Undercurrent: early signal intelligence for people who can act on it

Last week we flagged Vermont H0159 - a bill to repeal the state's Renewable Energy Standard, with 24 sponsors, unusually high for a repeal measure in a Democratic-majority legislature.

This week a second Vermont bill appeared that goes after something larger. The target has shifted from a specific policy to the legal architecture that makes climate commitments enforceable at all.

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HOW TO READ THIS BRIEF

Undercurrent tracks threats to environmental protection and clean energy across all 50 states - surfacing coordinated campaigns, emerging tactics, and early warning signals before they become visible as organized efforts. 

Each brief moves from orientation to signal to context. Threat entries include a stage (how far along the threat is), a trigger (what would move it forward), and a leverage point (where a small amount of effort could matter disproportionately).

The stages:

• Pre-legislative - 12-36 months out

• Infrastructure building - 6-12 months out

• Active legislation - introduced and moving

• Enacted - signed into law

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THE WEEK AT A GLANCE

The landscape this week: enforcement mechanisms are the primary target across multiple states - not the laws themselves, but the legal teeth behind them.

A secondary tactic is emerging alongside outright repeal: redefine what counts as "renewable" until the mandate means something different than what voters or legislators intended. Both approaches achieve rollback with lower political visibility than repeal.

Read this first if time is short:

- Vermont: opposition escalated from RPS repeal to attacking the enforcement architecture of the climate law itself

- Missouri: five bills against a voter-passed standard, with dilution as the lower-visibility path

- Hawaii: the enforcement-removal bill matters more than the target-reduction bill

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THIS WEEK'S FORWARD-LOOKING SIGNALS

Two signals that escalated or appeared for the first time this week.

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Vermont introduced a second bill that would make its climate law legally unenforceable. That's a different threat than repealing the RPS - and a harder one to reverse.

Last week: H0159, a bill to repeal Vermont's Renewable Energy Standard. Twenty-four sponsors, a named PAC (REAL PROGRESS) that formed six days before the bill was introduced.

This week: S0110, targeting the Global Warming Solutions Act itself. It would repeal the Affordable Heat Act, convert Vermont's binding greenhouse gas reduction targets into aspirational goals, and eliminate citizen suit enforcement of climate commitments.

The backstory matters. In January 2026, the Vermont Public Utility Commission issued a final order concluding that the Clean Heat Standard rulemaking - four years and $1.7 million in the making - was administratively unworkable. That was a genuine regulatory failure, and it gave the opposition a real opening. S0110 uses that opening not to fix the failed program but to attack the enforcement architecture of the broader climate law.

The distinction between H0159 and S0110 is the distinction between repealing a policy and making a law unenforceable. A repealed law can be reinstated. A law stripped of its enforcement mechanism - targets converted from binding to aspirational, citizen suit provision eliminated - operates differently. Future governors can miss emissions reduction targets without triggering litigation. The commitment exists on paper. It has no legal force.

Emerging playbook: Create a regulatory failure. Use it to justify structural rollback. Target enforcement, not just policy. Watch for this sequence in other states where clean energy programs have encountered implementation problems.

Coordination signal: 24 sponsors on H0159 in a legislature this size is organized momentum. REAL PROGRESS PAC formed before the bills were filed. S0110 arrived as a second front after H0159 established the political infrastructure. This is sequenced, not coincidental.

A Democratic majority blocks both bills this session. But the infrastructure outlasts a failed session, and the PUC's January ruling gives the opposition a procedural argument they didn't have last year.

Priority: High

Stage: Infrastructure building - Active legislation

Trigger: Legislative majority shift

Leverage point: S0110 co-sponsor count is the leading indicator - it targets a different law and may attract different support than H0159. Watch it independently.

If this holds: Vermont's binding 40% emissions reduction target by 2030 becomes aspirational. A future governor can miss it without legal consequence.

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Missouri has five bills attacking a renewable standard its voters passed by ballot initiative. The lower-visibility bills are the ones to watch.

Missouri is not on most clean energy watch lists. It should be.

Five bills in this session target Missouri's Renewable Energy Standard. Two (HB2475, HB2578) would dilute the standard by replacing "renewable energy resources" with "alternative energy resources," allowing nuclear and pumped storage to count toward the mandate. Others modify or repeal RPS provisions outright.

What makes Missouri structurally different: voters passed this standard themselves. In November 2008, Missourians approved Proposition C - the Missouri Clean Energy Act - with 66% support. Legislative rollback of a voter-passed mandate overrides a direct democratic decision. That history has not been prominent in coverage of these bills.

Emerging playbook - "redefine, don't repeal": The dilution approach has lower political visibility than outright repeal. It looks like a technical amendment. It achieves the same result. The same tactic is appearing in NH (HB219 restructures RPS class requirements) and MD (SB706 reduces Tier 1 targets). Watch for it in states where outright repeal has repeatedly failed.

Coordination signal: Five simultaneous bills against a standard that has survived annual repeal attempts since 2013 suggests recalibrated opposition. No named campaign yet, no new FEC signal. The cluster is notable; confirmed coordination awaits further evidence.

Priority: Medium

Stage: Active legislation

Trigger: Committee advancement on HB2475 or HB2578

Leverage point: The dilution bills are lower-visibility and more likely to advance than outright repeal. Opposing them on "redefining renewable" grounds - and surfacing the ballot initiative history - is the higher-leverage argument.

If this holds: Missouri's RPS effectively covers nuclear and pumped storage, not new wind and solar. The voter mandate remains on the books. What it requires changes substantially.

