On January 6th, the White House Council of Environmental Quality ("CEQ") released a new Guidance on Consideration of Greenhouse Gas Emissions and Climate Change ("the Guidance") in permitting decisions, with significant implications for energy and infrastructure projects. Though this Guidance is effective as of the date of publication, it was issued on an interim basis and CEQ will consider comments until March 10th, after which it could be revised further.
CEQ's recommendations will influence the Biden Administration's analysis of greenhouse gas ("GHG") emissions in environmental reviews under the National Environmental Policy Act ("NEPA"), applying immediately to all newly proposed actions as well as some on-going NEPA reviews. While the Guidance is largely framed as a series of recommendations rather than requirements, it highlights best practices for environmental reviews that could help expedite project completions, improve agency decision making, and minimize litigation risks for developers.万博体育app手机登录归根结底,CEQ正努力确保机构和项目开发商充分关注气候影响,不无端延迟机构决策,特别是考虑到加速清洁能源基础设施是Biden爱慕气候议程的一个关键部分。
指南力求加深理解温室气体影响和替代物取舍,从而提高对联邦温室气体分析质量的期望。 项目开发商希望与联邦监管商密切合作,确保NEPA机构审查的充足性。万博体育app手机登录失败可能为项目反对者提供诉讼路径 。
Below万博体育app手机登录Encouraging Consistency in Agency Analysis of GHGs
CEQ's Guidance builds upon an earlier 2016 policy document, and is the latest in a series of efforts aimed at enhancing certainty in agency GHG analysis.[1] This Obama-era 2016 guidance was revoked and replaced by the Trump Administration,[2] and then ultimately reinstated by the Biden Administration in early 2021.[3] In the interim, court decisions have required some kind of analysis of project climate impacts under NEPA, without articulating clear generally applicable guidelines as to what level of review would be sufficient, thus resulting in uncertainty.[4]
CEQ is encouraging more certainty in addressing GHG consequences, while acknowledging that any such analysis must be conducted in a measured, proportional, yet thorough manner.CEQ实现这一点的主要方式是建议机构量化并联系相关温室气体影响
A万博体育app手机登录Quantifying GHG Emissions and Reductions
CEQ recommends agencies first quantify all reasonably foreseeable GHG emissions and reductions of a proposed action, any reasonable alternatives, and a no action alternative. In doing so, CEQ recognizes the unique nature of the climate emissions challenge, where the effects arise from a wide range of emissions activities. It thus notes, "NEPA requires more than a statement that emissions from a proposed Federal action or its alternatives represent only a small fraction of global or domestic emissions."[5] In other words, an agency is not absolved from analyzing GHG emissions because no single agency action has the ability to mitigate climate change on its own. Instead, an agency must recognize that adequate reforms will occur incrementally, and therefore analyze the emissions impacts of significant federal actions that contribute to, or remediate, climate impacts.[6] To do so, CEQ directs agencies to use tools that are commonly deployed by the private sector and government to quantify emissions.[7]
Using these tools, emissions increases and reductions should be quantified individually by constituent greenhouse gases, as well as aggregated in terms of total carbon dioxide equivalency. Additionally, where feasible, agencies are encouraged to represent the proposed action's annual emissions or reductions, especially when those emissions might vary over the life of the project.[8]
CEQ further instructs that agencies evaluate direct, indirect, and cumulative emissions as part of their environmental review. Among other things, CEQ notes that quantifying direct and indirect emissions "is generally essential to reasoned decision making."[9] Cumulative emissions are critical to consider given the nature of the climate problem, where detrimental effects flow from the accumulation of historic GHGs. Consideration of cumulative effects can be accomplished by summarizing and citing to the relevant scientific literature, as well as monetizing and contextualizing emissions as noted in the following section.[10]
Analyzing direct, indirect, and cumulative emissions is likely to be one of the most challenging aspects of CEQ's guidance to implement, and similar recommendations have already been the source of some controversy. For instance, in February 2022, the Federal Energy Regulatory Commission (FERC) issued a policy statement stating that for gas pipeline approvals FERC would review "GHG emissions that are reasonably foreseeable" including those resulting from upstream impacts—such as those tied to construction and operation of the project—and downstream impacts—such as emissions resulting from the combustion of transported gas.[11] Barely a month later, FERC re-designated this policy statement as a draft and invited additional comments after it garnered significant industry and political criticism.
CEQ attempts to tamp down such controversy by making clear that any analysis of GHGs should be bounded by principles of proportionality. They caution against "an in-depth analysis of emissions regardless of the insignificance of the quantity of GHG emissions that the proposed action would cause."[12] For example, "the relative minor and short-term GHG emissions associated with construction of certain renewable energy projects, such as utility-scale solar and offshore wind, should not warrant a detailed analysis of lifetime GHG emissions."[13] In order to further enhance efficiency and avoid duplicative efforts, CEQ expects that agencies will rely on and incorporate scientific and technical information on impacts from other, more expert, agencies, as well as international organizations and academic literature.[14]
B.Monetize and Contextualize GHG Emissions
Agencies should contextualize GHGs associated with a project after quantifying them. This can include monetizing climate damages using the "best available estimates" of the social cost of GHG ("SC-GHG") and placing emissions in the context of relevant climate goals and commitments.
The best available SC-GHG figure is currently in flux. Two years ago, the Biden Administration reconstituted an Interagency Working Group (IWG) on the SC-GHG, which issued an interim estimate of the SC-GHG in the spring of 2021. As detailed in a prior blog post, that estimate has been the subject of litigation and the IWG has yet to issue a final SC-GHG. More recently, EPA issued a regulatory document in the fall of 2022, which previewed a much higher SC-GHG than contemplated in the IWG's interim estimate.[15]
CEQ nonetheless notes that "in most circumstances" agencies should use the SC-GHG to analyze a proposed action and its alternatives. In doing so, the SC-GHG will empower agencies to make clearer comparisons of the GHG impacts of each action.[16] Monetizing emissions is particularly useful if: (a) the NEPA review monetizes other costs and benefits from the proposed action!替代物在不同时间或温室气体排放类型上有差异and (c) the significance of the climate impacts are hard to assess or not readily apparent without monetization.[17] Any such SC-GHG should be global in nature and utilize a discount rate that accurately reflects the harms climate change inflicts on future generations.[18]
Despite encouraging the monetization of GHG impacts, CEQ clearly states that "NEPA does not require a cost-benefit analysis where all monetized benefits and costs are directly compared." Utilizing SC-GHG to estimate the societal cost of GHG emissions does not create a requirement to do so.[19] However, if an agency considers a formal cost-benefit analysis appropriate, it is not prohibited from including or appending this analysis to its NEPA documents.
For any actions "with relatively large GHG emissions or reductions" or that "perpetuate reliance on GHG-emitting energy sources"—such as fossil fuels—agencies should explain how the proposed action and its alternatives would meet or detract from broader climate goals and commitments, such as federal or state goals or international agreements.[20] For example, agencies could discuss how the actions align with the U.S.机构应考虑使用更多语法或无障碍方法描述温室气体排放量,其中一些例子可包括使用“familiar度量法,例如家用每年排放量、公路上一定数车或加仑燃烧汽油平均量值”。 CEQ is also using this Guidance to encourage agencies to take actions that lower GHG emissions by building such considerations into the process. This underlines CEQ's desire to align government decision making with the Biden Administration's net-zero ambitions. Embedded in this approach is the hope that a more complete consideration of GHG impacts will lead to more climate-positive decision-making, even though NEPA does not require agencies to opt for the most environmentally friendly alternative.[22] CEQ provides advice on how to consider reasonable alternatives and mitigation measures that might address short- and long-term climate change effects, with the aim of promoting emission mitigations.[23] CEQ notes that agencies should also acknowledge the impacts of climate change on the proposed action (not just the impact of the proposed action on the climate) and embed considerations of climate adaptation and resilience into the formulation of the proposed action and alternatives.[24] CEQ also recommends evaluating reasonable alternatives that have lower GHG emissions, including technically and economically feasible clean energy alternatives to proposed fossil-fuel projects.[25] CEQ notes how "[s]ome proposed actions, such as those increasing the supply of certain energy resources like oil, natural gas, or renewable energy generation, may result in changes to the resulting energy mix as energy resources substitute for one another on the domestic or global energy market." CEQ encourages agencies to conduct a "substitution analysis" to understand how any energy project proposals will affect the resulting energy mix and GHG emissions. When doing this analysis, agencies should not assume that if any project does not go forward it will be replaced by one that generates identical emissions, such that net emissions relative to a baseline are zero.[26] Instead, agencies should conduct modeling that "accurately account[s] for reasonable and available energy substitute resources, including renewable energy."[27] By encouraging the consideration of renewable energy alternatives to fossil fuel infrastructure early in the NEPA process, CEQ is pushing agencies to prioritize permitting cleaner forms of energy, consistent with the Administration's broader climate policy goals. CEQ鼓励前方社区参赛,重点是考虑环境公义对温室气体排放的影响万博体育app手机登录One of the most effective ways to accomplish this, according to CEQ, is to leverage early planning processes to integrate GHG emissions and climate change considerations into the identification of alternatives to the proposed action, as well as any reasonable mitigation efforts. CEQ recommends that agencies use the scoping process to identify potentially affected communities and provide early notice of opportunities for public engagement, which is especially important "for communities of color and low-income communities, including those who have suffered disproportionate public health or environmental harms and those who are at increased risk for climate change-related harms."[28] Community engagement should begin in the scoping process and should recognize any unique climate-related risks and concerns posed by the proposed action. For example, CEQ discusses how "chemical facilities located near the coastline could have increased risk of spills or leaks due to sea level rise or increased storm surges, putting local communities and environmental resources at greater risk."[29] In these types of scenarios, agencies should meaningfully engage with affected communities in designing the action and selecting alternatives, "including alternatives that can reduce disproportionate effects on such communities."[30] Such early project engagement, before the contours of a project are fully fixed, can assist in improving project outcomes and building greater community-level support for a project. We will continue monitoring developments pertinent to NEPA reviews of energy and infrastructure projects in the coming months, including CEQ's final guidance on GHG analysis expected in March, and other efforts by the Biden Administration and Congress to reform federal permitting processes. [1] CEQ, Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews, 81 FR 51866 (Aug.万博体育app手机登录2016年4月5日CEQ撤销2016年最终指南。CEQ撤销联邦各部门和机构在国家环境政策法评审中审议温室气体排放和气候变化影响最终指南,III.Up-Front社区参与环境公义
[7] Guidance at 1201-1202. CEQ keeps a list of these tools on their website. See CEQ, GHG Tools and Resources, https://ceq.doe.gov/guidance/ghg-tools-and-resources.html.
[8] Id. at 1201.
[9] Id. at 1205.
[10] Id. at 1206.
[11] FERC, Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews, Docket No.万博体育app手机登录PL21-3-000, February 18, 2022.
[12] Guidance at 1201.
[13] Id.
[14] For instance, CEQ notes that "agencies may summarize and incorporate by reference the relevant chapters of the most recent national climate assessments or reports from the USGCRP and the IPCC" and encourages them to "engage other agencies and stakeholders with knowledge of related actions to participate in the scoping process to identify relevant GHG and adaptation analyses from other actions or programmatic NEPA documents." Guidance at 1208, 1210.
[15] Specifically, the February 2021 IWG estimates places the social cost of carbon at $51/ton, while the EPA in the fall of 2022 estimated the social cost of carbon at $190/ton. This larger estimate was derived in part by using lower discount rates.万博体育app手机登录See Supplementary Material for the Regulatory Impact Analysis for the Supplemental Proposed Rulemaking, "Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review," EPA External Review Draft of Report on the Social Cost of Greenhouse Gases: Estimates Incorporating Recent Scientific Advances, EPA-HQ-OAR-2021-0317 (September 2022).
[16] Guidance at 1202.
[17] Id.
[18] CEQ further notes that in utilizing a SC-GHG, agencies should keep in mind that currently available estimates "may be conservative underestimates because various damage categories (like ocean acidification) are not currently included." Id. at 1203.
[19] Id. at 1211.
[20] Id.
[21] Id.
[22] CEQ itself recognizes that "[n]either NEPA, the CEQ Regulations, or this guidance require the decision maker to select the alternative with the lowest net GHG emissions or climate costs or the greatest net climate benefits." Id. at 1204.
[23] Id. at 1203.
[24] Id. at 1208-1209.
[25] Id.1205 id>#em>
(a) The make, model, model year, and any other appropriate identifiers of the motor vehicle;
(b) Certification that the motor vehicle is made by a qualified manufacturer, within the meaning of Section 30D(d)(3);
(c) Certification that the motor vehicle is treated as a motor vehicle for purposes of title II of the Clean Air Act;
(d) The gross vehicle weight rating of the motor vehicle;
(e) The battery capacity of the motor vehicle;
(f) The motor vehicle's vehicle identification number!and
(g) Such other information as the Secretary may provide on irs.gov.
With respect to the Section 30D credit, the following additional information needs to be provided:
(a) Certification that the motor vehicle is propelled to a significant extent by an electric motor that draws electricity from a battery that has a capacity of not less than 7 kilowatt hours and the battery is capable of being recharged from an external source of electricity, or the motor vehicle is a new qualified fuel cell motor vehicle;
(b) Certification that the motor vehicle is manufactured primarily for use on public streets, roads and highways (not including a vehicle operated exclusively on a rail or rails) and has at least four wheels;
(c) Certification that the final assembly of the motor vehicle occurred within North America;
(d) Certification of the percentage of the value of the applicable critical minerals contained in the electric vehicle's battery that were (i) extracted or processed in the United States or a FTA partner country, or (ii) recycled in North America;
(e) Certification of the percentage of the value of the EV battery components that were manufactured or assembled in North America;
(f) Whether the motor vehicle is a van, sport utility vehicle, pickup truck, or other vehicle!and
(g) The motor vehicle's manufacturer's suggested retail price.
Similarly, with respect to Section 25E and 45W credits, the manufacturer must provide additional information to show that vehicles satisfy the statutory qualifications for credit eligibility.
A vehicle seller, such as a dealer, must furnish a report to a purchaser not later than the purchase date and an annual report to the IRS, including the following information:
(a) The name and taxpayer identification number of the seller;
(b) The name and taxpayer identification number of the purchaser;
(c) The vehicle identification number, if assigned, of the vehicle;
(d) The battery capacity of the vehicle;
(e) For new clean vehicles, verification that original use of the vehicle commences with the purchaser;
(f) The date of sale, sale price of the vehicle, and maximum credit allowable to the purchaser!and
(g) If a purchaser makes an election to transfer the credit to the selling dealer that satisfies certain requirements for sales after December 31, 2023, any amount paid or allowable as a partial payment or down payment.
This revenue procedure notably does not require qualified manufacturers to certify as to a vehicle's satisfaction of the requirements in Section 30D(d)(7)—that the critical minerals in the battery have not been extracted, processed, or recycled by a "foreign entity of concern" and that the components contained in the battery have not been manufactured or assembled by a foreign entity of concern. This would seem to impose less of a diligence burden on manufacturers.同理,税收程序没有解决车辆购买者如何确定车辆满足这些需求的问题。我们注意到,IRS可添加这项附加认证要求,作为2024或2025前“秘书可能提供的其他信息”的一部分,而2024或2025前外国受关注实体规则生效。
IT似乎报告需要解决车辆信用分数问题万博体育app手机登录As such, two vehicles of the identical make, model, and year may not always have the same credit eligibility, which will vary depending on the composition of critical minerals and components and the location of final assembly.
Manufacturers and sellers must submit a declaration under penalties of perjury that the facts presented in support of this certification are true, correct, and complete. A purchaser of a vehicle can rely on the manufacturer's certification for the Section 30D, 45W, and 25E credits.
This revenue procedure does not provide any guidance on how to determine the value of critical minerals and components. The revenue procedure expressly notes that it does not constitute the guidance the IRS is required to propose regarding Section 30D(e)(1) (Critical Minerals Requirement) and Section 30D(e)(2) (Battery Components). Such guidance is due to be published separately, by no later than December 31, 2022.
最后,我们注意到税收程序没有表示政府会放松信用计划的法定时限-例如提供过渡期-正如许多制造商所请求的那样。
我们将继续监测和报告这些动态。
环境保护局发布三份信息请求 关于回收问题,这是分配资金和执行去年《基础设施投资与就业法》(通称双党基础建设法)所载任务的第一步EPA请求信息程序主要面向改善消费者垃圾回收:
图类高度:自动机abjectivity-left数据对齐>IIJAsec70401bbrbrbrbrbrbr>(2) 建立程序促进电池回收,为电池生产者和消费者开发电池和其他形式的通信材料自愿标签指南,说明电池关键材料的复用和回收IIJAsec70401cabr+++br+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++br信息电池回用和回收通信素材面向电池生产者和消费者EPA在每个类别中列出了一系列关于当前回收实践的具体问题,例如:The current recycling rate in the United States—about 32 percent—is well below what it could be. EPA has set a target of 50% by the end of the decade, and last year published the agency's first ever national recycling strategy. These requests for information focus on some of the most commonly cited reasons for the low rate, including consumer attitudes toward recycling and poor infrastructure in many parts of the country.
The RFIs should be of interest to a broad set of stakeholders. EPA's desire to better understand battery recycling practices is of particular note, given the prevalence of batteries in modern consumer products, and the importance of energy storage solutions to the Biden Administration's climate goals. The guidelines developed by EPA could ultimately become the basis for either federal or state mandatory requirements. Manufacturer take-back programs are also specifically mentioned, suggesting that EPA may eventually consider extended producer responsibility for these products, a trend that is prevalent in a number of states.响应这些请求的书面评论和信息必须在2022年7月25日或之前收到。 EPA资源保护恢复局今年将在全国各地主办虚拟会议。
The revised TEN-E Regulation 2022 continues to work towards developing better connected energy networks while updating the TEN-E framework to focus on the latest environmental targets and ensuring consistency with the climate neutrality objectives set out in the EU Green Deal.
Towards a better integrated and greener EU energy market
The TEN-E Regulation 2022 reallocates and identifies 11 priority corridors with the purpose of meeting objectives to (i) reduce carbon emissions by 55% by 2030 and (ii) achieve carbon neutrality by 2050.优先通道侧重于更新基础设施类别,如近海电网通道和可再生和低碳气体,如氢解电机天然气基础设施和石油管道将不再有资格获得PCI状态TEN-E条例2022还确定了新的优先专题领域:(一) 采行配有IT技术(“智能电网”)电气网络;(二) 开发跨边界二氧化碳网络。
/p>能源基础设施项目proto侧重于推广绿色清洁能源的项目可获取PCI状态,如近海风能和可再生/低碳氢化注解氢或可混入其他气体(如天然气或生物甲烷)或自成一体的能源源TEN-E第2022号条例也鼓励智能电网和二氧化碳运输存储的PCIs 。补充地说,TEN-E第2022号条例将欧盟能源市场边界扩展至第三国,为所谓的互利项目引入新合作机制与PCIs相似,如果他们为欧盟总体能源和气候政策提供保障和去碳化服务,可选择它们。
欧盟委员会将每两年通过PCIs和PMIs清单(“EU链表”),第一批欧盟链表将在2023年11月30日前通过。
TEN-E规范2022还为欧盟链表中所有项目规定了新义务PCIs和PMI必须满足强制可持续性标准,并依照举例说,估计耗资8 000亿欧元提高近海可再生能源的摄取量,根据欧盟绿色交易目标,其中三分之二将用于相关电网基础设施。电力传输配电网单实现2030目标每年估计平均投资505亿欧元。
并举,帮助支付巨额费用,欧盟清单上的PCIs和PMIs可能有资格获得财政援助:
连接欧洲机制下Finance支持On April 20, 2022, the cybersecurity authorities of the United States, Australia, Canada, New Zealand, and the United Kingdom—the so-called "Five Eye" governments—announced the publication of Alert AA22-110A, a Joint Cybersecurity Advisory (the "Advisory") warning critical infrastructure organizations throughout the world that the Russian invasion of Ukraine could expose them "to increased malicious cyber activity from Russian state-sponsored cyber actors or Russian-aligned cybercrime groups." The Advisory is intended to update a January 2022 Joint Cybersecurity Advisory, which provided an overview of Russian state-sponsored cyber operations and tactics, techniques, and procedures ("TTPs").
In its announcement, the authorities urged critical infrastructure network defenders in particular "to prepare for and mitigate potential cyber threats by hardening their cyber defenses" as recommended in the Advisory.
Overview. The Advisory notes that "evolving intelligence" indicates that the Russian government is exploring options for potential cyber attacks and that some cybercrime groups have recently publicly pledged support for the Russian government and threatened to conduct cyber operations on behalf of the Russian government. The Advisory summarizes TTPs used by five state-sponsored advanced persistent threat ("APT") groups, two Russian-aligned cyber threat groups, and eight Russian-aligned cybercrime groups. Additionally, it provides a list of mitigations and suggests that critical infrastructure organizations should implement certain mitigations "immediately."
Russian State-Sponsored Cyber Operations. The Advisory notes that Russian state-sponsored cyber actors have "demonstrated capabilities" to compromise networks!保持长期持续访问网络从信息技术网络和操作技术网络排出敏感数据并使用破坏性恶意软件干扰关键工业控制系统及OT网络咨询详解俄罗斯APT五大类:
Russian Foreign Intelligence Service ("SVR"): SVR has likewise targeted multiple critical infrastructure organizations, although the Advisory does not specify the sectors in which these organizations operate. SVR's TTPs include custom and sophisticated malware targeting Windows and Linux systems and lateral movement within a compromised network that can bypass multi-factor authentication ("MFA") on privileged cloud accounts. The U.S., UK, and Canada have attributed the SolarWinds Orion supply chain compromise to the SVR.
Russian General Staff Main Intelligence Directorate ("GRU"), 85th Main Special Service Center ("GTsSS"): GTsSS primarily targets government organizations, travel and hospitality entities, research institutions, non-government organizations, and critical infrastructure entities. Its TTPs include harvesting credentials to gain access to targets via spear phishing emails and spoofed websites that trick users into entering their account names and passwords.
GRU's Main Center for Special Technologies ("GTsST"): GTsST is known to target critical infrastructure entities, including those within the Energy, Transportation, and Financial Services Sectors, as well as member states belonging to the North Atlantic Treaty Organization ("NATO") and Western governments and military organizations. GTsST is particularly known to use destructive or disruptive attacks, such as distributed denial of service ("DDoS") and wiper malware.
Russian Ministry of Defense, Central Scientific Institute of Chemistry and Mechanics ("TsNIIKhM"): TsNIIKhM is known publicly as a research organization in the Russian Ministry of Defense, but the Advisory notes it has developed destructive ICS malware, known as Triton, HatMan, and TRISIS.
Russian-Aligned Cyber Threat Groups. The Advisory addresses two state-sponsored cyber threat groups: PRIMITIVE BEAR and VENOMOUS BEAR. The former is known to target Ukrainian organizations and the latter is known to target NATO governments, defense contractors, and "other organizations of intelligence value." Notably, the Advisory explains that none of the governments responsible for the Advisory have formally attributed either of these groups to the Russian government, but nevertheless seems to recognize that these groups are aligned with the Russian government.
Russian-Aligned Cybercrime Groups. The Advisory details eight cybercrime groups aligned with the Russian government. The Advisory notes that these groups are often financially motivated and pose a threat to critical infrastructure organizations throughout the world, primarily through ransomware and DDoS attacks. The Advisory notes that while these groups "may conduct cyber operations in support of the Russian government ...网络犯罪分子极有可能继续主要基于金融动机运作,这可能包括攻击政府和关键基础设施组织。
MUMMY SPIDER: This group operates an advanced, modular botnet, known as Emotet, which primarily functions as a downloader and distribution service for other cybercrime groups. Emotet has been used to target "financial, e-commerce, healthcare, academia, government, and technology organizations' networks" throughout the world.
SALTY SPIDER: This group also operates a botnet, known as Sality, which uses advanced peer-to-peer malware loaders. SALTY SPIDER has conducted DDoS attacks against Ukrainian web forums discussing the Russian invasion of Ukraine.
SCULLY SPIDER: This group operates a "malware-as-a-service" model, which includes maintaining a command and control infrastructure and selling access to its malware and infrastructure to affiliates. SCULLY SPIDER also operates the DanaBot botnet, which effectively functions as an initial access vector for other malware and can result in ransomware deployment. The group primarily targets organizations in the United States, Canada, Germany, United Kingdom, Australia, Italy, Poland, Mexico, and Ukraine.
SMOKEY SPIDER: This group operates a malicious bot, known as Smoke Loader or Smoke Bot, which is used to upload other malware. The group's bot has been used to distribute malware payloads used in DDoS attacks against Ukrainian targets.
WIZARD SPIDER: This group develops TrickBot malware and Conti ransomware. This group has targeted construction and engineering companies, legal and professional services, manufacturing, retail, U.S.healthcare, and first responder networks, and has publicly pledged support to the Russian government, threatened critical infrastructure organizations of countries perceived to "carry out cyberattacks or war against the Russian government," and threatened to "retaliate against perceived attacks against the Russian people."
