Transforming the US Energy System

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In collaboration with Deloitte

TRANSFORMING THE US ENERGY SYSTEM

TRANSFORMING THE US ENERGY SYSTEM

EXECUTIVE SUMMARY

The transformation of the energy system continues to gain momentum as the economics of different technologies evolve and market demand patterns change .

Policies on the evolving energy system have changed many times over the last twenty years, but the direction of travel over the long term is set and continuing.

In 2024, the Climate Group and Deloitte launched Transforming the US Energy System Program (the Program) to help organizations understand issues of importance relating to the energy system for leaders from business and government and propose possible ways to overcome the barriers identified by the participants. The Climate Group works with governments, businesses, and communities to accelerate the energy shift. Deloitte works with clients across the public and private sectors to advise on technology, economic, and other measures that can help them meet the many needs for energy supply in the future.

The overall challenge of transforming the energy system for the future is highly complex and varies across regions and markets. Many discussions and publications can either be highly technical and/or just focus on a specific aspect of the whole system.

However, public and private sector participants of the Program identified several common and overriding challenges that can impact elements of the energy system. They are workforce development, collaboration and trust, finance, and changing demand patterns.

In seeking to address these generic issues in a meaningful way, the Program generated a range of potential demonstration projects to showcase how cooperative solutions could be delivered in a way that both meets current needs and provides a precedent for broad adoption. The rationale for this approach was to design and deliver projects that demonstrate different and more effective methods to navigate sector challenges in a way that could then be replicated across the country. The developed demonstration projects consider the topics of permitting, grid modernization, optimizing the future energy mix, and critical minerals.

SYSTEM-WIDE CHALLENGES

Throughout the Program, the participants named three generic barriers that impacted changes throughout the energy system: workforce development, collaboration and trust, and finance and demand .

Workforce Development

As the transformation of the energy system continues, the skills and capabilities of the workforce should adapt as well. These changes will likely be driven by the differing skills needed in the field for the construction and maintenance of different types of assets and from the level of automation and central control of an increasingly interactive system with multi-directional energy flows. Add the rapidly increasing energy requirements of AI applications and the workforce of today needs a major reconfiguration and boost to be able to meet the demands of energy supply tomorrow.

Workforce development hinges on the expansion or transformation of several human capital assets, specifically those advancing human sustainability. Human sustainability is the degree to which an organization creates value for people as human beings –dimensions that include opportunities for advancement, greater employability, stronger skills, and good jobs.1

Collaboration and Trust

The changes to the energy system are complex and are already affecting many of the norms that business, workers, and the community at large have been used to. To enable the change to continue in an efficient way requires all parts of the system to concurrently evolve. A wide range of changes is underway across the energy mix including the sources, the assets in the system, the ways it is traded, the demand patterns, the workforce skills required, and the regulatory frameworks.

To facilitate a change that has a wide societal benefit requires collaboration across stakeholder groups. For the collaboration to be successful, it should start with listening, understanding, and respecting the concerns and fears each party may have. As a solution gets designed and implemented, it then needs to include a consideration of these concerns, and there may need to be some level of compromise by all parties. Through a process such as this, trust can be established between the parties and support for the changes underway can be created.

For example, effectively utilizing federal tax credits for energy efficiency involves a mutual understanding amongst a multi-pronged stakeholder relationship. This stakeholder relationship is between the energy company, the workforce installing the efficiency assets, and the owners of homes and industry. Despite the workforce upskilling undergone for this aspect of clean energy jobs, the homeowner or business leader needs to understand the purpose of the new asset and the benefit to them to support the investment.

Finance and Demand

Both finance availability and the scale and patterns of demand can influence the pace and scale of change to the energy system.

The scale of increasing demand for data centers is one factor that presents huge challenges to the current energy system, with projections indicating that data centers could consume up to 3-8% of global electricity by 2030, and in some advanced economies reach up to 20%. 2 . It is also an opportunity to drive major changes in how new loads are met and the required energy system is built. while still serving the community that hosts the assets.

Historically, project finance of major energy assets has been underpinned by a stable, growing market and—often—long-term offtake agreements to take all of the power generated. As the market conditions rapidly change, the business models are changing as well and can move toward being higher risk with a consequent higher cost of funding. As energy systems evolve under these emerging pressures, different funders with different risk/return mandates may therefore be required.

DEMONSTRATION PROJECT DESIGN TO ENABLE CATALYTIC COLLABORATION

In designing the potential demonstration projects, the ambition of the participants was to approach some clear technical, business, or regulatory needs in a way that might demonstrate a more effective solution that would drive benefits to interested and affected stakeholders .

These critical generic barriers were subsequently integrated throughout the discussions and design iterations.

By taking an approach that seeks to meet the needs of stakeholders, requisite large-scale transformation has a significantly increased likelihood of being achieved. If done well, then this shift can illustrate pathways for change to be achieved more efficiently, more cost effectively, and with more benefits across the economy than would otherwise be the case.

DEMONSTRATION PROJECT 1

Permitting

The issue of permitting is a common yet significant barrier to delivering on energy system change outcomes, with permits for some projects requiring significant processing time for approval . From 2007 and 2015, the median approval duration was over nine years (109 months); while from 2016 and 2023, this improved to almost four years (47 months) . 3

This reduction in time is highly encouraging, but it is not clear if the trend will continue. The primary sources of delays are seen to be from resourcing constraints within the permitting body, the ability to allow parties not directly impacted to engage in the consultation, and—at times—extensive legal action. 4

As the US advances on energy system change, efficient permitting is critical to enable economic growth and innovation. While significant incentives are at times provided through federal and state programs, permitting processes are often characterized by delays and inefficiencies that can hinder the timely execution of projects.

Progress was initiated through the establishment of the Federal Permitting Improvement Steering Council (FPISC) in 2015 to convene interagency leaders and coordinate government-wide efforts to streamline processes for large infrastructure projects. 5 A centralized dashboard was established to track the status of federal permitting and review procedures for major infrastructure projects in key sectors, including renewable energy, transmission, mining, AI, and carbon capture, storage, and utilization (CCUS), 6 to enhance both transparency and accountability. Sector-specific reforms were introduced, including expedited processes and coordinated timelines. 7 Further, a task force was created in 2020 to specifically address permitting related to CCUS projects. 8

Established in 1969 under the National Environmental Policy Act (NEPA), the Council on Environmental Quality (CEQ) updated the NEPA regulations in 2020 in line with Executive

Order 13807 (2017) to streamline environmental reviews. 9 To expedite proceedings, key changes included: establishing a two-year time limit for completing Environmental Impact Statements (EIS) and a one-year limit for Environmental Assessments (EA); page limits for EIS (300 pages) and EA (75 pages); and categorical exclusions were established for projects with minimal environmental impact.10

In 2023, the National Association of Environmental Professionals (NAEP) noted a total of 162 EIAs were issued (both draft and final) with an average preparation time of 4.1 years, and of the 77 final EIAs, 22 were completed within the 2-year timeline.11

The Energy Act of 2020 established a program to improve the permit procedures for eligible projects and an interagency working group to coordinate efforts at the federal level. 12 As early as 2005, the Department of Energy (DOE) was empowered to be the lead coordinating agency for administrative and environmental reviews.13 A 2023 memorandum of understanding (MoU) signed by nine federal agencies provided the foundation for the DOE to launch the Coordinated Interagency Transmission Authorization and Permits (CITAP) as a centralized platform for transmission and generation infrastructure permitting and environmental assessments, enhancing the efficiency and effectiveness of the process.14

Similar centralized or “one-stop” approaches have been adopted in Australia and Finland to streamline permitting procedures and remove administrative barriers to green energy development.15

Foundation Case Studies

This is not a new issue and has been tested and explored over recent years in many global and national jurisdictions. Some examples of leading case studies that have already been implemented are profiled below.

