Response to the Department of Energy’s (DOE) request for information (RFI) on Accelerating Speed to Power/Winning the Artificial Intelligence Race

Earthjustice responds to a DOE request for information on accelerating power delivery for AI and industrial growth. The organization argues against reviving retired coal plants due to high costs and unreliability, instead advocating for the rapid deployment of wind, solar, and battery storage. It recommends that the DOE address speculative and inflated data center load forecasts, automate interconnection studies to reduce timelines, and deploy Advanced Transmission Technologies (ATTs) to increase grid capacity quickly. Additionally, it emphasizes the need for early community engagement in permitting and the long-term expansion of interregional transmission lines.

• Data center electricity demand forecasts are often speculative and inflated due to duplicative project requests and 'phantom' load, which can lead to the funding of unnecessary infrastructure and stranded assets.
• Reviving retired coal-fired generators is economically and technically untenable; these plants are often inefficient, inflexible, and unreliable, with some restart costs estimated as high as $1.9 billion for a single plant.
• New clean energy resources are the fastest and most cost-effective options for meeting near-term demand, with solar and batteries typically deployable within 1.4 to 1.7 years, compared to much longer timelines for gas, coal, and nuclear.
• The generator interconnection process is currently too slow, with a median duration of approximately five years; automating interconnection studies using tools like SUGAR could reduce study timelines from years to days.
• Advanced Transmission Technologies (ATTs), such as Dynamic Line Ratings and advanced conductoring, can increase grid capacity by up to 100% and be implemented significantly faster than traditional transmission projects.
• Early and meaningful community engagement is critical for the timely implementation of energy infrastructure and should be supported by DOE financial resources for technical assistance and public services.

APA

Earthjustice (2025). Response to the Department of Energy’s (DOE) request for information (RFI) on Accelerating Speed to Power/Winning the Artificial Intelligence Race. https://earthjustice.org/wp-content/uploads/2026/01/earthjustice-response-re-doe-speed-to-power-rfi.pdf

Chicago

Earthjustice. Response to the Department of Energy’s (DOE) request for information (RFI) on Accelerating Speed to Power/Winning the Artificial Intelligence Race. 2025. https://earthjustice.org/wp-content/uploads/2026/01/earthjustice-response-re-doe-speed-to-power-rfi.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Response to the Department of Energy’s (DOE) request for information (RFI) on Accelerating Speed to Power/Winning the Artificial Intelligence Race |date=21 November 2025 |url=https://earthjustice.org/wp-content/uploads/2026/01/earthjustice-response-re-doe-speed-to-power-rfi.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2025response, author = {{Earthjustice}}, title = {{Response to the Department of Energy’s (DOE) request for information (RFI) on Accelerating Speed to Power/Winning the Artificial Intelligence Race}}, publisher = {Earthjustice}, year = {2025}, month = nov, url = {https://earthjustice.org/wp-content/uploads/2026/01/earthjustice-response-re-doe-speed-to-power-rfi.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }