Continued uncertainty: Department of Energy circulates latest “retain/modify” awards list

Last month, the Department of Energy (DOE) submitted a list to Congress that included 1,951 awards that it intends to retain or modify after conducting an unprompted, 16-months-long internal review process. This review process—which has yielded two formally published lists and two unofficially circulated lists, including this latest “retain/modify” list—has injected significant uncertainty into clean energy development and deployment at a time of surging energy and electricity prices. The latest list leaves many questions unanswered for both project developers and the broader U.S. energy markets.

Administering a dose of uncertainty

Throughout the first half of this decade, Congress repeatedly¹ directed DOE and other federal agencies to deploy federal financial resources to support clean energy development, bolster domestic supply chains, and secure the future of advanced American manufacturing. In response, DOE stood up innovative competitive funding opportunities for early-stage and first-of-a-kind projects across a wide array of energy and industrial technologies to support private sector innovation. Many projects were awarded federal funds and proceeded to obligation (i.e., entered into binding contracts) or outlay (i.e., disbursement) before January 20, 2025.

In 2025, DOE initiated an unprecedented, unprompted review of federal financial awards for hundreds of projects intended to advance American energy production and technological innovation. The review spanned multiple industries, including next-generation geothermal, grid and transmission infrastructure, nuclear energy, carbon capture and storage, advanced manufacturing, and natural gas technologies, despite the Trump administration’s publicly stated support for many of these technologies.

As CATF has previously recounted, the process yielded a May cancellation list of 24 awards worth about $3.7 billion. In October, DOE announced 321 award terminations worth approximately $7.56 billion (inclusive of the May list). A third overlapping list, reportedly from DOE, also circulated among industry, advocates, and policymakers later that month, including about 300 additional awards. In total, nearly 650 awards worth approximately $23 billion in federal funding were known to be jeopardized by the DOE’s review process. Unlike the prior two lists, the third list—which was never formally issued—included awards for projects located in Republican-controlled states and congressional districts.

Grantees that received formal cancellation notices could:

1. Close out the award;
2. Attempt to renegotiate the award;
3. Dispute the termination pursuant to the DOE’s regulatory process;² or
4. Challenge the termination in court.

Grantees, as well as impacted states, have pursued different options based on their perceived interests. Some grantees sued, alleging that the DOE’s cancellations targeted states that vote for Democratic candidates, and won a district court ruling that the Trump administration’s targeted cancellation violated the Fifth Amendment to the U.S. Constitution. A coalition of state attorneys general also filed suit. At least one grantee, working with DOE, is reportedly renegotiating the use of the grant money in a way that could violate congressional direction. Against that backdrop, a bipartisan Congress directed DOE to follow its previously published procedures for award terminations.³

At last, partial resolution

In mid-April 2026, DOE reportedly submitted to Congress a list of nearly 2,000 awards that the agency plans to “retain/modify.” A significant majority of these awards (1,667 out of 1,951) had never been placed on any of the lists published or circulated by DOE in 2025 (see table 1 below). Further, the DOE’s April 2026 retain/modify list failed to resolve the fate of the majority of awards that had been on its 2025 lists (see table 2 below), with 364 awards still uncertain.

Table 1: The majority of awards and dollars from the retain/modify list were not on any previous lists

	Awards	Amount
October 1 list (Announced)	16	$595.1M
October 7 list (Reported)	268	$11.2B
Not on any previous list	1,667	$12.1B
All projects	1,951	$23.9B

Table 2: The majority of awards from the 2025 lists were not addressed by the April 2026 retain/modify list (count of awards)

	Not addressed	Addressed by April 2026 retain / modify list	Total
October 1 list (Announced)	324	16	340
October 7 list (Reported)	40	268	308
Total	364	284	648

The awards retained or modified were originally made by a variety of DOE offices, including the Grid Deployment Office (GDO), the Office of Fossil Energy and Carbon Management (FECM), the Office of Energy Efficiency and Renewable Energy (EERE), the Office of Clean Energy Demonstrations (OCED), the Advanced Research Projects Agency-Energy (ARPA-E), and the Office of Manufacturing and Energy Supply Chains (MESC). By award count, almost three-quarters of the awards retained or modified were made by EERE. By award value, the largest group of awards retained or modified were made by MESC or OCED (see tables 3 and 4 below).