Case Study #1: Arizona

Adopting a similar institutional approach, the Arizona Department of Environmental Quality (ADEQ) offers an expedited process specifically for companies that demonstrate a commitment to environmental stewardship. A project proprietor who voluntarily adopts permanent emission limitations, controls, or requirements beyond those mandated can circumvent classification as a Class I permit and avoid several administrative requirements. 16 The Resolution Copper Project—a joint venture between Rio Tinto and BHP—began the permitting process in 2013, received a draft Environmental Impact Statement in 2019, and is hopeful final approval should be forthcoming following a successful holding at the Arizona Supreme Court, despite a request for leave to the US Supreme Court.17

Case Study #2: Colorado

Colorado has an expedited process for small-scale mining operations that have limited impact including coordinated reviews and clear timelines for permit approvals.18 Similar streamlined processes are established in California through the California Environmental Quality Act (CEQA) and use of categorical exemptions, as well as New York.19

Case Study #3: Washington

In 2023, Washington State created an interagency coordinating council to improve permitting for clean energy projects through the development of an integrated process. 20 Two coordinated pathways were established for engaging appropriate agencies— projects of statewide significance and state-alone projects—with designated focal points to navigate the administrate process, localized processes for alignment with cities and municipalities, and dedicated procedures for consultations and meaningful engagement with Indigenous nations. 21

Demonstration Project Design

To demonstrate what good looks like, the following demonstration project design has been conceived to cover the major impacted parties by streamlining and focusing the consultation on those most impacted while delivering improved outcomes for all parties.

Concept

• Design a project that demonstrates how tactical alterations to planning and permitting regulations can enable accelerated energy system outcomes while increasing community support for the required infrastructure.

• Achieve this through focusing consultation on local and directly impacted communities only and adopting a more proactive consultation methodology.

• This is likely to require increased resourcing over a shorter period; so the added shortterm cost of this would need to be spread across the parties that stand to benefit, namely:

- the state that would secure improved energy resilience and accelerated system change;

- the infrastructure owner that would accelerate its development cycle; and

- the community that would benefit from accelerated outcomes.

Collaborators

To deliver this demonstration project effectively would involve participation of at least the following active collaborators:

• A permitting authority, likely state-based, seeking to find innovative ways to deliver energy outcomes that meet local community objectives;

• An infrastructure developer/owner that is looking to develop specific energy-related infrastructure within the permitting jurisdiction. This might be a transmission line wholly within the jurisdiction, an interconnector, or a generation plant;

• Potentially also include a financial institution that would finance the project once permitted and a major new load that would represent the anchor off-taker of the infrastructure once operational;

• An organized and active local community representative body that can engage in the design of the decision-making framework; and

• Independent adviser(s) to confirm that prospective outcomes meet energy, environmental, and social objectives. This could include non-governmental organizations (NGOs) a local university, or others.

The First Six Months

• Having secured and briefed the participants in the specific identified project, convene a full-day workshop that systematically considers the issues below. Participants in the workshop would be asked to bring suggested process modification suggestions to enable focused discussions on practical proposals.

• The workshop format could include:

- the strengths and weaknesses of the existing permitting process with respect to the project under consideration. This process would be designed to consider the costs and benefits to the energy system, the local economy, and the local community with respect to both environmental and social aspects;

- modifications to the permitting process that would change the balance of the costs and benefits across these factors, and conclude the indicative impacts on each factor. This would include not only possible changes to the regulatory frameworks but also more broadly looking at resourcing, financing, project design, community engagement, etc.

- prioritize potential modifications that appear to produce the optimum balance of decreased costs and increased benefits for further analysis.

• Complete a more detailed cost-benefit analysis of the proposed permitting process modifications.

• During another full-day workshop, present the findings of this analysis back to the participants for review and discussion with the aim of homing in on specific modifications that could be implementable. Then design a high-level action plan for the selected modifications to move toward implementation.

• Complete a more detailed action roadmap for review by the participants before commencing implementation activities.

• Convene a monthly steering group of the participants to maintain oversight of progress and proactively review potential areas of opportunity for AI solutions.

Road to Scale

• On the basis that the demonstration project is able to successfully meet the goals of the project, look to roll out the changes across energy infrastructure within that jurisdiction.

• Should there be inadequacies or unforeseen consequences emerging from the changes, then develop rectification measures to better achieve desired outcomes in the future.

• Work with other jurisdictions to highlight the improvements and benefits for all parties to scale the adoption of similar measures across other regions.

• Work with convening bodies to enable lessons learned across different jurisdictions to the shared to drive ongoing improvements in the process to create additional benefits

DEMONSTRATION PROJECT 2

Grid Modernization

As energy consumption and storage expand as a component of the energy system, grid modernization in the US will be critical to maintaining living standards; managing increased demands from electric vehicle use, households, and industry; and positioning the economy for growth post-2030.

Global energy demand is expected to rise by an average of 3.4% annually from 2024 to 2026. 22 US consumption is expected to rebound by 2.4% over the same period following a 1.6% decline in 2023, with demand driven by industry, electrification of the vehicle fleet, heat pumps, and data centers. 23 With the ongoing move toward different generation sources and fuel types, the aging US grid infrastructure remains a vulnerability and an inhibitor to the changes already underway.

With 70% of the US electricity grid over 25 years old and the critical need to double–or triple–transmission infrastructure to accommodate expected demand, 24 the “Building a Better Grid Initiative” was launched in 2022, providing US$13 billion of investment for grid modernization. 25 The initiative supports the upgrade and replacement of transmission capacity which is estimated at US$360 billion by 2030 and US$2.4 trillion by 2050. 26

Cost of blackouts to the US economy have been estimated to be between US$44-150 billion annually, 27 and infrastructure limitations undermining power reliability have been identified as a key challenge for data centers, among other industry growth sectors. 28 As we observe the convergence of AI demand, enhanced expansion of renewable energy, and increased connectivity across the economy, grid modernization is a key priority to provide the flexibility and resilience needed for the post-2030 economy.

Foundational Case Studies

Case Study #1: The United Kingdom

The United Kingdom announced in November 2024 an enhanced Nationally Determined Contribution (NDC) committing to economy-wide greenhouse gas (GHG) reductions of 81% below 1990 baselines by 2035, 29 and is leading on energy system transformation among developed economies. Grounded in collaboration among regulators and utilities, the UK adopted an approach to grid modernization that promoted flexibility, innovation, and performance. 30 By transitioning to a smart, localized and flexible energy system, the UK aimed to embed responsiveness, agility, and resilience in their transformation, and projected to reduce operational costs by up to £10bn (~ US$12.48bn) per year by 2050, and cumulatively £30-70bn (~US$37.44-87.36bn) from 2020-2050. 31 To achieve this, the UK prioritized working with customers to understand and develop the appropriate infrastructure and regulatory environment, remove systemic and technological barriers to the grid. These included storage solutions and interconnections, reforming markets to incentivize flexibility from producers, digitization of the system for greater visibility into energy assets, and monitoring and ongoing refinement of the plan going forward. 32

Case Study #2: Massachusetts

Massachusetts created the Grid Modernization Advisory Council (GMAC) as a multistakeholder advisory body to review and direct investor-owned utilities in the State. 33 Through use of Electric-Sector Modernization Plans (ESMPs), distribution system investments, improvements, and 5-10 year forecasts are provided with GMAC providing recommendations to improve grid reliability, increase adoption of renewable and distributed energy resources, promote electrification, and embed resilience to climaterelated grid disruptions. 34

Case Study #3: New York

New York began a process to modernize transmission infrastructure in 2014, prioritizing research and development, collaboration, and localized programs to spark innovation. 35 As a result, the Joint Utilities was created to bring together primary providers covering 13 million users to collectively and collaboratively respond to recommendations of the New York Public Service Commission (NYPSC) and provide Distributed System Implementation Plans (DSIPs) to outline progress and future planning. 36 The New York State Energy Research and Development Authority (NYSERDA) has run a range of programs to support development and scalability of grid technologies and solutions, including the current Grid Modernization Program. In 2024, the NYPSC initiated a flexibility study to be finalized by the end of the following year. 37 Concurrently, the Future Grid Challenge provided funding for eligible projects that develop or demonstrate improved grid functionality, transmission, capacity, or business operations. 38 Progress in New York is grounded in a policy framework supporting climate action and enhanced integration of renewables into the energy mix. 39

Case Study #4: California

Beginning in 2006 with the integration of advanced meters and continuing in 2009 with innovative investments and smart grid pilots, California has explored and accelerated development of decentralized energy resources to build resilience and modernize grid infrastructure and functionality. 40 Over 2009-2013, a regulatory architecture was developed, enabling data sharing and network connection, 41 and strategic planning with large utilities required to submit annual Smart Grid Development Plans. 42 In 2022, the California Energy Commission adopted new standards for price transparency among utility providers to enable smart devices to help shift usage and support load management, 43 and in 2023 adopted a target of 7,000 megawatts (MW) of load shifting capacity by 2030 to more effectively utilize the 38,000 MW of state-funded projects. 44 Aiming to accelerate innovation, a predominant utility in the state launched a competition to address priority challenges from their R&D strategy and capped off by a summit and pitch fest. 45

Demonstration Project Design

This demonstration project design would seek to identify where material local impacts can be delivered that meet multiple objectives through both quick wins and building foundations for systemic change that can enable rapid replication across other localities.

