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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.
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Document type: Statement
DODGING THE FIRM FIXATION FOR DATA CENTERS AND THE GRID
The report critiques the 'firm fixation' approach where utilities meet surging data center demand by adding gas plants or refurbishing coal units. It identifies six defining features of data centers—agency, clustering, consumption profiles, flexibility, backup requirements, and modularity—that make them unsuitable for simple one-to-one matching with firm power plants. Instead, the author advocates for a 'system of systems' approach combining clean energy portfolios, battery storage, and demand-side flexibility. Key recommendations for policymakers include using the interconnection process as leverage to ensure cost causation and exploring demand-side resources, such as sponsoring household energy upgrades, to free up grid capacity.
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Document type: Report
Overbuilding coal capacity is not the solution
The document outlines strategies for India's power sector transition, emphasizing the need to improve coal plant flexibility, reform power purchase agreements, and scale up energy storage to manage solar integration and grid reliability.
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Document type: Report
Supplemental Report on Utility VPPs
The report identifies metering and telemetry as a primary barrier to scaling virtual power plants (VPPs) in the United States, citing inconsistent regional requirements and hardware restrictions. It evaluates five metering approaches based on affordability, reliability, and fairness to provide actionable recommendations for grid operators and policymakers. Additionally, it references a companion report specifically addressing utility VPPs where the utility acts as the service purchaser.
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Document type: Report
From Scrap to Supply: Circular Strategies for Critical Minerals
The United States faces significant supply chain vulnerabilities due to heavy reliance on imports for critical minerals, with China dominating the supply of 60% of U.S.-designated critical minerals. To mitigate this, the document proposes a shift toward a circular economy focusing on recycling and secondary recovery. Battery recycling, particularly for electric vehicles, could reduce the demand for mined lithium, nickel, and cobalt by approximately 10%, though currently fewer than 15% of U.S. lithium-ion batteries are recycled. Secondary recovery opportunities include extracting rare earth elements from acid mine drainage (AMD) and phosphogypsum waste from phosphate fertilizer production. Recent federal actions, including a March 2025 executive order and nearly $1 billion in Department of Energy funding, aim to prioritize domestic production, though the author argues for further long-term support for infrastructure and clearer circular economy standards.
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Document type: Research paper
Reducing curtailment in Chile: key to unlocking the full potential of renewable energy
Chile faces significant renewable energy curtailment due to limited transmission and storage capacity, with 5,642 GWh of solar and wind energy curtailed in 2024. The report recommends a National Curtailment Reduction Plan, the mass installation of Dynamic Line Rating (DLR) systems, minimum storage requirements for new projects in congested areas, and the creation of a formal demand response market. It also suggests strengthening electricity exchange markets with Argentina and Peru to improve system flexibility.
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Document type: Report
Reducir los vertimientos en Chile: una clave para aprovechar al máximo las energías renovables
Chile faces significant energy curtailments due to transmission bottlenecks and a lack of system flexibility, with 2024 curtailments reaching 19% of solar and wind generation. The document argues that while large infrastructure projects like the Kimal-Lo Aguirre line are planned for 2029, immediate action is needed through a 'Clean Flexibility Kit' including battery storage, Dynamic Line Rating (DLR), and demand response markets. It compares Chile's situation with other high-renewable systems like China, Ireland, and California to provide a roadmap of short-, medium-, and long-term recommendations to improve grid efficiency and reduce economic losses for investors.
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Document type: Policy brief
Geologic Hydrogen in Context
The document examines geologic hydrogen—molecular hydrogen formed naturally underground—as a potential low-cost, low-emissions energy source. It details three extraction pathways: natural accumulation, stimulated accumulation, and stimulated generation. While offering theoretical costs as low as $0.50 to $1.00 per kilogram and vast global reserves estimated at 5-6.2 trillion tons, the resource faces significant hurdles, including extreme resource uncertainty, a lack of commercial-scale extraction methods, and potential methane leakage during production.
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Document type: Fact sheet
Distributed solar and flexibility can ease Türkiye’s soaring cooling demands
Türkiye faces increasing electricity demand for cooling, which aligns temporally with peak solar generation. The report suggests leveraging over 120 GW of rooftop solar potential to reduce grid strain and recommends creating a comprehensive air conditioner database to improve demand forecasting. To ensure grid stability, the document advocates for grid-scale batteries, pumped-storage hydroelectric plants, and demand-side management to balance supply and demand.
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Document type: Report
Reality Check: We Have What’s Needed to Reliably Power the Data Center Boom, and It’s Not Coal Plants
The briefing challenges the notion that coal plants are necessary for grid reliability amidst a data center boom in the US. It asserts that coal plants are prone to unplanned outages, lack the ramp speed required for voltage-sensitive loads, and create grid congestion. The author suggests that over 95 percent of future demand can be met using scalable clean solutions such as battery storage and demand flexibility.
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Document type: Briefing
Nuclear weapons: beginner's guide
The document outlines the existential risk posed by the approximately 12,000 nuclear warheads held by nine nations. It explains the physics of fission and fusion weapons and analyzes the catastrophic effects of detonations, ranging from immediate blast and radiation deaths in urban centers to global climate disruption. The guide highlights the instability of 'launch on warning' postures and the potential for 'nuclear winter' and ozone depletion, arguing that even regional conflicts would cause global famine and societal collapse.
