ISSUE AREAS

Permitting Reform

PROBLEM: The federal permitting system is hindered by redundant reviews, conflicting regulations, and litigation strategies designed to delay or block infrastructure projects. This dysfunction slows or prevents the development of critical energy assets, imposing significant economic costs.

These challenges are especially acute for the nation’s electric grid, which is already under strain. The demand for electricity—from new data centers and cloud computing, new manufacturing, and increased electrification of other sectors across the economy—is increasing and expected to increase for the foreseeable future. Unless decisive action is taken, the nation faces the prospect of power shortfalls and higher electricity bills.

SOLUTION: To ensure a resilient grid and protect consumers from rising costs, the U.S. must significantly expand its electricity supply. That requires removing bureaucratic obstacles and reducing frivolous litigation. While comprehensive permitting reform legislation is essential for long-lasting change, immediate regulatory updates are needed to move priority projects forward without delay.

PRINCIPLES:

  • Permitting vs. Compliance: Federal policymakers must clearly distinguish between permitting and compliance. Permitting should be a well-defined, efficient review process that confirms compliance with environmental and safety laws. Except in narrow, statute-defined circumstances, approvals should default to presumptive approvals based on a simple, predictable process.

  • Simplicity: Reduce the number of agencies and permits involved in energy infrastructure projects wherever possible, with the long-term goal of centralizing federal permitting authority.

  • Efficiency: Agencies should operate under deemed-approved deadlines, meaning that if they fail to act by a date certain, then permits will be automatically approved. Permits can only be rejected for extraordinary reasons clearly delineated in statute. Judicial review of deemed approvals should be limited.

  • Certainty: While citizens must retain the right to challenge permits based on demonstrated economic harm, lawsuits from parties without standing—those unable to show tangible harm—should be limited or barred.

 

Regulatory Reform

PROBLEM: Federal regulation, including permitting, of energy and infrastructure projects has retreated from the framework Congress established and toward an increasingly interventionist approach that prioritizes administrative overreach instead of durable rules. Overlapping authority among agencies creates uncertainty and delays in projects across the electricity supply chain. This regulatory overreach threatens grid reliability at a time of rapidly rising electricity demand driven by AI, data centers, advanced manufacturing, and electrification. Without regulatory reform, investment will continue to lag demand, increasing the risks of a reliable grid and higher costs for consumers and businesses.

SOLUTION: The federal permitting system should be realigned with congressional intent to ensure the electric grid can meet demand reliably. Streamlining permitting—reducing duplicative agency involvement, imposing firm statutory deadlines with deemed approvals, and limiting denials to clearly defined statutory grounds—would reduce delays and support timely project development.

PRINCIPLES:

  • Rule of law: Federal agencies must operate within the authority and intent granted by Congress. Regulations should not exceed statutory mandates or create outcomes beyond legislative objectives. Denials of permits or other regulatory actions should be clearly grounded in statute, and agencies should avoid discretionary actions that conflict with congressional intent.

  • Durability: Federal policy should provide clear and predictable rules that remain stable over time, allowing markets and private capital to plan and develop long-term projects. Durable policies will support grid expansion and modernization to meet rising demand from AI, advanced manufacturing, and electrification.

  • Reliability: Regulatory decisions should prioritize a sufficient and resilient electricity supply to meet current and projected demand.

POSITIONS/COMMENTS ON REGULATIONS:

  • Add submission for ESA rulemakings

  • Add submission for WOTUS rulemaking

Supply Chain Resilience

PROBLEM: The U.S. energy and technology sectors face vulnerabilities across critical supply chains, including manufacturing, sourcing of critical minerals, and workforce capacity. Production delays, concentration of suppliers abroad, and gaps in skilled labor threaten the timely deployment of energy infrastructure and advanced technologies necessary to meet surging electricity demand and maintain global competitiveness.

SOLUTION: Federal policy should strengthen domestic supply chains by expanding U.S. manufacturing of critical components, reducing reliance on foreign sources, and creating strategic stockpiles of essential materials. Incentives and targeted programs can accelerate production of components and technologies critical to energy infrastructure, while workforce development ensures sufficient skilled personnel to design, construct, and operate projects. Executive authorities, including the Defense Production Act (DPA), should be used where appropriate to mobilize industry and address supply chain bottlenecks quickly.

PRINCIPLES:

  • Prioritize Domestic Supply: While U.S. production of critical components and materials should remain the default, exceptions for foreign-sourced components may be permitted when domestic alternatives are unavailable. Such exceptions should be granted through a transparent, expedited process that evaluates supply chain risk, national security, and the potential for domestic development. Federal support should simultaneously incentivize domestic production, ensuring that reliance on foreign sources is temporary and strategic.

  • Workforce Preparedness: Federal policy should support training, skill development, and retention of personnel needed to design, build, and operate energy infrastructure projects, ensuring that the workforce keeps pace with evolving supply chain and technological demands.

Public-Private Partnerships

PROBLEM: Companies seeking to support federal energy and technology initiatives often face challenges comprehending complex agency programs, obtaining funding, and connecting projects to federal resources. Without simplified engagement, private-sector participation can be slowed or underutilized, limiting the impact of federal investments aimed at expanding domestic energy production and modernizing the grid.

SOLUTION: Federal agencies should establish clear, coordinated pathways for private-sector participation. Agencies, programs under the DPA, other federal grants, and federal laboratories should provide transparent opportunities, technical guidance, and expedited processes for projects aligned with national priorities. Executive authorities should be leveraged to mobilize private investment, accelerate deployment of energy infrastructure and technologies, and ensure alignment with national priorities for domestic energy expansion.

PRINCIPLES:

  • Access and Transparency: Agencies should provide clear and predictable opportunities for private-sector participation, including guidance, streamlined applications, and program support.

  • Leveraging Federal Assets: Partnerships should use federal lands, laboratories, and programs to pilot, scale, and deploy energy infrastructure and technologies efficiently.

  • Neutrality: Partnerships should encourage private investment in projects that advance domestic energy production and infrastructure buildout without distorting markets or favoring specific technologies.