Concept

• Design a local project that combines public, private, and community participants to build a solution that delivers a step change in the adoption of solutions with multiple benefits. The project would, however, be fundamentally focused on addressing specific local community needs.

• There are many examples in the US and globally of project designs, some of which are highlighted above; but rather than seek to adopt previous experiences as delivered, they seek to select elements of other projects and combine with a locally focused methodology that addresses specific local community challenges.

• Local issues at the heart of the project design may include one or more of energy poverty, energy security, or even local housing or employment challenges. By putting the community at the center of design, it may be possible to increase support for and the speed of change across other communities seeking to benefit from the associated investment and modernization.

Collaborators

To deliver this demonstration project effectively would involve participation of the following active collaborators:

• An organized and active local community representative body;

• The local distribution network company;

• Potential technical system integrators; and

• The relevant city or state government departments and/or regulators.

The First Six Months

• Work with community representatives to consider key principles of both the process to deliver equitable community outcomes and specific local issues that would ideally be addressed.

• Take a community-focused perspective to a combination of the network company and the technical system integrator and design a proposal that could address some or all the identified issues through the delivery of accelerated energy solutions.

• In addition to technical solutions such as demand response community batteries, rooftop solar, or VPPs, consideration should be given to workforce resourcing solutions from the community, shared financial benefits with the community, and options for economic development within the community.

• Bring together parties to present, review, and discuss the proposed solutions and agree on demonstration implementations to test the concepts in practice.

Road to Scale

• In addition to documenting the process and its successes and failures, develop a clear pathway for repeating the process across other communities within the region and beyond.

• Celebrate the successes widely to demonstrate how a community-centric development plan can achieve multiple benefits more effectively.

• Develop a playbook for both communities and network operators to approach the challenge in a different way and seek to find collaborative win-win outcomes. Transforming

DEMONSTRATION PROJECT 3

Diversification of the energy mix

Broadening of the energy mix engages both federal and state-level authorities and has been addressed across multiple areas, including clean energy adoption, mobilization of finance, workforce development, and cost management in demonstrated in some of the case studies included in this report.

At the federal level, targeted incentives support expansion and adoption of innovative technologies and energy solutions. Examples include the Investment Tax Credit, which provided a 6% credit for production services brought online that year, and the Production Tax Credit, which granted a 0.3 cents/kilowatt credit for qualified clean energy production (wind, closed-loop biomass, and geothermal energy) over a 10-year duration, and 1.5 cents/kilowatt hour for others (open-loop biomass, landfill gas, trash, qualified hydropower, and marine and hydrokinetic renewable energy). 46 Rebates are utilized for the purchase of energy-efficient appliances, with standards for both appliances and buildings regularly updated to reflect technological advancements. 47

The Federal Energy Regulatory Commission regulates the transmission and wholesale market of electricity in interstate commerce to ensure rates, terms, and conditions have continuity; issues licensing and oversight of energy markets; conducts a review of the environmental impact assessment (EIA) for proposed energy projects; supports grid modernization and renewable energy integration; and provides dispute settlement for conflict between energy companies. 48 Research and development is supported through several grant-based schemes and promotion of public-private partnerships (PPPs) to drive innovation and enhance energy access, reliability, and affordability. 49

An Integrated Resource Plan (IRP) is a comprehensive decision-support tool used by states to evaluate and plan for meeting future energy needs in a cost-effective and reliable manner. Multiple states require utilities to develop and submit IRPs, often integrating a range of resources and policy goals, including: California, to meet GHG reduction targets while maintaining reliability and affordability;50 Colorado, Minnesota, Oregon and Washington which considers renewable energy, energy efficiency, and demand-side management;51 Michigan, North Carolina, Indiana and Virginia, which includes both renewable energy and energy efficiency measures and integrates reliability and cost-effectiveness;52 and Georgia, grounded in reliability and affordability of service, considering both supply-side and demand-side resources without designating a source. 53 These approaches illustrate how the IRP process was tailored to be responsive to localized variables and considerations.

Similarly, Renewable Portfolio Standards (RPS) have been utilized by several states as a mechanism to integrate diversified energy sources. Multiple jurisdictions require a percentage of electricity to be derived from renewable sources including: (i) California: 60% by 2030;54 (ii) Colorado: 30% by 2020 with targets for distributed generation;55 (iii) Hawaii: 40% by 2030, 100% by 2045;56 (iv) Massachusetts: 35% by 2030;57 (v) Minnesota: 25% by 2025 with a 31.5% by 2020 for designated utility providers;58 (vi) New York : 70% by 2030 and 100% zero emission by 2040;59 (vii) Oregon: 50% by 2040 for large utilities;60 (viii) Virginia: 100% by 2045;61 (ix) and Washington: 15% by 2020 coupled with efficiency measures. 62 Hawaii also sets an energy efficiency portfolio standard of 4300 gigawatt hours of efficacy achieved by 2030. 63

Foundational Case Studies

Case Study #1: New York

To advance cost management, New York implemented Demand Response Programs (DRPs) to reduce peak electricity demand, enhance grid reliability, lower energy costs, and promote sustainability outcomes. By incentivizing consumers to adjust their energy usage during critical periods through capacity payments, these programs assist in balancing supply and demand, reducing blackouts, and reducing the need for additional power generation. 64

Case Study #2: California

California integrated a Community Choice Aggregation (CCA) program, which allows subnational authorities and other authorized entities to aggregate the electrical load to select electricity sources, negotiate power purchase agreements, and develop energy programs that align with local priorities and enable achievement of renewable energy consumption targets. 65 This statutory framework supports California’s broader environmental and energy goals by enabling communities to choose cleaner energy sources, reduce GHG emissions, and foster local economic development.

Case Study #3: Hawaii

Hawaii launched the Clean Energy Initiative Program (HCEI) and the Energy Systems and Technology Training program as two critical components of the legislative framework aimed at advancing the state’s clean energy goals and fostering the development of green jobs. By aligning policy goals with workforce development through incentivization of PPPs and green skill development, these programs aim to create a sustainable pathway for achieving Hawaii’s environmental and economic objectives. 66

Demonstration Project Design

This demonstration project would seek to take a specific multi-state region of the country, such as the Northeast, and develop the most economically efficient system design plan to achieve both near- and long-term energy, environmental, and societal goals while incorporating broader economic resilience and benefits.

Concept

• Bring together a range of interested stakeholders to build an independent set of scenarios that enable a specific region to transform its energy network over a specific timeframe.

• Structure the initiative so that it brings in multiple stakeholder views, tests the boundaries of assumptions, and ultimately presents a small number of economically and socially rational options to underpin long-term planning and investment.

Collaborators

• To deliver this demonstration project effectively would involve the participation of the following active collaborators:

- The distribution network companies;

- Local and state governments;

- Energy generation and infrastructure developers; and

- Potential technical system integrators

The First Six Months

• Bring together major parties across the region to agree on fundamental design principles based on leading practices both in the US and globally.

• Agree on the scope of work, timeframe, and funding model to deliver a practical guide to the most economical solution to regional energy transition.

