According to media reports, Energy Department officials are compiling a list of clean energy projects, awarded billions of dollars, that could be overturned by the Trump administration in what may become the most significant rollback of the Biden administration's climate policies to date.

The list, requested by Trump administration officials and expected to be completed any day, includes projects funded through the Inflation Reduction Act, bipartisan infrastructure law, and regular appropriations, according to the Politico report. Projects or programs that have spent less than 45 percent of their allocated or awarded funding reportedly are subject to review.

According to the published report, the initial list of projects recommended for elimination includes:

• $8 billion for hydrogen hubs; 
• $7 billion for carbon capture hubs;
• $6.3 billion for industrial demonstrations;
• $500 million for long-duration energy storage;
• $133 million for the Liftoff program for accelerating new technology development; and $50 million for distributed energy programs.

While we are watching the situation closely, the Trump Administration has yet to comment on the Politico report or the specifics of such a list of targeted projects. However, the administration and Congressional Republicans already have targeted Environmental Protection Agency (EPA) grants and funding allocated by the Biden Administration. Days ago, a Congressional committee asked interim EPA Administrator Lee Zeldin for a briefing on grants and funding awarded by the agency under the Biden Administration.

If you are a private company, nonprofit or university that has received a guaranteed loan, grant, or contract that has been identified for elimination:

• FIRST - Look to the four corners of the agreement with the Federal government to understand the terms that define available remedies. 
• SECOND - Take administrative action as directed by the agreement or other legal provisions (the Code of Federal Regulations, Federal Acquisition Regulations). 
• THIRD – Consider challenging it in court, while weighing the political considerations against business realities.
• FOURTH – Maintain detailed documentation of the cost and time impacts associated with any modifications or terminations of agreements.
• FIFTH – Communicate with your subcontractors and suppliers about potential impacts.

Additionally, it may be prudent to consider direct advocacy before Congress and the Administration, leveraging memberships in trade associations or directly engaging with elected officials.