The Xaknet Team: The Xaknet Team has only been active since March 2022 and has stated they will work "exclusively for the good of [Russia]." The group has threatened to target Ukrainian organizations in response to perceived attacks against Russia and, in March 2022, leaked emails of a Ukrainian official.
Mitigations. The Advisory provides several mitigations that it recommends critical infrastructure organizations implement "immediately": (1) updating software!最大可能执行MFA并需要强密码安全监控远程桌面协议并(4)提供终端用户对潜在网络威胁的认识和培训。
a咨询还建议关键基础设施组织维护者“在识别潜在恶意活动指标时努力克尽职责”,并在检测APT或绑定软件活动后采取具体步骤。
这些步骤包括:(1)立即隔离受影响的系统识别阻塞疑似攻击者IP流量,允许防火墙速率限制,通知组织互联网服务提供人和远程触发黑洞安全备份(4) 收集并审查相关日志、资料和人工品(5)考虑加入第三方IT组织并(6)向适当的网络和执法当局报告事件。咨询还“强烈劝阻”向犯罪方支付赎金,指出支付并不总能成功恢复受害者的档案,这种支付可能“鼓动对手攻击更多组织,鼓励其他犯罪方分发赎金件和/或资助非法活动。”
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- First, consistent with the subject matter of this blog, the twenty-six alphabetical posts that we published since mid-April focus on the broad array of energy and environmental infrastructure objectives of the AJP. We did not address in depth two of the other core infrastructure elements of the AJP — namely digital infrastructure (high-speed broadband) and social infrastructure (education, housing, health, social services to support the "care economy"). Nor did we address President Biden's companion American Families Plan that proposed an additional $1.8 trillion mix of federal spending and tax credits in support of the care economy or his Made in America Tax Plan that would raise $2 trillion in revenue to fund the AJP and Families Plan.AJP和Friends计划蓝图,加之已颁布的1.9万亿
正因如此,尽管AJP本身规模庞大,但凡想分析和理解AJP全部范围和前景者,都应在大全中加以考虑,大全中包括政府为改变美国经济和社会而综合的一套主要政策优先级。 - 第二编,立法不是线性过程AJP开始从蓝图向立法过渡时, 众议院和参议院法案触及AJP各种元素像蘑菇在酷暑之夜扩散While members in both houses of Congress and on both sides of the aisle have introduced scores of bills vying to be part of the final legislative package, as of this writing the path forward appears to have winnowed to a dual track of two legislative "vehicles" for which much bill drafting still remains to be completed.
- Track one is the $1.2 trillion Bipartisan Infrastructure Framework which was initially negotiated and published in late June with the support of 21 senators (split among 11 Republicans, 9 Democrats and one independent) and promptly endorsed by President Biden.最初的博弈后,两党努力近乎破碎四星期后从框架通向立法,原因是党内和党内辩论部分范围,但主要是“付费”。然而,经过紧张谈判后,联盟现在似乎把足够的立法细节放入原框架骨架上,使参议院能够批准67-32票推向参议院全面辩论并修正众议院初始议案
https////www.congress.gov/bell/congress/house-bill/3684>R3684 seeking to implement the framework. A White House fact sheet detailing the revised bipartisan framework summarizes $550 billion of new spending including the following:
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- $110 billion for roads, bridges and other major projects;
- $11 billion in transportation safety programs;
- $39 billion in transit modernization and improved accessibility;
- $66 billion for rail transport;
- $7.5 billion to build a national network of electric vehicle chargers;
- $7.5 billion in electric busses and ferries;
- $42 billion in airports and port infrastructure;
- $65 billion in high-speed internet broadband infrastructure for rural and other disadvantaged areas of America;
- $50 billion to make communities safer and more resilient against extreme weather, climate and cyber risks
- $55 billion in water infrastructure including to remove lead pipes and PFAS contamination;
- $21 billion in environmental remediation!and
- $73 billion in power infrastructure and clean energy transmission.
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As such the bipartisan framework addresses many of the AJP's components but falls considerably short of meeting the AJP's full ambitions to address climate change and essentially ignores investments in the care economy. And the "payfors" in the bipartisan framework come from repurposing some COVID relief funding and a hodgepodge of aspirational sources without proposing any new taxes or tax increases. Accordingly, although President Biden has endorsed the bipartisan framework, he also has committed to support a second track that would enact other portions of the AJP and portions of the Families Plan.
- Track two is a Senate Democratic-led budget resolution that is still evolving, albeit quickly.初步估计规模和范围介于1万亿至6万亿美元之间,而参议院民主党似乎在a3.5万亿美元预算对齐包细节远未消除 并保持整个民主核心 将保持高线行为最终轮廓将受民主党进步翼和中间翼之间所达成的任何折中约束。 决议将在院中取多数票并参院根据
As a budget measure, this will be the vehicle to implement any meaningful new taxes or tax increases, likely over Republican opposition, to pay for the infrastructure spending. But also as a budget measure, this legislative vehicle cannot carry non-fiscal matters. This poses a structural challenge for including the AJP's proposed federal clean energy standard that we described in an earlier post and that is not included in the bipartisan framework.
Between now and August 6 when the Senate recesses until after Labor Day we will see "make or break" efforts by Senate Majority Leader Schumer and Speaker Pelosi to herd and coalesce their respective members around legislative language that can accomplish both tracks of President Biden's agenda with the expectation of final votes after Congress returns from recess.
- Third, legislation is a beginning, not an end of government policy engagement.万博体育app手机登录Regardless of the contours of final AJP legislation, if and when it is enacted, Congress inevitably will leave vast ambiguities and details to be resolved by administrative rulemaking, agency implementation guidance and likely an array of administrative and civil litigation. All stakeholders in the AJP, whether disappointed or pleased with the final legislative product, will carry forward myriad policy debates in these regulatory and judicial forums. So opportunities for continued policy engagement will be robust and, accordingly, we will continue to follow and write on these developments.
- Fourth, despite the divisiveness and rancor that have plagued American politics, the unfolding process seeking to enact the AJP is an object lesson in the fundamental optimism that historically has imbued American government and society."Build Back Better" embodies that optimism. While acknowledging that some in the world may like to see the United States democracy falter, President Biden in his April 28 Statement to a Joint Session of Congress urged that "we have to prove democracy still works — that our government still works and we can deliver for our people" and that, "if … "We the People" … all do our part … we will meet the center challenge of the age by proving that democracy is durable and strong … the future belongs to America." He concluded by adding "it's never, ever been a good bet to bet against America … There is not a single thing — nothing — nothing beyond our capacity. We can do whatever we set our mind to do if we do it together."