• Develop governance and advisory board structure to ensure solution design meets the needs of stakeholders.

• Agree on a lead collaborator to lead project management of solution delivery.

Road to Scale

• Publish outcomes, including proposed implementation pathway.

• Seek to move toward specific procurement processes for that region to implement.

• Provide the design principles and clear step-by-step process for achieving optimal outcomes.

• Look to replicate across other regions to enable energy system change acceleration.

DEMONSTRATION PROJECT 4

Critical Minerals

As the global economy shifts to electrification, access and utilization of critical minerals is a key strategic supply chain consideration. Essential for production of renewable energy technologies and electric vehicles, critical minerals have weathered price volatility as demand continued to demonstrate strong growth, with lithium increasing by 30%, and nickel, cobalt, graphite, and rare earth elements increasing by 8-15% in 2023. 67 Market value of critical minerals is projected to more than double along net-zero scenarios, reaching US$770 billion by 2040. 68

In the same year, production of critical minerals had significant geographic concentrations globally including China producing upward of 60% of rare earths and 80% of graphite, Democratic Republic of Congo (DRC) providing over 60% of cobalt, Indonesia producing over 50% of nickel, and Australia providing over 40% of lithium. 69

Recognizing the strategic importance of critical minerals for national security, economic growth, and technological innovation, the Energy Act of 2020 provides a broad definition and empowers the Secretary of the Interior, working in conjunction with the US Geological Survey, to designate and publish a prioritized list for governance. 70 The 2023 list included 22 critical minerals. 71 Under the Infrastructure Investment and Jobs Act (IIJA), critical minerals projects were integrated into the innovation energy loan guarantee program initiated through the Energy Policy Act (2005) to enhance domestic production. 72 Further funding was provided for the United States Geological Survey (USGA) research facility, to rare earth demonstration facility, in collaboration with academic partners, as well as supporting research in extraction, recycling, and reclamation strategies, techniques, and technologies. 73 Lastly, the 2023 National Defense Industrial Strategy (NDIS) released by the Department of Defense identifies the need to increase domestic production and stockpiling of critical minerals as a strategic defense imperative. 74

Further efforts would be needed to scale up transparency tools across the market to increase investor confidence and incentive structures that can allow domestic organizations to compete with state-backed entities abroad.

Foundational Case Studies

Some of the existing and relevant examples of critical minerals acceleration are provided below .

Case Study #1: California

At the state level, several institutional and collaborative approaches have been developed to further domestic capacity. California created the Lithium Valley Commission, a 14-member public-private multistakeholder body, to evaluate and provide recommendations on areas of opportunity for lithium extraction and use in the state. 75 Recommendations included regulatory reform, research and development, infrastructure expansion, and collaborations. 76 Lithium Valley was prioritized in the California Blueprint, 77 and Salton Sea Lithium Valley has been identified as holding significant resources, with the project advanced by Controlled Thermal Resources 78 given approval in January 2025 to advance following legal challenges by community organizations. 79

Case Study #2: Nevada

Nevada established a Division of Minerals to facilitate exploration and development of mineral resources, which aims to ensure regulatory compliance and environmental stewardship. 80 A specialized multistakeholder commission was developed, including energy and resource development and processing expertise, as well as community representation, to provide recommendations on policy, inform the operations of the division, and report on progress. 81 The Nevada Governor’s Office of Economic Development (GOED) also supports development of lithium and other critical mineral projects through tax incentives and infrastructure development. 82 In 2023, GOED prioritized development of lithium extraction and supply chains in the 5-year strategic plan, including supporting research and development, scaling workforce opportunities, and expanding partnerships. 83 The Nevada “Lithium Batteries and Other EV Materials Loop” Regional Technology and Innovation Hub (Nevada Tech Hub), led by the University of Nevada at Reno, is a nationally recognized hub acting as a designated focal point to support business expansion and build capacity in the region. 84 A collaboration between Lithium Americas Corp. and the US Department of Energy, Thacker Pass Lithium Project received a US$2.26B loan in 2024 to develop one of the largest lithium deposits in the US in collaboration with research institutions to advance extraction technologies. 85 The Nevada Battery Coalition is an advocacy group composed of companies along the whole battery supply chain that informs both the public and private sectors regarding the economic, environmental, and national security issues associated with the battery supply chain in order to strengthen Nevada’s position as a leading battery center in North America. 86

Case Study #3: Alaska Industrial Development and Export Authority (AIDEA)

Similarly, the Alaska Industrial Development and Export Authority (AIDEA) is empowered to provide financing and development support for critical mineral projects, the Department of Natural Resources (DNR) Mining Section manages mineral resources and supports exploration and development through regulatory oversight and technical assistance. 87

Lack of a widespread grid means that energy is essential in Alaska and is frequently the biggest factor preventing development. Innovative financing regimes are essential to overcoming that barrier, as is a willingness to work with native corporations. As an example, Teck Alaska’s Red Dog Mine has worked with NANA Regional Corporation, an Alaska Native Corporation operating in northwestern Alaska and owned by more than 14,500 Iñupiat shareholders, at every stage of development to be inclusive of local indigenous populations. Over 50 percent of mine personnel are NANA shareholders. Through a Payment In Lieu of Taxes (PILT) to the Northwest Arctic Borough, Red Dog has paid $140 million dollars since mining began in 1989. Through the Alaska Industrial Development & Export Authority, the State of Alaska provided loans to the mine operator to construct the DeLong Mountain Transportation System. 88

Demonstration Project

Supply chains overall, and critical minerals, are a potential brake to the progress of energy system change in the US. If the supply chain capacity and resilience is not increased, then the cost or speed of change will likely be slowed.

Concept

This demonstration project could build an innovative collaboration along a specific energy value chain and assemble the participants to explore innovative commercial ways to bring forward critical mineral production and drive benefits across participants.

For example, as discussed in the Alaska case study above, a lack of energy infrastructure and supply can be a major barrier to critical mine development. Including infrastructure developers into the design and financing discussion and enabling the connection between a blue-chip off-taker from the mine and the infrastructure financier may help overcome development delays.

Collaborators

Along a specific identified value chain commencing with a critical mineral mine, bring together key stakeholders, including:

• Critical mineral producer;

• Intermediary product processors, manufacturers, assemblers, as relevant;

• Final product provider;

• Final product purchaser for some or all of the product from the production facility;

• Utility infrastructure provider;

• Project financier provider; and

• Relevant regulatory bodies for mine and production facility approvals.

The First Six Months

• Decide on the value chain - the initial step would be to identify and then confirm the value chain under consideration through consultation with key players in the market. There should be a focus on where there appears to be current or impending supply constraints and, consequently, how accelerating commodity commercialization through this value chain would contribute more quickly meeting growing demand.

• Assemble Participants - working with one or more key value chain participants, identify the full value chain and engage with potential participants to bring together a full actual current or potential value chain.

• Map Current State - map out the business-as-usual process for receiving approvals and finalizing commercial arrangements at each step of the value chain. The focus here should be on specifics throughout the process where there are risks of delays or other barriers, and hence identifying potential points of

intervention to accelerate activation.

• Design Workshop – having mapped the process from early stage to final product sales and identified potential areas for positive interventions, convene the full value chain for a workshop to explore innovative ways to accelerate the process. This might involve regulatory changes, innovative commercial arrangements that span multiple parties, or the potential to bring alternative business models or parties to enable a different route to market.

• Design Commercial Structures - having identified a series of potential innovative interventions, assess practicalities of implementation and seek to design a workable demonstration agreement that the participants are willing to adopt. This could, for instance, include forward-looking and long-term offtake agreements by the processor tied to end product sales agreements with the end purchaser.

Road to Scale

• Having proven out the use case for the specific value chain, seek to replicate across other instances of that same value chain with other industry participants.

• Assess and publicize how the same structures could be replicated across other similar critical mineral value chains and engage industry bodies and major players to understand and appreciate the potential benefits of adoption.

