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Energy Innovation Oral Testimony to the United States Treasury Department and Internal Revenue Service 45V Clean Hydrogen Production Tax Credit (REG-117631-23)
Energy Innovation urges the US Treasury and IRS to uphold the 'three pillars' of incrementality, deliverability, and hourly time-matching for the 45V Clean Hydrogen Production Tax Credit. The organization warns that weakening these rules would lead to 'greenwashing' and significantly increase greenhouse gas emissions, potentially adding 200 to 1,000 million metric tons of CO2 annually by 2032. It argues that strict rules incentivize innovation in flexible technologies and new renewables, whereas loose rules would encourage a reliance on existing nuclear plants and fossil fuel ramp-ups. The testimony recommends rejecting broad exemptions for existing clean energy and maintaining the 2028 hourly matching phase-in date.
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Document type: Statement
NATURAL JUSTICE COMMENTARY ON THE INTEGRATED RESOURCE PLAN 2023
Natural Justice argues that the IRP2023 is a regression from previous plans and lacks a proper legal basis, as it functions as a policy instrument rather than an operational plan. The organization contends that the IRP2023 incorrectly prioritizes energy security over other national policy objectives like affordable access and environmental sustainability. It calls for the adoption of an Energy Justice Framework to address the rights of indigenous peoples and local communities, particularly regarding land, water, and gender equality, and recommends the development of a comprehensive Integrated Energy Plan (IEP) as mandated by the National Energy Act.
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Document type: Report
NGO Declaration on the Future of Nuclear Energy
The NGO Declaration on the Future of Nuclear Energy advocates for the rapid expansion of nuclear power to support global decarbonization and energy security, while emphasizing that speed must not compromise safety or security. It calls for coordinated leadership across government, industry, and finance, and suggests specific actions such as pooling resources for design orderbooks, implementing sustained investment policies, and maintaining independent regulatory capabilities.
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Document type: Statement
A solutions-based approach to the UK’s net-zero transition
The report argues that the UK is currently off track to meet its 2030 NDC and sixth carbon budget, necessitating a shift toward 'accountability and implementation'. It advocates for a systems-based approach that complements electrification with carbon capture and storage (CCS), low-carbon hydrogen, nuclear energy, and aggressive methane mitigation. Key recommendations include establishing a Methane Action Plan, creating a 'producer responsibility' policy for CO2 storage, and prioritising low-carbon hydrogen for 'no-regrets' industrial sectors like refining and ammonia production. The document also emphasises the need for international collaboration, particularly with the EU and emerging economies, to scale these technologies and maintain the UK's global climate leadership.
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Document type: Report
Decarbonising Poland’s Power System: A Scenario-Based Evaluation
The report argues that Poland requires a diverse technological portfolio—including wind, solar, nuclear, and carbon capture—to decarbonise its power system by 2050. Modelling of 19 scenarios indicates that relying on a narrow set of technologies increases system costs and infrastructure needs, while a 'base' scenario suggests a rapid transition involving a massive build-out of onshore wind and the introduction of nuclear power to replace coal.
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Document type: Report
A Vision for Poland’s Clean Energy Transition
The report argues that Poland, as one of Europe's most carbon-intensive economies, must adopt a diversified technology portfolio to achieve climate neutrality. It recommends a shift from coal (currently 70% of the power mix) toward a combination of renewables, nuclear energy, carbon capture and storage (CCS), clean hydrogen, and superhot rock geothermal energy. The authors emphasize that restricting technology options would significantly increase system costs and infrastructure needs. Key policy recommendations include implementing 'carbon contracts for difference' to advance CCS, prioritizing clean hydrogen for 'no regrets' industrial sectors, and reforming the nuclear industry through standardized, product-based business models. Additionally, the report calls for urgent action to reduce methane emissions from the oil and gas sector and the mapping of thousands of abandoned wells. Public polling indicates strong Polish support for advanced nuclear (63%) and superhot rock energy (66%).
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Document type: Report
Climate Change in the American Mind
A survey of 896 registered U.S. voters in Spring 2024 reveals broad support for clean energy policies and climate justice, though global warming remains a lower-ranked voting priority overall compared to the economy. While 62% of voters prefer candidates who support climate action, there is a sharp partisan divide in how important the issue is for the 2024 election. Majorities support transitioning to 100% clean energy by 2050 and the Inflation Reduction Act of 2022, but few believe the U.S. government is currently responding well to the crisis.