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Document type: Guide
Decoding the coal-power transition in China: facts, challenges, and opportunities
The report investigates the factors behind the acceleration of coal power approvals in China between 2022 and 2024, including rising power demand and energy security concerns. It details China's strategy to maintain supply continuity through flexibility retrofits and carbon-reduction pilots while proposing a transition toward clean power generation and storage technologies to replace coal's role in system reliability.
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Document type: Report
Optimizing Grid Infrastructure and Proactive Planning to Support Load Growth and Public Policy Goals
The US power sector is experiencing unprecedented load growth, requiring the grid to expand more than five times faster than in the previous two decades. To address this, the report recommends maximizing existing grid value through grid-enhancing technologies (GETs) and demand-side flexibility, accelerating connections via 'energy parks' and streamlined interconnection processes, and adopting proactive, scenario-based planning. It also suggests targeted affordability measures for low-income customers and specialized rate designs for large loads to prevent cost-shifting and stranded-asset risks.
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Document type: Report
Making Deterrence by Denial a Reality: Key Biological Defense Tools and Technologies
The document proposes a 'deterrence by denial' framework to dissuade the use of biological weapons by reducing the likelihood that such attacks would achieve their intended goals. This strategy is built upon four pillars: detection (early warning systems), response (preparedness and rapid action), mitigation (long-term resilience and medical countermeasures), and attribution (identifying the source of an attack). The authors assert that the necessary tools—including metagenomic sequencing, AI-driven surveillance, and advanced biomanufacturing—already exist and can be implemented through a whole-of-government approach. The paper also addresses challenges such as the 'dual-use dilemma,' where defensive biosecurity efforts may be misinterpreted as offensive programs, and the impact of disinformation on public health responses.
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Document type: Research paper
Harnessing Carbon Removal Opportunities in Desalination
The report examines how coastal desalination plants can integrate carbon removal technologies, such as Direct Ocean Capture (DOC), Electrochemical Ocean Alkalinity Enhancement (eOAE), and Direct Air Capture (DAC), by leveraging existing seawater pumping infrastructure and brine outflows. It identifies significant synergies, including reduced energy costs when using concentrated brines and potential energy savings of up to 30% through shared infrastructure. While theoretical carbon removal capacities are high—with eOAE potentially reaching 200 MtCO2/y under ideal conditions—the report highlights critical constraints such as high low-carbon energy requirements (up to 2.8 MWh/tCO2), the need for large-scale acid or chlorine byproduct offtake, and the necessity for rigorous environmental safety testing regarding pH and salinity changes in marine ecosystems.
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Document type: Report
Unlocking California’s Geothermal Potential
California possesses vast untapped geothermal potential, particularly in superhot rock resources, which could significantly support the state's clean energy goals. However, the industry faces substantial barriers, including a lack of long-term strategic planning, complex and lengthy permitting processes, outdated regulations, and interconnection uncertainties. The report recommends the creation of a statewide strategic plan, streamlining environmental reviews, updating well regulations, and establishing a clean energy infrastructure financing fund to attract private capital and accelerate deployment.
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Document type: Report
REGULATING HYDROGEN
The report outlines the regulatory complexities of the energy transition toward low-emissions hydrogen, emphasizing the high uncertainty of future demand. It provides specific guidance for electricity and gas regulators on managing infrastructure investments, pricing, and safety risks. The authors argue that regulators must balance government policy goals with their mandate to ensure affordable and safe service, warning against 'stranded assets' if hydrogen investments are based on hype rather than economic reality. Key technical concerns include hydrogen's propensity for pipeline embrittlement, low roundtrip efficiency in power generation, and the necessity of high-integrity emissions accounting to avoid greenwashing.
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Document type: Report
Water Retention Beneficial Management Practices
The International Institute for Sustainable Development has developed a replicable strategy for spatial targeting of water retention projects, such as wetlands and small naturalized dams, in the Canadian Prairies. This approach uses models like PTMApp and LiDAR-based digital elevation models to identify optimal sites for phosphorus interception, particularly in ungauged basins where data is limited. Such natural infrastructure is presented as critical for mitigating the increased flood and drought risks caused by climate change in the region.
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Document type: Report
Challenges and opportunities
The report examines the need for grid modernisation and policy alignment in ASEAN to support the transition to renewables. It highlights the current dominance of fossil fuels, the risk of curtailment seen in Vietnam, and the potential of clean flexibility options such as pumped hydro, battery energy storage systems (BESS), and demand-side management (DSM) to ensure grid stability and enable cross-border energy sharing.
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Document type: Report
Submission to the Clean Energy Regulator: Enhancing Method 2 for Coal Mine Emissions Reporting
The document critiques 'Method 2', a site-specific approach to estimating methane emissions at open-cut coal mines in Australia, noting that its compulsory implementation for large mines is undermined by measurement failures and a lack of independent verification. It advocates for the adoption of modern stationary and atmospheric measurement technologies and reforms in data collection and modelling to improve the accuracy of Australia's emissions inventory.
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Document type: Report