SCALING DEPLOYMENT

Conclusion: Toward a Transformative Regulatory and Industry Ecosystem for Critical Minerals and Energy System Transformation

Transitioning to a sustainable, resilient, digitally-connected, and AI-enabled economy places enhanced demand pressures on the energy system as well as on critical minerals supply chains. The variables identified—PPPs, streamlined permitting, R&D investment, workforce development, incentive programs, interagency coordination, sector-specific reforms, and stakeholder engagement—are not isolated levers but components of an interconnected system. Their effective orchestration is essential to address the multidimensional challenges facing the sector and to help it realize the potential for economic, environmental, and strategic advancement.

1 Public-Private Partnerships: The Foundation of Collaborative Innovation

PPPs serve as a cornerstone for leveraging collective expertise, distributing risk, and accelerating innovation. The complexity of the critical minerals and energy landscape— marked by rapid evolution in AI and technology, volatile markets, and global supply chain vulnerabilities—involves collaboration across government, industry, and academia to advance ambition. PPPs enable pooling of resources and knowledge, fostering an environment where innovation can thrive while risks are shared and mitigated. Importantly, these relationships can bridge the gap between public policy objectives and private sector agility, promoting regulatory frameworks that are both robust and adaptable to emerging technologies and market needs.

2 Streamlined Permitting Processes: Balancing Efficiency and Rigor

The permitting process often represents a bottleneck in project development, with protracted timelines and overlapping requirements stifling innovation and investment. Streamlining these processes—while upholding environmental and safety standards—is critical. Important components include a regulatory architecture that is both efficient and accountable, reducing red tape without compromising due diligence. Modernizing permitting can be achieved through digital platforms, clear timelines, and standardized procedures, facilitating faster project approvals and de-risking investments. Effectively leveraging frontier technology to optimize this process is a significant area of opportunity.

3 Research and Development: Securing Technological Sovereignty and Supply Chain Resilience

Investment in research and development underpins the sector’s ability to reduce dependency on foreign sources, enhance supply chain resilience, and drive technological progress. R&D initiatives—whether focused on extraction, processing, recycling, or alternative materials—are vital for maintaining competitiveness and enabling sustainability. They also create pathways for circular economy models, which aim to reduce waste and environmental impact. A regulatory environment that incentivizes R&D through strategic use of public funding catalyzes innovation and helps domestic industries remain at the forefront of global technological trends.

4 Workforce Development: Building Human Capital for a Dynamic Industry

A skilled workforce is the backbone of any thriving industry, particularly in sectors as complex and evolving as critical minerals and energy system transformation. Workforce development programs—including technical education, vocational training, and upskilling—are essential to meet current and future labor demands. These initiatives should be closely aligned with industry needs, ensuring that curricula and training pathways reflect technological advancements and operational realities. Public policy can play a pivotal role by supporting education-industry partnerships, apprenticeships, and continuous learning programs, thereby fostering a talent pipeline that sustains long-term sectoral growth.

5 Incentive Programs: Aligning Financial Mechanisms with Sustainable Development

Financial incentives—such as grants, tax credits, and low-interest loans—are powerful tools for steering industry behavior toward energy system priorities. Well-designed incentive programs can lower the barrier to entry for innovative projects, de-risk investments in new technologies, and encourage responsible resource management. However, incentives should be carefully structured to avoid unintended consequences, such as market distortions or unsustainable practices. Alignment with broader economic policy objectives—such as emissions reduction, local content requirements, and community benefits—is crucial to make sure that incentives drive broad, long-term value creation.

6 Interagency Coordination: Overcoming Fragmentation for Cohesive Action

Governance architecture related to critical minerals and energy systems are often fragmented, with overlapping mandates and competing priorities across agencies. Interagency coordination—through working groups, councils, or centralized task forces— enables a unified approach to policy development, permitting, and oversight. Institutional coordination mechanisms help minimize duplication, harmonize standards, and ensure that policy interventions are mutually reinforcing.

7

Sector-Specific Reforms: Tailoring Solutions to Unique Challenges

Sector-specific reforms—grounded in robust data and stakeholder input—enable targeted interventions that enhance outcomes for each industry segment. This approach facilitates regulatory frameworks that are fit-for-purpose, flexible, and responsive to evolving sectoral landscapes.

8 Stakeholder Engagement: Embedding Transparency and Inclusivity

Effective stakeholder engagement is integral to the legitimacy and success of regulatory and industry initiatives. Public participation—through consultations, hearings, and advisory panels—ensures that the voices of communities, businesses, and other affected parties are heard and considered. Transparency in decision-making fosters trust, accountability, and social license to operate, which are critical for project acceptance and long-term viability. Moreover, inclusive engagement processes can surface local knowledge, identify potential risks, and generate innovative solutions that might otherwise be overlooked.

Interconnections and the Imperative for Systemic Transformation

The variables outlined in this report illustrate some of the deep interdependence and connectivity across the energy system transformation. Effective PPPs often rely on clear regulatory frameworks and robust stakeholder engagement; streamlined permitting is facilitated by interagency coordination and transparent processes; and the success of R&D initiatives is contingent on workforce development and targeted incentives. These interconnections underscore the need for systemic thinking—an approach that recognizes the sector as an ecosystem where changes in one domain reverberate across others.

Systemic thinking highlights the risks of siloed interventions, where well-intentioned reforms in one area may be undermined by inertia or misalignment elsewhere. For instance, accelerating permitting without parallel investments in workforce development or stakeholder engagement may result in projects that are technically feasible but socially or environmentally unsustainable. Conversely, robust engagement and incentives, absent efficient regulatory processes, may fail to deliver timely or scalable outcomes.

LOOKING FORWARD

Toward a Cohesive, Future-Ready Sector

Industry transformation across energy, infrastructure, and of the critical minerals sectors is both a strategic imperative and a complex, multi-faceted challenge. Achieving this transformation requires more than piecemeal reforms; it calls for a broad, systemic approach that integrates the variables discussed above into a coherent policy and industry framework.

By fostering robust PPPs, streamlining permitting, investing in R&D and workforce development, designing effective incentives, enhancing interagency coordination, implementing sector-specific reforms, and embedding transparent stakeholder engagement, policymakers and industry leaders can create an enabling environment for sustainable, resilient, and innovative growth.

Success in this endeavor includes the evolving regulatory architecture and the alignment of incentives with both industry needs and societal objectives. Systemic thinking— grounded in collaboration, adaptability, and evidence-based policy—will be important to help unlock the sector’s full potential and secure its role as a driver of economic prosperity in the decades to come.

ENDNOTES

1 Deloitte, 2024 Global Human Capital Trends (Deloitte, 2024), www.deloitte.com/content/ dam/assets-zone2/dk/en/docs/services/consulting/2024/DI_Global-Human-Capital-Trends-2024.pdf

2 Deloitte, Powering AI (Deloitte, 2024), www.deloitte.com/global/en/issues/climate/ powering-ai.html; IEA, Energy and AI, (IEA, 2025), https://iea.blob.core.windows.net/ assets/601eaec9-ba91-4623-819b-4ded331ec9e8/EnergyandAI.pdf

3 L Bauer and W Edelberg, “Eight facts about permitting and the clean energy transition” Brookings Research (May 2024), www.brookings.edu/articles/eight-facts-about-permitting-and-the-clean-energy-transition/;

4 R Sud and S Patnaik. 2022. “How Does Permitting for Clean Energy Infrastructure Work?” Brookings Institution, Washington, DC.

5 US, Fixing America’s Surface Transportation Act of 2015 (Public Law 114-94) (4 December 2015), Title 41, www.govinfo.gov/content/pkg/PLAW-114publ94/pdf/PLAW-114publ94. pdf; 42 USC Chapter 55, Sec 4370m-1, https://uscode.house.gov/view.xhtml?path=/prelim%40title42/chapter55/subchapter4&edition=prelim. [FAST]

6 Ibid, FAST, Sec.437m(6): Including: “infrastructure for renewable or conventional energy production, electricity transmission, surface transportation, aviation, ports and waterways, water resource projects, broadband, pipelines, manufacturing, semiconductors, artificial intelligence and machine learning, high-performance computing and advanced computer hardware and software, quantum information science and technology, data storage and data management, cybersecurity, carbon capture, energy storage, or any other sector as determined by a majority vote of the Council.”

