production and curb smuggling, and would progressively reduce quotas every year between 2005 and 2010.

The dramatically lowered export quota announced in mid-2010 may very well have contributed to the continuing customs delays and export disruptions throughout October and November that year. But the intensity and timing of events in late September coincided far too closely with the China-Japan diplomatic crisis to discount as a bureaucratic coincidence. Even Chinese commerce minister Chen Deming drew a link between the two issues in a televised interview on 26 September, suggesting that Chinese businesses might be acting on their own patriotic initiative to pause shipments.

International governments certainly interpreted this rare earths shock as an undeclared set of sanctions. In retrospect perhaps these trade disruptions appear short-lived to observers today, but in the moment the affected actors saw these measures as indefinite and reacted with alarm. By October 3rd, Japanese officials were negotiating with the Mongolian government to develop new rare earth mining projects in Mongolia. By late October, Japan and Korea had announced a partnership in which Japan would help Korea survey potential deposits. Within a couple months, the United States and Japan were exploring projects in California, Australia, and Indonesia.

Implications of China’s Recent Export Restriction

Chinese policymakers likely weaponized rare earth exports opportunistically in the moment. The framework for export limits did genuinely originate out of industrial policy crafted with China’s national interest in mind, and well predated the tensions that prompted their temporary weaponization. Japan and China had been negotiating specifically over rare earth export quotas earlier in the year—including just weeks beforehand. With the issue fresh in recent memory, Beijing policymakers understood full well that this was a powerful lever in China-Japan relations.

The 2010 rare earths disruption and the current situation now unfolding between China and the United States share some similarities but also exhibit notable differences. As in 2010, the new Chinese export restrictions on gallium, germanium, and other critical mineral shipments to the U.S. clearly form part of a planned tit-for-tat response to the latest U.S. restrictions targeting the Chinese semiconductor industry manufacturing chain. In contrast to the 2010 incident, however, Beijing’s leverage of critical mineral supply chains is now overt and explicit, rather than ambiguous. Furthermore, whereas disruption of rare earth shipments to Japan may have served a narrow, temporary geopolitical purpose, U.S.-China competition for advanced technology leadership clearly spans a far broader scope, with no simple or near-term resolution in sight.

Meanwhile, with China now operating export control frameworks for everything from tungsten to magnesium to rare earth concentrating equipment to solar manufacturing machinery, the possibility of further escalation looms large—with significant implications for clean technology supply chains and trade.

The lesson from the 2010 rare earths shock and its origins emphasizes that Chinese export controls on critical minerals likely originated out of narrow national economic self-interest, rather than serving as part of some grand strategic conspiracy. But fundamentally speaking, the combination of overwhelming market share control and absolute authority over export policies means that Beijing can control market supply and international prices for a wide host of critical commodities with the stroke of a pen, an ability whose geopolitical utility is clearly now obvious to Chinese leaders. Should the right situation arise, the tools for bottlenecking trade already exist, including substantial latitude for subtle, undeclared, and plausibly deniable economic coercion in addition to the overt measures now enjoying the spotlight.

The only solution to this dynamic of self-perpetuating Chinese critical mineral market overconcentration is a forceful strategy of supply chain expansion and diversification. Such a strategy must dispense with the futile practice of tepidly ushering new entrants into unforgiving markets built upon lopsided terms of competition. Rather, governments must stubbornly and persistently ensure that alternative producers survive and multiply—in and of itself a necessary prerequisite for fostering competition and breaking monopoly power.

Ultimately, the world’s access to crucial advanced energy technologies cannot depend upon some People’s Liberation Army Air Force pilot’s ability to execute a reckless aerial maneuver around a Taiwanese patrol aircraft. The ease with which even the most optimistic clean energy commentator can imagine such a contingency should stress that both the geopolitical and decarbonization stakes of such efforts are high.

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Political pundits and cartoonists alike have long joked that contrary to voters’ implicit expectations, policymakers cannot simply turn a dial labeled “the economy”. Similarly, the Oval Office contains no dial that controls “national carbon emissions”. As Trump’s new policies mix with and in many cases supplant Biden-era policies, the next four years are uncertain enough that it’s hard to say what the trend in near-term US emissions will be. 