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Document type: Report
South Africa’s Energy Subsidies Inventory, 2023 Data, Definitions, and References
The report inventories major energy subsidies in South Africa, detailing fiscal support for oil, gas, electricity, coal, and nuclear energy. It highlights a significant increase in total quantified subsidies, reaching ZAR 118,317 million in FY 2022/2023, driven largely by carbon tax exemptions. The document describes specific mechanisms such as VAT exemptions for fuels, Free Basic Electricity for disadvantaged households, and various grants for state-owned enterprises like PetroSA and Eskom.
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Document type: Report
Le continent de Moscou : Les principes de l’engagement de la Russie dans la politique africaine
The document analyzes Russia's strategic pivot toward Africa as a means to diversify partners and evade Western sanctions following the invasion of Ukraine. It argues that while Africa is not a central priority for the Kremlin, it serves as a critical 'theater' for projecting power, securing natural resources, and challenging US-led unipolarity. The paper details Russia's approach across several sectors, including arms sales, nuclear energy, and mining, while highlighting the role of the Wagner Group in providing security in exchange for resource access. It concludes that Russia leverages African support at the UN to maintain its status as a global power and to promote a multipolar international system.
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Document type: Research paper
Actualización Plan Energético Nacional (PEN) 2022- 2052
The PEN 2022-2052 is a long-term planning exercise by Colombia's UPME to transition the national energy matrix toward sustainability and decarbonization. It analyzes five scenarios—Actualization, Modernization, Inflexion, Innovation, and Energy Transition—ranging from conservative technological updates to ambitious transformations. Key focus areas include the electrification of transport, the integration of non-conventional renewable energy sources (FNCER), the development of a hydrogen economy, and the potential introduction of Small Modular Reactors (SMR). The report emphasizes that while Colombia has the capacity for carbon neutrality, current trajectories may not meet the 2030 NDC goal of a 51% emission reduction without accelerated implementation of efficiency and substitution measures.
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Document type: Report
The road to COP29: Finance, geopolitical uncertainty, and the need for a new global paradigm
The document argues that while COP28 increased ambition through technology inclusivity and pledges to scale renewables and nuclear energy, the transition now depends on effective financing and planning amidst significant geopolitical instability. It highlights that 2024 is a critical year due to widespread democratic elections and rising trade protectionism, which may prioritize domestic security over climate action. Looking toward COP29 in Baku, the authors expect a focus on the new collective quantified goal on climate finance (NCQG), the phase-out of inefficient fossil fuel subsidies, and the need for more realistic macroeconomic modeling to address a global climate financing gap estimated between $4.5 to $10 trillion per year. The text suggests that because multilateral consensus is increasingly difficult, progress will likely shift toward regional climate weeks and bi- or trilateral partnerships.
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Document type: Research paper
Česká republika potřebuje zelenou sametovou revoluci
The document contends that the Czech Republic's climate policy is stalled by a 'mantra of productivism' and the dominance of fossil fuel and nuclear oligarchs who control significant media outlets. The author highlights a disconnect between the country's high per capita emissions and its political inaction, noting that progress is primarily driven by European Union pressure. The text criticizes the current government's focus on monumental infrastructure and nuclear energy over community energy and decarbonization. It calls for a new, pluralistic movement to dismantle the power of corporate interests and establish a green, social, and participatory democracy, drawing a parallel to the 1989 Velvet Revolution.
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Document type: Statement
EESI’s 2023 Climate, Environmental, and Energy Congressional Hearings Tracker
The EESI 2023 Climate, Environmental, and Energy Congressional Hearings Tracker catalogs hearings across numerous House and Senate committees. House activity was led by the Natural Resources (28 hearings) and Energy and Commerce (24 hearings) committees, focusing on energy security, grid reliability, and critical minerals. Senate activity was prominent in the Environment and Public Works (22 hearings) and Budget (10 hearings) committees, with a strong emphasis on the economic costs of climate change, infrastructure resilience, and the implementation of the Inflation Reduction Act and Infrastructure Investment and Jobs Act.