President Biden doubled down on this optimism in his June 24 statement in support of the bipartisan framework.白屋声明中说 : “ 总统上任后承诺寻找公有基础实现 — — 并实现这一承诺.[他]认为,我们必须投资于我们国家和人民,创造高薪工会工作,解决气候危机并持续增长经济,在未来几十年内实现公平.[他还]相信,我们正处在民主与自治之间的分界点上.拜登总统认为我们必须向世界展示美国民主能为美国人民实现.但民主需要妥协.[并As we first noted in our Earth Day post, the AJP targeted solutions to the twin "great challenges of our time: the climate crisis and the ambitions of an autocratic China." It was no coincidence that the White House launched the AJP prior to President Biden's Leaders Summit on Climate on Earth Day which was a warmup for the June 11-13 G7 Summit in Cornwall in which President Biden sought to reassure the World that "America is Back." That Summit culminated in the Carbis Bay Communiqué in which the leaders of the G7 democratic nations announced a joint agenda of global action to:
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- Reinvigorate our economies by advancing recovery plans that build on the $12 trillion of support we have put in place during the pandemic;
- Secure our future prosperity by championing freer, fairer trade within a reformed trading system, a more resilient global economy, and a fairer global tax system that reverses the race to the bottom;
- Protect our planet by supporting a green revolution that creates jobs, cuts emissions and seeks to limit the rise in global temperatures to 1.5 degrees!i/li/hrefs/ss/served/ss-releases/2021/06/12fact-president-pident-biden-g7-leaders-reading-building-back-bet-world-b3w-Partnership/So as Congress continues its non-linear legislative process that demands compromise, the larger geopolitical context should be a patriotic unifying factor to help forge final AJP legislation.
In conclusion, while the hurdles of vigorous, tense, political and policy negotiations and detailed bill drafting still remain, there is reason to be confident that over the next three months this Congress will pass, and President Biden will sign, a version of the AJP that will materially alter the size and impact of the federal government on the American economy and society. This legislation will set the stage for years of further regulatory proceedings, negotiated transactions, and a variety of litigation involving major stakeholders seeking to leverage the AJP's legislative outcome. This is how democracy works. Just as Amanda Gorman so eloquently pronounced about America in her Inaugural poem, "The Hill we Climb", likewise the AJP is "not broken, but simply unfinished." There is much more to come.
This is the twenty-sixth post in our series on "The ABCs of the AJP."
As we wrap up our blog series on the climate and energy implications of the Biden Administration's American Jobs Plan (AJP), it is an opportune moment to revisit our journey from A through Z, and reflect on whether the Biden Administration's proposed investment in infrastructure can set the nation on a path to achieve its 2050 net-zero target.
We started with our first post in the series on Earth Day, April 22, when, on the first day of the Leaders Summit on Climate, President Biden announced a new nationally determined contribution (NDC) to achieve a 50 to 52 percent reduction in economy-wide greenhouse gas (GHG) pollution from 2005 levels by 2030.
The President's announcement noted the many steps his Administration would take to support the NDC, which will be submitted to the United Nations Framework Convention on Climate Change in advance of the Conference of the Parties 26 later this year in Glasgow. The announcement also described the Administration's "whole-of-government" approach to addressing climate change, including through infrastructure investment and job creation.
We then discussed the ways in which the AJP could give life to the Administration's mantra to "Build Back Better," including through investments in battery technology, where we noted that Princeton's Net-Zero America study projected a massive build-out of batteries to achieve deep-decarbonization goals on par with this Administration's. We also discussed why, besides addressing the climate crisis, the AJP is also intentionally designed to reverse the trend of China's dominance in manufacturing electric vehicle (EV) batteries and onshore that manufacturing capacity here in the U.S.
Other investments proposed by the AJP are intended to make the power grid more resilient, an objective made clearer by last winter's storms in Texas and the resulting power outages. As the AJP notes in supporting its proposed investments in distributed energy resources (DERs), power outages cost Americans over $70 billion each year in lost productivity.
The AJP notes how past infrastructure investments – most notably, construction of the largest infrastructure investment in the past century – often split communities apart, such as the construction of an elevated freeway through the middle of a predominantly African American neighborhood in Syracuse, New York. To leverage infrastructure investment to counteract environmental injustice, the AJP would instead target 40 percent of the benefits of climate and clean infrastructure investments to disadvantaged communities.AJP支持政府所有四大优先事项:响应COVID-19大流行创造工作支持经济恢复减少种族不平等and addressing climate change.
Recognizing the role that forests and working lands can play in climate mitigation and adaptation, the AJP also calls for $10 billion to create a new "Civilian Climate Corps." The AJP also endorses legislation introduced in Congress, which proposes $120 billion in wildfire and climate change resilience projects, forest health, and watershed restoration, as a means of creating two million jobs in rural America. Given the role that power lines have had in sparking wildfires in California, and the experience in Texas last February, the AJP also calls for $100 billion in grid modernization and hardening.
The AJP would also support game-changing technologies, such as green hydrogen. Hydrogen is viewed as key to decarbonization of hard-to-abate industrial processes and would be supported by the AJP's proposal of 15 decarbonized hydrogen demonstration projects in distressed communities and as part of an additional $15 billion increase in funding for climate R&D priorities.
Such proposed investments may reveal the disconnect between the AJP's broad concept of "infrastructure" and some of its opponents' narrower formulation of what should appear in an infrastructure package. While the Biden Administration views infrastructure investment as a vehicle to promote economic opportunity and equality and to address climate change, Republican proposals have sought to strip the package from many components viewed as either "soft" infrastructure or too focused on climate change.
As a vehicle of job creation, the AJP intends to blunt the impacts of the energy transition upon communities whose livelihood has centered around fossil fuels, including by ensuring that jobs in the clean energy economy would pay prevailing wages and provide opportunities for unionization. The Administration's objective in this regard – often referred to as "just transition" – is shared by international efforts to address climate change, including in the Paris Agreement and the European Green Deal.
Some of that just transition could be fulfilled in part by the AJP's proposal to invest $100 billion to modernize kids' schools and childcare facilities. Additionally, the AJP's proposal for a $40 billion Dislocated Workers Program to fund job training out of fossil-intensive industries and into union jobs might help support this transition in the labor force.