To a degree, this would have likely been true under a Harris-led successor Democratic administration as well. Efforts to significantly expand U.S. climate or clean energy policies beyond the Inflation Reduction Act would have faced daunting political constraints of their own. Biden’s goal of halving national emissions by 2030 in deference to 1.5C climate pathways was never plausibly within reach to begin with, despite the entreaties of international climate meetings and much of the mainstream environmental movement. Voter sentiment this year seems to suggest that the necessary politics for prioritizing climate as a top national policy issue just aren’t in place—and likely never will be. Most importantly, between worried speculation over everything from U.S. economic health amid a tariff war to drone attacks on Red Sea shipping to a rocky Chinese economy, uncertainty in how U.S. emissions will respond to shifting world events may well far outweigh the impact of relatively narrow changes to U.S. energy and environmental policies.

Rather, the critical question is how a Trump presidency and full Republican control of the federal government will influence U.S. competitiveness in advanced energy technologies. For the next four years and likely beyond, even the most ardent environmental advocates must recognize that technology, not regulation, will have to drive national momentum towards decarbonization.

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Likely, many climate advocates will devote much attention and critique towards other environmental policy actions under Trump that will matter far less for national and global energy transition efforts than those advocates might care to admit. For example, U.S. withdrawal from the Paris international climate agreement and possibly the UN Framework Convention on Climate Change will ultimately exert minimal real impacts on progress towards global climate goals. Many countries like Japan, the United Kingdom, and Brazil remain far off-track from near-term emissions targets and must reckon with that uncomfortable reality within years. Few governments seem inclined to make stricter, more ambitious voluntary climate commitments needed for the increasingly unreachable 1.5C climate pathway, but neither would countries court unnecessary condemnation by following the U.S. in exiting the Paris Agreement.

Environmentalists will also doggedly oppose Republican policies to boost fossil fuel production, build fossil fuel infrastructure including Gulf Coast natural gas export terminals, and roll back federal environmental regulations. The environmental impacts of such fossil energy development efforts will not be negligible, certainly. But neither are they catastrophic. For example, the Biden EPA itself estimated that its proposed stronger regulations for U.S. coal and gas-fired power plants would only reduce national emissions by an added 36 million tons of CO2 (Mt CO2) per year by 2035. Should the Trump administration roll back this rule, the stakes will amount to less than one percent of annual U.S. emissions, or just slightly higher than the city of Hong Kong’s emissions in 2023.

In contrast, the federal government’s approach to public energy sector innovation over the next few years may well define the long-term trajectory of the nation’s whole energy system. A well-developed advanced energy toolbox will prove critical for assuring U.S. technology leadership, reducing fossil fuel dependence, and curbing carbon pollution. Haphazard dismantlement of Biden-era policies supporting nuclear and other clean power sources, solar and battery manufacturing, or critical minerals projects could prevent the nation from developing powerful new capabilities and economic assets.

One major outstanding policy question, which received surprisingly little discussion in pre-election climate commentary, involves Trump’s campaign promises to impose new steep tariffs on overseas imports—suggesting possibilities like heavy tariffs on imports from Mexico, 60% tariffs on all goods from China, and 10% on goods from all other countries. Any and all of these trade actions would induce significant economy-wide effects and likely produce strong domestic and international political reactions.

From an energy sector perspective, supply chain costs would rise across the board, frustrating development of domestic energy infrastructure, strategic technologies, and manufacturing. When it comes to electricity grids, the United States faces a double import dependence, firstly on Chinese transformers and grid equipment, and secondly on the electrical steel needed to try and manufacture more transformers domestically. Hefty tariffs would significantly impact clean technology deployment as well—partly because the U.S. continues to import many technologies like batteries and solar modules from China. Protection and high market demand for products to replace tariffed imports could stimulate investment in some sectors, especially for upstream sectors that produce inputs and raw materials. But long lead times to establish such upstream industrial capacity might weaken the investment case for downstream domestic manufacturing projects. For example, a proposed battery gigafactory may find itself neither able to pay +60% extra for imported cathodes, nor able to wait several years for an alternative domestic cathode material plant to get up and running. Projects must also account for the risk that the administration backtracks on the tariffs as part of international negotiations or in response to political backlash, effectively changing the market landscape for competition again.