Table 3: Awards on retain/modify list, by office

	ARPA-E	MESC	OCED	GDO	FECM	EERE	Total
October 1 list (Announced)	–	1	–	13	2	–	16
October 7 list (Reported)	2	33	25	13	57	138	268
Not on any previous list	3	29	40	60	250	1,258	1,667
All projects	5	63	65	86	309	1,423	1,951

Table 4: Value, in millions of dollars, of awards on retain/modify list, by office

	ARPA-E	MESC	OCED	GDO	FECM	EERE	Total
October 1 list (Announced)	–	$20.3M	–	$553.7M	$21.1M	–	$595.2M
October 7 list (Reported)	$11.2M	$3,323.0M	$5,998.8M	$428.1M	$701.0M	$736.4M	$1,198.5M
Not on any previous list	$8.7M	$2,882.7M	$2,040.0M	$2,447.1M	$1,036.5M	$3,661.3M	$12,076.2M
Total	$19.9M	$6,223.0M	$8,038.8M	$3,428.9M	$1,758.6M	$4,397.8M	$23,869.8M

The awards on the retain/modify list are also predominantly from DOE’s base funding and the bipartisan Infrastructure Investment and Jobs Act (IIJA), rather than the Inflation Reduction Act (see table 5 below). Most of the award value derives from IIJA (see table 6 below).

Table 5: Award count by funding source

	IRA	IIJA	Base	Total
October 1 list (Announced)	–	14	2	16
October 7 list (Reported)	21	128	119	268
Not on any previous list	19	192	1,456	1,667
Total	40	334	1,577	1,951

Table 6: Award value ($M) by funding source

	IRA	IIJA	Base	Total
October 1 list (Announced)	–	$574.1M	$21.1M	$595.2M
October 7 list (Reported)	$2,411.2M	$8,248.4M	$538.8M	$11,198.5M
Not on any previous list	$1,765.5M	$5,997.7M	$4,312.9M	$12,076.2M
Total	$4,176.8M	$14,820.2M	$4,872.9M	$23,869.8M

An analysis of the DOE’s retain/modify list sheds some light on the DOE’s perspectives on specific technologies, but also raises questions about internal cross-administration consistency

Hydrogen: Outstanding discrepancies between the treatment of hydrogen hubs in Fiscal Year 2027 President’s Budget Request (FY 2027 PBR) and the retain/modify list create fresh uncertainty

In 2021, IIJA provided $8 billion to seed regional clean hydrogen hubs around the country. In 2025, many of these projects were thrown into question by the administration’s previous lists of canceled awards, which included hydrogen hub awards. Two recent administration documents, the retain/modify list and the FY27 PBR, do not resolve uncertainty for the hydrogen hubs.

There is tension between the circulated retain/modify list and the FY2027 PBR that the administration released on April 3:

• The PBR requests to “repurpose” $3.5 billion in funding from IIJA’s Regional Hydrogen Hubs program to new DOE funding accounts for baseload power (coal upgrades, oil and gas upgrades and related infrastructure, among other uses) and $1.2 billion to fund artificial intelligence and quantum activities.⁴ Separately, the PBR also asks Congress to “permanently cancel” $3.25 billion in unobligated funding for hydrogen hubs.⁵ These proposed actions would eliminate the majority of the $8 billion hydrogen hubs program funding.
• While the PBR seeks to cancel or transfer this funding, the retain/modify list includes awards for five of the seven hydrogen hubs projects that would tap into that very same source. This potential misalignment underscores the uncertainty that directly impacts grantees and which may slow the growth of the U.S. clean hydrogen industry more broadly.

Carbon management: The industry fares better than expected in the retain/modify list

The carbon management sector was particularly hard hit by DOE’s 2025 cancellations. The retain/modify list suggests that the administration may be taking a more balanced approach in 2026. DOE’s unprompted review of approximately $2.7 billion in carbon capture and storage (CCS) awards yielded roughly $2.0 billion (74 percent) in provisionally confirmed cuts, with $718 million retained across 59 awards. The pattern of cuts and retentions suggests possible sectoral priorities, although uncertainty remains given the incomplete nature of the retain/modify list.