7 Ibid, FAST, Sec.4370m-2.

8 Ibid, FAST, Sec.4370m; Public Law 116–260, 27 December 2020), 134 Stat. 2250, https:// uscode.house.gov/statviewer.htm?volume=134&page=2250

9 E.O. 13807, Establishing Discipline and Accountability in the Environmental Review and Permitting Process for Infrastructure Projects (2017), www.federalregister.gov/documents/2017/08/24/2017-18134/establishing-discipline-and-accountability-in-the-environmental-review-and-permitting-process-for

10 Council on Environmental Quality, Update to the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act (16 July 2020), Sec. 1501.4, 1501.10, 1502.7, www.federalregister.gov/documents/2020/07/16/2020-15179/update-to-the-regulations-implementing-the-procedural-provisions-of-the-national-environmental

11 National Association of Environmental Professionals (NEPA), 2023 Annual NEPA Report, (Oct 2024), 4-5, https://naep.memberclicks.net/assets/annual-report/NEPA_Annual_ Report_2023.pdf

12 US, Energy Act 2020, HR 133 1237, (2020), Sec 1010, 1012(C), 3102, 8011, www.aip.org/sites/ default/files/aipcorp/images/fyi/pdf/energy-act-of-2020.pdf

13 US, Energy Policy Act of 2005, Public Law No: 109-58, Sec 1221, www.congress.gov/ bill/109th-congress/house-bill/6/text; Federal Power Act, 16 U.S.C. 791a-828c, Sec 216(h), www.ferc.gov/sites/default/files/2021-04/federal_power_act.pdf

14

US, Memorandum of Understanding among the US Department of Agriculture, Department of Commerce, Department of Defense, Department of Energy, the Environmental Protection Agency, the Council on Environmental Quality, Department of the Interior, and the Office of Management and Budget regarding Facilitating the Federal Authorizations for Electrical Transmission Facilities, (2023), www.energy.gov/sites/default/ files/2023-05/5-04-2023%20216h%20Transmission%20MOU.pdf; Department of Energy, Coordination of Federal Authorizations for Electric Transmission Facilities, Final Rule 10 CFR 900 (2023), www.energy.gov/sites/default/files/2024-04/CITAPFinalRuleDOE.pdf

15 South Australia, Minister for Planning Wind farm planning policy (2012), www.energymining.sa.gov.au/industry/hydrogen-and-renewable-energy/ large-scale-generation-and-storage/wind-farm-planning-policy; Finland, “One-stop services and streamlined permit procedures” (2023), https://ym.fi/en/ onestop; EU, Accelerating permitting for renewable energy and green investments – Support to establish a single permitting authority, a single environmental procedure, and better digital tools in Finland (2023), Technical Support Instrument, https://reform-support.ec.europa.eu/what-we-do/green-transition/ accelerating-permitting-renewable-energy-and-green-investments_en

16 Arizona, Administrative Code Sec R18-2-306.01 (as amended 2024), https://apps.azsos. gov/public_services/Title_18/18-02.pdf

17 C Jamasmie, Rio Tinto bets on Trump support for long-stalled Arizona copper mine (22 January 2025), www.mining.com/rio-tinto-bets-on-trump-support-for-long-stalled-arizona-copper-mine/; N Thukral & M Burton, Rio Tinto exec asks Trump Administration to speed up permitting, (6 November 2024) Reuters, www.reuters.com/markets/commodities/rio-tinto-exec-asks-trump-administration-speed-up-permitting-2024-11-07/

18 Colorado, Colorado Revised Statutes, Sec 34-32-110. Limited impact operations - expedited process, https://leg.colorado.gov/colorado-revised-statutes

19 California, Senate Bill No. 149 Chapter 60 (2023), Sec 21183, 21189.80, 21189.85-86, https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB149; New York, State Compilation of Codes, Rules and Regulations (CRR-NY) (2022), Sec 617.14, https://govt.westlaw.com/nycrr/Browse/Home/NewYork/UnofficialNewYorkCodesRulesandRegulations?guid=Ifb3e6cb0b5a011dda0a4e17826ebc834&originationContext=documenttoc&transitionType=Default&contextData=(sc.Default)

20 Washington State, HB 1216: Clean Energy Project Siting (23 July 2023), Sec 101102, https://lawfilesext.leg.wa.gov/biennium/2023-24/Pdf/Bills/Session%20Laws/ House/1216-S2.SL.pdf?q=20230727083311 [WS HB 1216]; Washington State, Revised Code of Washington, 19.405.020; Clean energy projects are defined to include low carbon energy manufacturing, grid transmission, and biomass energy facilities.

21 Ibid, WS HB 1216, Sec 201-207.

22 IEA, Electricity 2024, at 8, https://iea.blob.core.windows.net/assets/18f3ed24-4b26-4c83a3d2-8a1be51c8cc8/Electricity2024-Analysisandforecastto2026.pdf. [IEA Electricity 2024]

23 IEA Electricity 2024 at 9.

24 P Denholm et al., Examining Supply-Side Options to Achieve 100% Clean Electricity by 2035 (National Renewable Energy Laboratory, 2022), at 68, www.nrel.gov/docs/fy22osti/81644.pdf; J Moch & H Lee, The Challenges of Decarbonizing the U.S. Electric Grid by 2035, Brief January 2022, Harvard Kennedy School Belfer Center, www.belfercenter.org/ sites/default/files/pantheon_files/files/publication/Brief_US%20Grid_FINAL.pdf

25 US Department of Energy, Building a Better Grid Initiative to Upgrade and Expand the Nation’s Electric Transmission Grid to Support Resilience, Reliability, and Decarbonization (11 January 2022), www.energy.gov/sites/default/files/2022-01/Transmission%20 NOI%20final%20for%20web_1.pdf

26 E Larson et al., Net-Zero America: Potential Pathways, Infrastructure, and Impacts (Princeton/Carbon Mitigation Initiative, 2020), at 106, https://netzeroamerica.princeton. edu/img/Princeton_NZA_Interim_Report_15_Dec_2020_FINAL.pdf

27 CK Woo et al, “Average residential outage cost estimates for the lower 48 states in the US” Energy Economics 98 (June 2021), https://doi.org/10.1016/j.eneco.2021.105270; KH LaCommare et al, “Improving the estimated cost of sustained power interruptions to electricity customers” Energy 153 (June 2018), 1038-1047, https://doi.org/10.1016/j.energy.2018.04.082; I Orr & M Rolling, “The levelized cost of blackouts” Center for American Experiment (2024), www.americanexperiment.org/the-levelized-cost-of-blackouts/; Pew, Distributed Generation: Cleaner, Cheaper, Stronger. Industrial Efficiency in the Changing Utility Landscape” (Pew Charitable Trust, 2015), https://www.pewtrusts.org/ en/research-and-analysis/reports/2015/10/americas-electric-grid-growing-cleaner-cheaper-and-stronger

28 T Keefe et al, 2025 Power and Utilities Industry Outlook (Deloitte, 2024), https://www2. deloitte.com/us/en/insights/industry/power-and-utilities/power-and-utilities-industry-outlook.html

29 E Miliband, Statement made on 12 November 2024 at COP29, (12 November 2024), https://questions-statements.parliament.uk/written-statements/detail/2024-11-12/ hcws206

30 UK, Transitioning to a net zero energy system Smart Systems and Flexibility Plan 2021, (Department for Business, Energy & Industrial Strategy/OFGEM, 2021), https://assets. publishing.service.gov.uk/media/60f575cd8fa8f50c7f08aecd/smart-systems-and-flexibility-plan-2021.pdf. [UK BEIS/OFGEM 2021]

31 Ibid, UK BEIS/OFGEM 2021, at 10-11.

32 Ibid, UK BEIS/OFGEM 2021

33 Massachusetts, An Act Driving Clean Energy and Offshore Wind, Chapter 179 (2022), Sec. 53, 92B-92C, https://malegislature.gov/Laws/SessionLaws/Acts/2022/Chapter179 [Mass 2022]