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Document type: Fact sheet
Nuclear power and net zero: too little, too late, too expensive
The author argues that the UK's 24 GW nuclear target by 2050 is unrealistic. Key barriers include the long lead times for nuclear projects (typically 15-20 years), the lack of mature, commercially available reactor technologies, and the difficulty of securing private investment for high-cost projects. The document highlights the failure of the EPR-1 design and the financial risks shifted to consumers under the Regulated Asset Base (RAB) model. It concludes that nuclear power is too slow and expensive to contribute meaningfully to the UK's electricity decarbonisation goals of 2030 or 2035.
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Document type: Research paper
6:1 – a ratio to successfully transform our energy system
The document advocates for a radical shift in banking practices to support the energy transition, specifically calling for a 6:1 investment ratio in favor of sustainable power supply over fossil fuels. Based on IEA Net Zero Emissions (NZE) projections, the author argues that total annual energy sector investments must rise to US$4.7 trillion by 2030, with energy transition investments exceeding US$4.2 trillion. Reclaim Finance emphasizes that this ratio should specifically target sustainable technologies—solar PV, wind, grids, and storage—while excluding biomass, nuclear energy, and Carbon Capture Use and Storage (CCUS), which it deems too risky or damaging. The document concludes that banks should set specific targets for sustainable power, end all support for fossil fuel expansion, and incorporate the 6:1 ratio into credible climate transition plans.
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Document type: Statement
6:1 un ratio pour transformer notre système énergétique
The document argues that limiting global warming to 1.5°C requires a radical shift in financial flows, moving away from fossil fuel expansion toward sustainable energy. Based on IEA data, it proposes a 6:1 ratio for banks: investing six times more in sustainable electricity supply than in fossil fuels by 2030. It specifies that 'sustainable' energy should focus on mature technologies like solar, wind, grids, and storage, while excluding nuclear, biomass, and carbon capture (CCUS).
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Document type: Statement
Clean Hydrogen NECP Playbooks for EU Member States
The document argues that clean hydrogen should be treated as a 'precious molecule' and prioritised for 'no regrets' hard-to-abate industrial sectors rather than being deployed indiscriminately. It recommends that EU Member States move beyond a sole focus on renewable ('green') hydrogen to include other low-carbon pathways, such as nuclear ('pink') and natural gas with carbon capture ('blue'), to avoid resource constraints. The guide emphasises locating production close to end-users to minimise transport inefficiencies and suggests that hydrogen in transport be limited to heavy-duty trucking, aviation, and shipping, while light-duty vehicles should prioritise electrification. Finally, it advises leveraging EU and national support mechanisms to fund 'champion' projects across the entire value chain.
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Document type: Guide
Small Modular Reactors
The document argues that SMRs can provide 'clean firm' power to decarbonize industrial systems and bolster energy security in the EU. It identifies that while 12 countries mention SMRs in draft NECPs and 7 plan investments, significant work is needed to improve these plans. The guide outlines five key recommendation areas: developing planning competencies (including techno-economic assessments and workforce studies), strengthening regional cooperation (such as joint licensing and a Joint Procurement Platform), enhancing financial frameworks (using contracts for difference and state aid), establishing national R&D and demonstration programmes, and creating industry-informed roadmaps. It specifically highlights the need for regulators to diversify competence beyond Light Water Reactors to evaluate advanced technologies like molten salt reactors.
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Document type: Guide
45V EXEMPTIONS NEED STRONG GUARDRAILS TO PROTECT CLIMATE, GROW HYDROGEN INDUSTRY
The report analyzes the U.S. Treasury's proposed regulations for the Section 45V Clean Hydrogen Production Tax Credit, specifically focusing on the 'incrementality' requirement. It argues that a proposed 'general carve-out'—exempting a percentage of existing clean energy from incrementality rules—would lead to significant 'dirty' hydrogen production and increase CO2 emissions by inducing fossil fuel power plants to run more often. The authors suggest that such a carve-out would also discourage investment in flexible electrolyzers and hydrogen storage. Instead, the report recommends targeted exemptions for curtailed power, retirement prevention, and binding emissions caps, provided they include rigorous guardrails to prevent emissions leakage and market manipulation.
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Document type: Report
Lessons from Kazakhstan for 2024
The document details Kazakhstan's efforts to eliminate its inherited Soviet nuclear and biological weapons legacies and its current leadership roles in the NPT and the proposed International Agency for Biological Safety (IABS). It recommends that Kazakhstan push for the elimination of tactical nuclear weapons, the creation of a nuclear weapons database, and the formalization of the IABS to address gaps in the Biological Weapons Convention.
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Document type: Research paper