• Injecting uncertainty into geologic storage: a priority without appropriate funding. DOE retained most CarbonSAFE geologic storage projects (22 of 29). This group includes awards for 19 of 25 IIJA-funded projects and three of four base appropriation projects. Regional hubs across the Gulf Coast, Wyoming corridor, and the Southeast were on the retain/modify list. However, implementation and funding uncertainty remains. While DOE included 19 IIJA-funded CarbonSAFE awards on the retain/modify list, totaling $433M, disbursement remains relatively low (~$79M, or 18%) according to USAspending.gov. Two projects on the retain/modify list (Project Crossroads, Virginia CarbonSAFE) show $0 disbursed, and several projects from the most recent Round III selection (October 21, 2024) have not yet finalized awards. DOE language explicitly noted these projects were “selected for negotiation,” not formally awarded, before the 2025 cancellations began. As noted, “retained” or “modified” do not necessarily mean “funded.” Until awards are finalized and funds are disbursed, these projects remain in administrative limbo, potentially vulnerable to further delays, scope reductions, or de facto cancellations through lack of funding. The combination of low disbursement rates and unfinalized awards suggests that even projects covered by DOE’s stated priorities and/or inclusion on the retain/modify list may struggle to advance without clearer funding commitments.
• Direct air capture: commercial hubs retained, earlier stage projects cut. Despite cutting 13 DAC‑related awards totaling approximately $52 million, DOE retained awards for the two commercial‑scale Regional DAC Hubs: South Texas ($50 million, primarily for 1PointFive) and Project Cypress in Louisiana ($50 million primarily for Battelle, Climeworks, and Heirloom). DOE also retained awards for six of 16 smaller regional DAC studies, totaling approximately $33 million.
• Decarbonized fossil energy: a mixed bag.
  • Coal power plants with CCS. Awards for early-stage coal decarbonization demonstrations were generally included on the retain/modify list, including awards for Dry Fork Station ($4.7 million, Membrane Technology & Research—a smaller demonstration project), Coal Creek CarbonSAFE ($42.8 million), and Edwardsport ($8.2 million). Project Tundra’s $4.2 million retention represents only the first installment of a potential $350 million total award—Phase 1 funding for permitting and community engagement rather than the full commercial demonstration that would capture 4 million metric tons of CO₂ annually from the Milton R. Young coal plant. Notably, the $49 million Dry Fork Large-Scale Pilot (a separate, larger project by TDA Research at the same power plant) is not included in the retain/modify list.
  • For natural gas combined cycle (NGCC) power plants with CCS, DOE followed a similar pattern, retaining small demonstrations at Lake Charles Power Station ($9.2 million) and the Polk Power Station ($4.7 million), and front-end engineering and design (FEED) studies at Pastoria Energy Facility, as well as two engineering-scale R&D projects. However, DOE terminated the $72 million Cane Run large-scale pilot along with federal funding for the Baytown and Sutter demonstrations. The Baytown funding was for Phase 1 of a project with up to $270 million in federal cost share and approximately $1 billion in total investment which, if completed, would capture 2 million metric tons of CO₂ annually from an 810 MW plant; Sutter represented an estimated $500+ million total project capturing 1.75 million metric tons annually from a 550 MW California facility. These federal funding cuts represent a setback for DOE’s efforts to accelerate learning by doing for natural gas deployed with CCS.

Industrial: The status of awards for key industrial decarbonization technologies is unknown because they do not appear on the “retain/modify” list

Notably not listed on the retain/modify list were awards to large Industrial Demonstration Program (IDP) projects that were listed as cancelled in 2025. These five major projects, which would have received ~$1.4 billion in federal awards, were not listed on the retain/modify list despite their significant potential to advance key strategic products that enhance American firms’ international economic and technological competitiveness (see table 7 below). e-Fuels and e-Methanol, for instance, could be critical to the long-term domestic prospects of the U.S. aviation and maritime industries, as highlighted by the energy security challenges stemming from the current U.S. war with Iran. The Dow Battery Chemicals facility would help to onshore part of the lithium-ion battery supply chain critical to products including electric vehicles, drones, energy storage, and other industrial applications.

Table 7: Some key industrial demonstration projects not included on retain/modify list

Sector	Facility	Federal Award Amount	Location
Cement	Heidelberg Mitchell Cement	$500 million	Mitchell, Indiana
Cement	Lebec Net Zero Cement	$500 million	Lebec, California
Chemicals & Advanced Fuels	SECURE e-Fuels/Ethylene	$200 million	U.S. Gulf Coast
Chemicals & Advanced Fuels	Star e-Methanol (Orsted)	$99 million	U.S. Gulf Coast
Batteries	Dow Battery Chemicals	$95 million	U.S. Gulf Coast

Beyond not clearly retaining or modifying awards to very large, potentially high-impact industrial projects with long-term implications for international economic competitiveness and local economies, DOE’s list does not retain or modify awards for other projects. For instance, the $4.3 million Vicksburg Containerboard Mill pilots, the only pulp and paper sector project (a sector that CATF has highlighted as particularly ripe for CCS and carbon dioxide removal (CDR) deployment) in the portfolio, does not appear on the retain/modify list. DOE did retain awards for smaller-scale industrial demonstrations and R&D projects, including cement capture R&D at Mitchell ($5 million—a separate, smaller project at the same facility described above), Foreman Cement FEED ($7.6 million award), cryogenic cement capture R&D ($5.9 million award), and an award for a steel production capture test.

One IDP award that has so far been retained highlights the potential modifications that an awardee might pursue with the Trump administration following the retain/modify list. The Biden-era DOE originally awarded up to $500 million to Cleveland Cliffs to transition a steel blast furnace to a “hydrogen-ready flex-fuel” facility as part of a project that was estimated to reduce emissions by 1 million metric tons of CO₂ annually. Reportedly, the company may instead use the award funding to re-line the blast furnace, which would lock in emissions.

Key questions remain after DOE’s circulation of the “retain/modify” list

Although the circulation of the retain/modify list reduces some uncertainty for project developers in the private sector, DOE still has not answered several key questions regarding the disposition of awards in its project review process:

• The list is titled “retain/modify.” Which awards are retained and which are modified?
• What is the scope and type of modification for projects that are modified? It is possible that some modifications may contravene congressional direction and expose award recipients to additional risks.
• The list does not address 364 projects from the two October lists. What is the status of these projects?
• Does DOE have the staffing capacity to properly oversee and manage grants, given headcount reductions at the agency over the past year?
• Awards that are included on the retain/modify list circulated by the Department of Energy are, in some cases, also listed as cuts in the FY2027 President’s Budget Request, as described above for hydrogen hubs. Will these awards (and other awards with similar conflicting dispositions) be retained, modified, or cut?

Beyond DOE, further uncertainties remain as grantees and Congress evaluate their courses of action. Will grantees whose awards were canceled accept the cancellations or pursue legal recourse? Will recipients proceed with projects in the absence of federal funding? How will Congress, which already weighed in through the appropriations process, react to the outcome of the unprompted review process? If Democrats take control of the House or Senate following November’s elections, will they conduct oversight into the grant cancellation and modification process? Given the uncertainty injected by a changing administration’s review, will future federal funding opportunities receive comparable levels of interest from the private sector?

DOE’s informal circulation of a retain/modify list, even a partial one, is an improvement over project cancellation lists. However, DOE has still not eliminated the uncertainty generated by its own actions. To do so, DOE should officially publish a final list of project dispositions to resolve the above questions, close its review process, and consent to congressional direction to follow its own published processes for future project reviews.

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Footnotes

¹ Through the bipartisan Infrastructure Investment and Jobs Act, the Inflation Reduction Act, and bipartisan annual appropriations bills.

² 2 C.F.R. § 910.128 (Disputes and appeals).

³ Explanatory Statement Submitted by Mr. Cole, Chair of the House Committee on Appropriations, Regarding H.R. 6938, Commerce, Justice, Science; Energy and Water Development; and Interior and Environment Appropriations Act, 2026; Volume 172 at H390 of the Congressional Record (January 8, 2026). “Award Terminations.—DOE shall carry out federal award terminations in accordance with its published procedures in the Department of Energy Guide to Financial Assistance (effective October 1, 2024). The Department shall not terminate a federal award in part or its entirety or require a renegotiation or rescoping of a federal award on the basis that the federal award no longer effectuates program goals or agency priorities, including pursuant to section 200.340(a)(4) of title 2, Code of Federal Regulations, without following the Department’s published procedures.”

⁴ Department of Energy Budget in Brief, FY2027 Congressional Justification at 51. Available at: https://www.energy.gov/documents/doe-fy-2027-budget-brief.

⁵ Appendix to the Fiscal Year 2027 President’s Budget Request, at 424 n. 21-23. Available at: https://www.whitehouse.gov/wp-content/uploads/2026/04/appendix_fy2027.pdf.