34 Ibid, Mass 2022, 92B(c).

35 State of New York, Reforming the Energy Vision (2014), www.ny.gov/sites/default/files/ atoms/files/WhitePaperREVMarch2016.pdf

36 State of New York Joint Utilities, Distributed System Implementation Plans, (2023), https:// jointutilitiesofny.org/utility-specific-pages/system-data/dsips

37 New York Public Service Commission, Case 24-E-0165: Proceeding on Motion of the Commission Regarding the Grid of the Future, Order Instituting Proceeding (18 April 2024), https://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=24-e-0165#

38 NYSERDA, Electric Power Transmission and Distribution (EPTD) Future Grid Challenges: Program Opportunity Notice (PON) 4393,(2024), https://portal.nyserda.ny.gov/servlet/ servlet.FileDownload?file=00P8z000004Rbh1EAC

39 New York, S. 6599, Climate Leadership Community Protection Act (CLCPA) (2019-2020) www.nysenate.gov/legislation/bills/2019/S6599; New York, S. 7508, Accelerated Renewable Energy Growth and Community Benefit Act (2021), www.hodgsonruss.com/assets/ htmldocuments/S7508%20Part%20JJJ.pdf

40 California Public Utilities Commission (CPUC), California’s Grid Modernization Report 2020 (2021), at 14-15, www.cpuc.ca.gov/-/media/cpuc-website/divisions/office-of-governmental-affairs-division/reports/2020/californias-grid-modernization-report-2020. pdf

41 American Recovery and Reinvestment Act of 2009 (Recovery Act), Pub. L. 111-5 (H.R. 1), 123 Stat. 115; CPUC, Decision 09-09-029 (10 Sept 2009), https://docs.cpuc.ca.gov/PublishedDocs/WORD_PDF/FINAL_DECISION/106992.PDF; CPUC, D.09-12-046 (29 Dec 2009), https://docs.cpuc.ca.gov/PublishedDocs/WORD_PDF/FINAL_DECISION/111856. PDF; CPUC, D.11-07-056 (28 July 2011), https://docs.cpuc.ca.gov/PublishedDocs/WORD_ PDF/FINAL_DECISION/140369.PDF; CPUC, D.12-08-045 (23 August 2021), https://docs. cpuc.ca.gov/PublishedDocs/Published/G000/M026/K531/26531585.PDF.; CPUC, Resolution E-4527 (27 Sept 2012), https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/ M028/K949/28949960.PDF

42 State of California, Senate Bill No. 17 Electricity: smart grid systems (11 Oct 2009), https:// leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200920100SB17; CPUC, Proceeding R.08-12-009 (18 Nov 2008), https://docs.cpuc.ca.gov/PublishedDocs/ WORD_PDF/FINAL_DECISION/106992.PDF; CPUC, Decisions D.10-06-047 (24 June 2010), https://docs.cpuc.ca.gov/PublishedDocs/WORD_PDF/FINAL_DECISION/119902. PDF; CPUC, D.12-04-025 ( 19 April 2012), https://docs.cpuc.ca.gov/PublishedDocs/ WORD_PDF/FINAL_DECISION/164808.PDF; CPUC, D.13-07-024 (25 July 2013), https:// docs.cpuc.ca.gov/PublishedDocs/Published/G000/M075/K390/75390046.PDF

43 CEC, CEC Adopts Standards to Help Consumers Save Energy at Peak Times (12 Oct 2022), www.energy.ca.gov/news/2022-10/cec-adopts-standards-help-consumerssave-energy-peak-times

44 CEC, California Adopts Goal to Make More Electricity Available Through Smarter Use (31 May 2023), www.energy.ca.gov/news/2023-05/california-adopts-goal-make-moreelectricity-available-through-smarter-use

45 PG&E, Accelerating Innovation with Breakthrough Thinking and Radical Collaboration: PG&E Launches New R&D Strategy Initiative and Innovation Summit (23 June 2023), https://investor.pgecorp.com/news-events/press-releases/press-release-details/2023/ Accelerating-Innovation-with-Breakthrough-Thinking-and-Radical-Collaboration-PGE-Launches-New-RD-Strategy-Initiative-and-Innovation-Summit/default.aspx

46 26 U.S. Code § 45: Electricity produced from certain renewable resources, etc., (as amended 2025), https://www.govinfo.gov/content/pkg/USCODE-2023-title26/html/ USCODE-2023-title26-subtitleA-chap1-subchapA-partIV-subpartD-sec45.htm 26 USC Sec 45(c)(1): IRS, Credit for Renewable Electricity Production and Publication of Inflation Adjustment Factor and Reference Price for Calendar Year 2025 (27 May 2025), https:// www.federalregister.gov/documents/2025/05/27/2025-09366/credit-for-renewable-electricity-production-and-publication-of-inflation-adjustment-factor-and#:~:text=Under%20the%20calculation%20required%20by,2022%2C%20from%20the%20qualified%20energy ; 26 U.S. Code Sec 48: Energy credit (as amended 2025), https://www. law.cornell.edu/uscode/text/26/48E

47 42 U.S.C. § 15821: Energy efficient appliance rebate programs (as amended 2025), https://uscode.house.gov/view.xhtml?req=(title:42%20section:15821%20edition:prelim); 42 U.S.C. § 6291: Definitions (as amended 2000), https://uscode.house.gov/view.xhtml?req=granuleid:USC-1999-title42-section6291&num=0&edition=1999

48 16 U.S.C. Regulation of the Development of Water and Power Resources (as amended 2025), Sec 792, 796-797, 824, 824o, 824v, 825o-1, https://uscode.house.gov/view.xhtml?path=/prelim@title16/chapter12&edition=prelim; 42 U.S.C. Sec 4321 (as amended 2025), https://uscode.house.gov/view.xhtml?req=(title:42%20section:4321%20edition:prelim); 18 C.F.R. Sec 385.604 (as amended 2025), https://www.ecfr.gov/current/title-18/chapter-I/ subchapter-X/part-385/subpart-F/section-385.604; Pub. L. 101–575, Sec 4, (15 Nov. 1990), 104 Stat. 2834, https://uscode.house.gov/statviewer.htm?volume=104&page=2834

49 42 U.S.C. Sec 1862p (as amended 2025), https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1862p-2&num=0&edition=prelim#sourcecredit; 23 U.S.C. § 601 (as amended 2025), https://uscode.house.gov/view.xhtml?path=/ prelim@title23/chapter6&edition=prelim

50 California, Public Utilities Code, Sec 454.5, (as amended 2002), https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PUC&sectionNum=454.5

51 Colorado, Revised Statutes Sec 40-2-123, (as amended 2023), https://leg.colorado.gov/ sites/default/files/images/olls/crs2023-title-40.pdf; ; Minnesota, Statutes Sec 216B.2422 (as amended 2024), www.revisor.mn.gov/statutes/cite/216b.2422; Oregon, Revised Statutes, Sec 757.522 (as amended 2024), www.oregonlegislature.gov/bills_laws/ors/ ors757.html; Revised Code of Washington, Sec 19.280.030 (as amended 2025), https:// app.leg.wa.gov/rcw/default.aspx?cite=19.280.030

52 Michigan, Compiled Laws (MCL) Sec 460.6t (as amended 2025), www.legislature. mi.gov/Laws/MCL?objectName=MCL-460-6T; North Carolina, General Statutes Sec 62-110.1 (as amended ), www.ncleg.gov/EnactedLegislation/Statutes/PDF/BySection/Chapter_62/GS_62-110.1.pdf; Indiana, Code Sec 8-1-8.5-3 (as amended 2024), https://codes.findlaw.com/in/title-8-utilities-and-transportation/in-code-sect-8-18-5-3/#:~:text=Sec.,for%20the%20generation%20of%20electricity.; Virginia, Code Sec 56-599 (as amended 2025), https://law.lis.virginia.gov/vacode/title56/chapter24/section56-599/#:~:text=Integrated%20resource%20plan%20required.,generation%20and%20 distribution%20services%20filing