Other union-pleasing provisions of the AJP would seek to onshore critical supply chains, in accord with an Executive Order President Biden signed during his first week in office!题为“全美工人建设未来”,该命令将在整个联邦政府嵌入“BuyAmerica”限制,包括创建新主管s/www.insideEnergyandEnvironce.com/202/05/made- in-merica-spring-droduction-brough-buy-america-rules-bed/'Made-in-America The AJP would accomplish this through support for deployment of nascent technologies, such as small modular nuclear units and offshore wind, which the Administration announced it intends to increase by 30 gigawatts (GW) by 2030 through a series of federal actions. By that date, the Administration has also set a goal of reducing power-sector emissions by 80 percent, including through a centerpiece "Energy Efficiency and Clean Electricity Standard" – what's generally referred to as a "CES" – which would require load-serving entities to increase their reliance upon zero-carbon power sources each year.
But these targets raise the question of what constitutes zero-carbon power and whether carbon capture, utilization and sequestration (CCUS) can play a role in cleaning up both the power sector and the broader economy. Despite opposition to CCUS from many in the environmental community, the Administration made a bold move in the AJP, when it announced support for expansion of the bipartisan Section 45Q tax credit, and made clear that this would apply not only to hard-to-decarbonize sectors, but to direct air capture and retrofits of existing power plants as well.
Beyond its emission reduction targets, the AJP also intends to make the electricity grid more resilient, including through promoting utility-scale energy storage by making standalone storage projects eligible for the federal investment tax credit.
Much of the disconnect between Democrats and Republicans with respect to advancing the AJP's objectives involves how to pay for trillions in infrastructure investment. Another major unresolved question is whether the Administration can advance a CES to reduce emissions from electric utilities through the reconciliation process. The AJP, when announced, made it unclear whether the Administration would pursue this through executive action or legislation!indeed, the White House's statement that "President Biden will establish an Energy Efficiency and Clean Electricity Standard (EECES)" might be interpreted to suggest that no Congressional authorization is needed.
Another element of the AJP on the chopping block is its proposed $174 billion investment in EVs. Although that investment in electrifying the nation's vehicle fleet was the single largest expenditure in the AJP as initially proposed, the bipartisan framework omits $100 billion in EV subsidies.
In contrast, that framework supports $55 billion of the AJP's proposed $111 billion in investments into improvements in drinking water and wastewater management systems, reflecting that replacing lead service lines may more clearly fall within what is viewed as hard infrastructure, than EV charging stations and rebates.
Perhaps the X-treme weather experienced globally this summer will cause both parties to come closer on the need to address the impacts of a warming environment, both by reducing emissions and promoting adaptation. Yet, the more likely scenario is that, even if dressed as improving children's health, investments in climate mitigation lie in a politically intractable place.
What's clear is that the AJP's investments would amount to a significant down payment towards the changes in energy generation and consumption needed to achieve the Administration's new NDC. Some Republicans say it is too much, too soon. Some progressives say it is too little, too late!我们今天应该停止生产和使用化石燃料,而AJP指向美国正确方向上的最大问题肯定就是 何时何时何地大都参会 实现净零未来
This is the twenty-fourth in our series, "The ABCs of the AJP."
In 2020 alone, the United States suffered 22 separate extreme weather and climate-related disasters that each caused at least $1 billion in damages, for a total of more than $100 billion in losses. That staggering statistic is not an anomaly, as climate change continues to result in more and more extreme weather events every year. For example, the Texas freeze that rocked the state earlier this year and killed more than one hundred people, also shut down the state's significant petrochemical industry, disrupting supply chains nationwide, and caused an estimated $80 billion to $130 billion in direct and indirect economic losses.数以百计的死亡者为 < a hrefss/www.npr.org/2021/07/climbs-in-crips-northWest/
Given the escalating human and economic costs of extreme weather events, it is no surprise that the Biden Administration's American Jobs Plan (AJP) prioritizes climate resiliency, a topic which has also been covered in a prior blog post. Significantly, the AJP pledges that: "Every dollar spent on rebuilding our infrastructure during the Biden administration will be used to prevent, reduce, and withstand the impacts of the climate crisis." The AJP also proposes to spend $50 billion on investments to specifically improve the resiliency of the nation's infrastructure, highlighting the importance of protecting critical infrastructure and services, defending vulnerable communities, and "[m]aximiz[ing] the resilience of land and water resources to protect communities and the environment."
As for protecting vulnerable communities, the AJP points out that "[p]eople of color and low-income people are more likely to live in areas most vulnerable to flooding and other climate change-related weather events" and "[t]hey also are less likely to have the funds to prepare for and recover from extreme weather events." To improve resiliency for those communities most vulnerable "physically and financially to climate-driven disasters", the AJP proposes increased investments through existing programs, such as FEMA's Building Resilient Infrastructure and Communities program and HUD's Community Development Block Grant program, new initiatives at the Department of Transportation, as well as "a bipartisan tax credit to provide incentives to low- and middle-income families and to small businesses to invest in disaster resilience, and transition and relocation assistance to support community-led transitions for the most vulnerable tribal communities."
Separately, the AJP would provide $500 million in grants and loan funds to renovate tens of thousands of multifamily homes to make them more resilient to extreme weather events.
Finally, the AJP proposes investing in nature-based resiliency, such as by restoring "our lands, forests, wetlands, watersheds, and coastal and ocean resources", as a means of wildfire and drought mitigation, among other goals. The Administration also suggests that such restoration and resilience project funds would follow the guidelines of the proposed Outdoor Restoration Force Act (S.近些年来,人们更加关注自然基础建设的潜在利益,值得注意的是,美国土木工程师学会首次使用s/informstructioncard.org/solups/reslience/历经数年研究分析 来自世界各地的专家 今年夏美Army Corps of Engineers is set to release first-of-their-kind guidelines for nature-based resilience projects.
Beyond the AJP, protecting against extreme weather has been a priority of the Biden Administration from the beginning. A few days into his presidency, President Biden signed a sweeping climate Executive Order which, among other things, directed federal agencies to develop climate resiliency plans. More recently, on May 24, 2021, the Administration announced a plan to invest $1 billion in protecting communities through FEMA's Pre-Disaster Building Resilient Infrastructure and Communities program. As with other actions taken by the Administration, this increased investment "seeks to categorically shift the federal focus from reactive disaster spending and toward research-supported, proactive investment in community resilience so that when the next hurricane, flood, or wildfire comes, communities are better prepared." Along with the increased funding, the Administration also announced plans to develop and launch "a new NASA mission concept for an Earth System Observatory" to better forecast and monitor natural disasters.