Such narrow business decision calculus would in turn unfold amidst broader national economic trends. Tariffs would raise costs of many products for households including clothing, shoes, many consumer goods, foods, electronics, appliances, pharmaceuticals, hardware supplies, automobiles and more. Increased consumer prices—and retaliatory tariffs targeting U.S. industries—could produce broad economic shocks like reduced household spending, financial sector volatility, and sector-specific job losses, potentially producing profound political discontent.

More narrowly for the energy sector, the incoming administration sees low value in renewable energy efforts and has committed to intensely scrutinizing federal spending in general, throwing the fate of many existing policies supporting strategic energy technologies into question. At the same time, Republican control of both House and Senate opens up large portions of the IRA to revisions, with Republican leaders eager to shrink and cut tax credit programs to make room for a desired extension of the 2017 Tax Cuts and Jobs Act.

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However, federal policymakers would be wise to refine IRA provisions using “a scalpel and not a sledgehammer,” as House Speaker Mike Johnson articulated in September. Republicans may feel skeptical that wind, solar, and electric vehicles are ready to assume large shares of the nation’s electricity and transportation sectors, but should consider that all of these technologies possess clear long-term value and growth potential. Across just North Carolina, South Carolina, Georgia, Michigan, and Texas, the IRA has stimulated over $70 billion in manufacturing investments across 141 projects. The U.S. cannot afford to fully cede U.S. competitiveness in these areas by indiscriminately eliminating IRA policy support or repealing the bill altogether. Energy policy observers have already begun theorizing that revisions to the IRA will seek a faster phaseout for tax credits for wind and solar electricity and elimination of the electric vehicle purchase tax credits, while preserving other incentives for advanced manufacturing and clean fuels. Indeed, it will be especially important for Congress and the new administration to continue vigorously supporting and developing emerging energy technologies like advanced nuclear, geothermal, carbon capture, and alternative fuels.

Since energy is an essential input into all, and especially advanced, economic activities, investments in these technologies will likely produce long-term economic gains that more than outweigh near-term expenditures—a value proposition emphasizing the importance of not only the continuity of innovation policies themselves but the federal infrastructure administering them. Indiscriminate cuts to agencies like Energy, Interior, FERC, USGS, NOAA, or the Nuclear Regulatory Commission may inhibit their ability to support national infrastructure efforts and stall important strategic efforts like critical mineral mapping, long-term energy system planning, and nuclear technology development. Any such cuts should be carefully and intentionally targeted to improve, not impair, administrative efficiency and state capacity. The incoming administration should similarly consider the importance of skilled industrial workers for building a strong future energy system and work closely with labor groups to align interests and foster workforce growth.

Ultimately the question of whether U.S. emissions tick marginally upwards over the next few years stands separate from the far more pivotal question of how to drive a sustained, structural, multi-decadal energy transition with an accompanying decline in carbon emissions. The recent election reinforces the hard lesson that politically-durable decarbonization depends upon making alternative energy sources more viable, as opposed to a principal strategy of hoping to regulate oil and gas into decline. Congressional legislation passed on very narrow margins via budget reconciliation, similarly, always confronts the risk of revision through the same mechanism.

In principle, room exists to align a new Republican federal government with an energy innovation agenda. Republican leadership will continue to favor near-term, America-first thinking on energy that prioritizes affordability, competitiveness, and energy security over climate. Such a philosophy could support structural energy sector trends that reduce emissions, if alternative technologies can convincingly demonstrate that they can advance these priorities. Clean energy transition proponents have long maintained—with ample supporting evidence—that this is precisely the promise that clean energy technologies like solar, batteries, geothermal, and nuclear offer. A strategic de-polarization of clean energy technologies along these lines may prove vital to establishing a new broad consensus on U.S. energy strategy that can advance both geostrategic and decarbonization goals.

Indeed, for the foreseeable future, a Trump White House makes it clear that the United States will have to find a way to advance the energy transition forward in the absence of muscular regulation on pollution. Technological progress and the strategic public sector support necessary to accelerate such innovation has never been more crucial to reducing pollution and securing a strong position for the U.S. in tomorrow’s global energy landscape. A robust political coalition must reemphasize to Congress and the new administration that America ultimately needs more than just wellpads and drilling platforms to guarantee a bright national future.

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