53 Georgia, Code Sec 46-3A-2, (as amended 2024), https://codes.findlaw.com/ga/title-46-public-utilities-and-public-transportation/ga-code-sect-46-3a-2/

54 California, Public Utilities Code Article 16. California Renewables Portfolio Standard Program Sec 399.11-399.33, (as amended 2002), https://leginfo.legislature.ca.gov/faces/ codes_displayText.xhtml?lawCode=PUC&division=1.&title=&part=1.&chapter=2.3.&article=16

55 Colorado, Revised Statutes 40-2-124, Renewable energy standards - qualifying retail and wholesale utilities - definitions - net metering - legislative declaration – rules. (as amended 2024), https://leg.colorado.gov/sites/default/files/images/olls/crs2023-title-40.pdf

56 Hawaii, Revised Statutes Sec 269-92 Renewable portfolio standards, (as amended 2024), https://health.hawaii.gov/cab/files/2022/06/Appendix-L-Draft_rb.pdf

57 Massachusetts General Laws Chapter 25A, Sec 11F: Renewable energy portfolio standard for retail electricity suppliers (as amended 2024), https://malegislature.gov/Laws/ GeneralLaws/PartI/TitleII/Chapter25a/Section11f

58 Minnesota, Minnesota Statutes Sec 216B.1691, Renewable energy objectives (as amended 2024), www.revisor.mn.gov/statutes/cite/216b.1691

59 New York, Consolidated Laws of New York, Sec 66-p, Establishment of a renewable energy program (as amended 2023), www.nysenate.gov/legislation/laws/PBS/66-P

60 Oregon Revised Statutes § 469A.005-469A.210, Renewable Portfolio Standards; Non-emitting Electricity Targets, (as amended 2023), https://www.oregonlegislature. gov/bills_laws/ors/ors469a.html

61 Virginia, Code of Virginia Sec 56-585.5, Generation of electricity from renewable and zero carbon sources (as amended 2025), https://law.lis.virginia.gov/vacode/title56/ chapter23/section56-585.5/

62 Washington, Revised Code of Washington Sec 19.285.040, Energy conservation and renewable energy targets (as amended 2024), https://app.leg.wa.gov/RCW/default. aspx?cite=19.285.040&pdf=true

63 Hawaii, Revised Statutes Sec 269-96 Renewable portfolio standards, (as amended 2024), https://health.hawaii.gov/cab/files/2022/06/Appendix-L-Draft_rb.pdf

64 New York, Public Service Law, Sec 66, (as amended 2024), www.nysenate.gov/legislation/laws/PBS/66

65 California, Public Utility Code, Sec 366.2 (as amended 2024), https://leginfo.legislature. ca.gov/faces/codes_displaySection.xhtml?lawCode=PUC&sectionNum=366.2

66 Hawaii, Revised Statute Sec 196-10.5, (as amended 2024) https://law.justia.com/codes/ hawaii/title-12/chapter-196/section-196-10-5/ [Hawaii, RS]; Ibid, Hawaii RS, Sec 19610.8 (as amended 2024), https://law.justia.com/codes/hawaii/title-12/chapter-196/section-196-10-8/

67 IEA, Global Critical Minerals Outlook 2024, (IEA, 2024), at 40, www.iea.org/reports/global-critical-minerals-outlook-2024. [Critical Minerals Outlook 2024]

68 Ibid, Critical Minerals Outlook 2024, at 97.

69 Ibid, Critical Minerals Outlook 2024, at 41.

70 US, Energy Act 2020, HR 133 1237, (2020), Sec 7002-7003. www.aip.org/sites/default/ files/aipcorp/images/fyi/pdf/energy-act-of-2020.pdf

71 Department of Energy, Notice of Final Determination on 2023 DOE Critical Materials List, (8 April 2023), www.federalregister.gov/documents/2023/08/04/2023-16611/notice-of-final-determination-on-2023-doe-critical-materials-list; Including: “aluminum, cobalt, copper, dysprosium, electrical steel, fluorine, gallium, iridium, lithium, magnesium, natural graphite, neodymium, nickel, platinum, praseodymium, terbium, silicon, and silicon carbide.”

72 US, Infrastructure Investment and Jobs Act, H.R.3684 (2021), at 40401, www.congress. gov/bill/117th-congress/house-bill/3684

73 Ibid, IIJA, at 40210, 40204-40205

74 Department of Defense, National Defense Industrial Strategy 2023, at 9, 17, 31, 44, www. businessdefense.gov/docs/ndis/2023-NDIS.pdf

75 California, State Energy Resources Conservation and Development Commission: Blue Ribbon Commission on Lithium Extraction in California, Assembly Bill 1657, (09 September 2020), https://legiscan.com/CA/text/AB1657/id/2210525

76 Lithium Valley Commission, Report of the Blue Ribbon Commission on Lithium Extraction in California (1 December 2022), https://efiling.energy.ca.gov/GetDocument.aspx?tn=247861

77 California, Governor’s Budget Summary 2022-2023, California Legislature Regular Session 2021-2022 (10 January 2022), at 88-89, https://ebudget.ca.gov/2022-23/pdf/ BudgetSummary/FullBudgetSummary.pdf#page=94

78 Controlled Thermal Resources, Hell’s Kitchen Lithium and Power project, https://static1.squarespace.com/static/5bbc837993a6324308c97e9c/t/674f9e74120a9915ad db4496/1733271208733/241204_Community+QA_Website.pdf

79 P Dobson, et al, Characterizing the Geothermal Lithium Resource at the Salton Sea, (2023) LBNL Report LBNL-2001557, https://escholarship.org/uc/item/4x8868mf#main; Comité Civico Del Valle vs County of Imperial, et al, Superior Cort of California Case ECU003425, Tentative Decision, www.courthousenews.com/wp-content/uploads/2025/01/comite-civico-del-valle-v-county-of-imperial-tentative-decision.pdf

80 Nevada Revised Statutes, Chapter 513, 513.073-513.093, https://law.justia.com/codes/ nevada/chapter-513/. [NRS]

81 Ibid, NRS, Chapter 513.023-513.063.

82 GOED, “$1.7 million approved to support workforce training in logistics, nursing and mining” (25 July 2024), https://goed.nv.gov/newsroom/1-7-million-approved-to-supportworkforce-training-in-logistics-nursing-and-mining/; GOED, “Abated companies will invest $120.7 million and generate $37.5 million in tax revenue” (25 January 2023), https:// goed.nv.gov/newsroom/abated-companies-will-invest-120-7-million-and-generate-375-million-in-tax-revenue/

83 SRI, Realizing Nevada’s Electric, Innovative, and Connected Future 5-Year Comprehensive Economic Development Strategy, Nevada Governor’s Office of Economic Development, (Dec 2023), https://goed.nv.gov/wp-content/uploads/2024/02/Statewide-PlanWater-Health-12.20.2023.pdf

84 California, 15 USC 3722a: Regional Technology and Innovation Hub Program (as amended 2025), https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section3722a&num=0&edition=prelim; US, H.R.4346, CHIPS and Science Act (2022), Sec 10621, https://www.congress.gov/bill/117th-congress/house-bill/4346

85 DOE, Thacker Pass, Loan Programs Office Project Page, www.energy.gov/lpo/thacker-pass

86 Nevada Battery Coalition www.nevadabatterycoalition.com

87 Alaska, Statues AS 27, Chapter 5, .Sec 27.05.010, www.akleg.gov/basis/statutes. asp#27; Alaska, Statues AS 38.05.185, Sec 38.05.185, www.akleg.gov/basis/statutes. asp#38.05.184

88 Teck Alaska Red Dog Mne Economic Development Report 2022, www.teck.com/media/ Teck-2022-Economic-Contribution-Report.pdf

The Climate Change Organisation (Climate Group) with Company Registration Number: 4964424 and Charity Registration Number: 1102909

The Climate Group, Inc. is a U.S. registered 501(c)3 with EIN 43-2073566.

M/s TCCO India Projects Private Limited with Corporate Identity Number U74999DL2018PTC334187

Stichting Climate Group Europe, with Chamber of Commerce KVK number 87378426

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