At this point, it is unclear whether or how Congress will act to implement the Biden Administration's proposals to protect against extreme weather. However, there are some signs of bipartisan interest in such legislation. For example, after the Texas freeze in early 2021, a bipartisan group of members of the Texas congressional delegation introduced the Power On Act (S.1432 帮助保护电网基础设施不受极端天气影响。此外,2019年,参议院环境与公共工程委员会一致通过了2019年美国交通基础设施法(
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Bipartisan Infrastructure Framework that the President endorsed last week would provide just about half of that amount – $55 billion – which the President nevertheless described as "the largest investment in clean drinking water and waste water infrastructure in American history."
Yet that includes all of the President's proposed investments in replacing lead-containing water service lines and pipes, reflecting apparent bipartisan agreement that reducing exposure to lead in drinking water is worthwhile.
Infrastructure, Unqualified and Unplugged
Municipal drinking water and wastewater treatment systems epitomize infrastructure.
In contrast to the electric vehicle and grid modernization technologies that the AJP also seeks to promote as solutions to the climate crisis, replacement of lead-containing domestic water service lines falls much more clearly within what's thought of as traditional infrastructure.
While the Bipartisan Framework would fund just half of the President's initially proposed water infrastructure investments, it includes all of the lead service-line replacement expenditures proposed by the President. Additionally, the Democratic-controlled House last week passed the INVEST in America Act (H.R.包括1 672.5亿美元的饮用水和废水基础设施拟支用量,由两位共和党成员s/clerk.house.gov/Votes/202208投票 Environmental Protection Agency, there is no safe level for lead in drinking water and even low levels of lead in children's blood can cause behavioral and learning problems, lower IQ and hyperactivity, slowed growth, hearing problems and anemia.
The memory of the recent Flint, Michigan water crisis also looms large in the public mindset. In Flint, where 40 percent of people live in poverty, the city made a cost-saving decision in 2013 to switch from obtaining its domestic water supply from Detroit, to the Flint River. The Flint's water was much more corrosive and not adequately treated, which resulted in lead in service lines and household plumbing leaching into the water.
Now, after $250 million of state funding and $100 million of infrastructure funding awarded by EPA pursuant to the Water Infrastructure Improvements for the Nation (WIIN) Act of 2016, the troubled service lines and household plumbing have largely been identified, with the last 500 service lines slated to be excavated, checked and replaced this month.
The situation in Flint – described by one researcher as the most egregious example of environmental injustice in recent U.S.历史 — — 成为对基础建设投资不足对贫困社区造成的不公平公共健康后果的象征Recent analysis suggests that lead exposure in the United States correlates to race.
Yet Flint is hardly unique:
- Newark, New Jersey, just recently removed over 18,000 lead service lines at no cost to residents.
- Washington, D.C., has embarked on a similar program, although one study found that customer-initiated service line replacements were being conducted primarily in higher-income neighborhoods.
These programs are costly and require significant levels of public investment to deploy at scale. Recognizing that, the AJP had initially proposed $45 billion in EPA State Revolving Fund and WIIN grants to replace all lead pipes and service lines for both homes and 400,000 schools and childcare facilities. The bill that the House passed last week includes funding for all of these efforts, plus an additional $53 billion to fund safe drinking water infrastructure and $51 billion for wastewater infrastructure.
Infrastructure and Environmental Justice
As described by our prior post, an animating principle of this Administration's infrastructure plan is addressing environmental injustice. And perhaps no feature of the AJP so tangibly marries the concept of traditional infrastructure to the Administration's environmental justice objectives as the proposed investment in the replacement of lead-containing water service lines.
Unlike other public health threats, the risks from exposure to lead have long been understood and its presence in domestic service lines and plumbing well known. As President Biden remarked upon pitching the Bipartisan Infrastructure Framework last week in Wisconsin, more than 70,000 of Milwaukee's 160,000 water service lines contain lead, although Milwaukee is far from unusual!上星期二EPA管理员Michael Regan与Milwaukee市长和副手一起出现
Even before the AJP was proposed, American automakers had been making EV commitments, and sales had been projected to grow. GM, for example announced its intention to sell only zero-emission passenger cars by 2035, while Ford introduced an electric version of its iconic Mustang and has announced plans to electrify the F-150, which has been the country's most popular vehicle for decades. Tesla, whose sales consist entirely of EVs, hit a number of impressive milestones in 2020, including delivering nearly 500,000 vehicles worldwide and joining the S&P 500
But EVs still face challenges that are delaying widespread adoption: EVs made up only about 2% of new car sales in the U.S.2020年成本竞争力大增,EVsss/www.bloomberg.com/news/newsletters/2021-05-25/hyperdrive-daily-ev-price-gap-nrows'has lagged behind other countries in terms of EV market share, again suggesting the benefits of proactive government intervention to encourage growth.
Enter the AJP, which would use diverse mechanisms to spur the American EV market:
- To address cost concerns, the plan proposes point of sale rebates and tax incentives for consumers.
- To expand necessary infrastructure, the plan seeks to establish grant and incentive programs for state, local, and private entities, with the goal of building 500,000 charging stations by 2030.
- To assist industry, the plan seeks to boost the entire EV domestic supply chain, beginning with critical raw materials like lithium and cobalt, all the way through improvements to American factories to make parts and the batteries themselves.
- The plan would also use the procurement power of the federal government to electrify the entire 645,000 vehicle federal vehicle fleet, further driving demand for EVs, including vocational and heavy duty vehicles.
- Finally, the plan would allocate research and development funds to developing the next generation of EV technology, to further drive down price and reduce reliance on raw materials.
This multi-pronged strategy reflects the "whole-of-government" approach that the President has articulated for dealing with the climate crisis. While all of these proposals and even more may ultimately be needed to spur the transition to EVs, the Bipartisan Infrastructure Framework announced last week includes only $7.5 billion for EV infrastructure, which the Administration says "will accomplish the President's goal of building 500,000 EV chargers;" but it includes none of the AJP's proposed $100 billion in EV subsidies.
Precisely because so much remains uncertain and so many different policy levers are available to affect the EV market, interested parties should carefully track how much of the AJP's originally proposed $174 billion in EV funding will ultimately be enacted as part of any bipartisan deal or budget reconciliation package.