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IN SESSION NOW

Hawaii's most significant RPS threat isn't the bill that reduces the target. It's the bill that removes the consequence for missing it.

Hawaii has a 100% renewable energy standard. HB1745 would reduce that target to 70% by 2045 - that's the bill that gets attention. SB1499 removes enforcement penalties for utilities that miss RPS targets. The 100% standard would remain on the books. A utility that fails to meet it faces no legal consequence.

This is the same structural approach as Illinois HB4124 and SB2720 - achieve the practical effect of repeal without the political visibility of repealing the law. Three separate bills attacking three separate mechanisms of Hawaii's clean energy framework in one session - the target level (HB1745), the compliance timeline (SB1370), and the enforcement penalty (SB1499) - is its own coordination signal.

Priority: High - SB1499 specifically

Leverage point: SB1499 is lower-visibility than HB1745 but higher-consequence. If only one of the three bills passes, enforcement removal is the worst outcome.

If this holds: Hawaii's 100% clean energy standard becomes the most ambitious unenforceable target in the country.

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STILL TRACKING

No major developments on these since last week’s brief. The core findings stand.

Illinois - The four-bill campaign against the Climate and Equitable Jobs Act remains the most structurally significant active threat in this dataset. HB2633 and HB4088 would repeal CEJA outright. HB4124 and SB2720 would prohibit state agencies from regulating CO2 from power generation - making CEJA unenforceable even if repeal fails. The authority-strip pair is the more dangerous instrument: stripped regulatory authority is harder to restore than a repealed law. A Democratic supermajority blocks passage this session. All four remain Introduced.

Rhode Island - S2080 and H7531 would repeal the 2021 Act on Climate and eliminate the citizen enforcement right that opens for the first time this year. Simultaneous introduction in both chambers was a coordination signal when these bills appeared; nothing has changed that read. Both remain Introduced, no committee advancement.

Michigan - SB0322 and HB5711 (full repeal of 2023 clean energy standards) remain Introduced, blocked by Whitmer's veto. HB5710 - which would strip the Michigan Public Service Commission of authority to override local zoning for large-scale solar and wind - is the bill to watch independently of the election. It doesn't need a new governor to create project-level permit risk. November election remains the primary trigger for the repeal bills.

New Jersey - S2463 (RGGI withdrawal) and A4491 (gas plant procurement mandate) remain Introduced. Governor Sherrill's veto holds. The two bills are independent tracks - A4491 doesn't require S2463 to advance. 2027 elections, when both the governorship and legislature are up, remain the trigger for simultaneous movement on both.

West Virginia - HB4556, the single-sentence net metering elimination, remains Introduced. Lawrence Berkeley research associates net metering with 40-60% of distributed solar adoption. No advancement since our last brief.

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RECENT DEVELOPMENTS

Florida S1510 - still active, changed context.

H1417 was signed in March - the Environmental Regulation Commission eliminated, rulemaking authority transferred to DEP. Companion bill S1510, which would further weaken wastewater treatment requirements, remains Introduced. The oversight body that would previously have challenged DEP rulemaking on wastewater no longer exists. S1510 moves through a fundamentally changed regulatory landscape.

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OPPORTUNITIES - WHERE ADVOCATES CAN ADVANCE, NOT JUST DEFEND

Places where the landscape is shifting toward stronger environmental protection, or where a small amount of effort could have outsized effect.

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Maryland is fighting itself - and how it resolves will signal something about the durability of state clean energy support.

SB706 would reduce Tier 1 RPS targets through 2030. SB341, HB345, and SB669 move in the opposite direction: strengthening the RPS, expanding solar procurement, and extending the small solar incentive program from 270MW to 540MW capacity. These reflect genuine legislative conflict inside a single state. How they resolve matters beyond Maryland - it's a useful leading indicator of whether state-level clean energy support holds under current political pressure.

Leverage point: The three strengthening bills are moving together as a package. Supporting that package while opposing SB706 is a coherent single-state play with visible stakes.

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Alaska introduced a clean energy strengthening bill in a Republican-controlled legislature. It won't pass. Its existence is the signal.

HB153 and SB149 would strengthen Alaska's RPS in a legislature that has historically opposed clean energy mandates. Their significance is that they exist at all - a pre-legislative signal in the opposite direction from Minnesota. The political cost of opposing clean energy is rising even in states with deep fossil fuel infrastructure.

Stage: Pre-legislative

What to watch: Whether these bills gain co-sponsors or similar bills appear in other traditionally hostile legislatures.

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DC's grid interconnection reform targets the bottleneck that defeats clean energy projects before they face any legislative threat.

B26-0602 reforms grid interconnection - the process by which new clean energy generation connects to the grid. Interconnection queue backlogs are currently one of the most significant practical barriers to clean energy deployment nationally, often more consequential than the legislative environment. A bill addressing the practical mechanics of deployment is worth noting in a session where most of the legislative energy is defensive.

Leverage point: Interconnection reform has broader coalition potential than RPS legislation - utilities, developers, and ratepayer advocates all have reasons to support it.

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ALL THREATS - APRIL 20, 2026

FL S1510 - ERC companion; weakens wastewater treatment standards; oversight body now eliminated (Introduced)

HI SB1499 - Removes enforcement penalties for RPS violations; leaves 100% standard unenforceable (Introduced)

HI HB1745 - Reduces Hawaii RPS from 100% to 70% by 2045 (Introduced)

HI SB1370 - Extends energy efficiency deadline 15 years to 2045 (Introduced)

IL HB4124 - Prohibits state agencies from regulating CO2 from power generation (Introduced)

IL SB2720 - Companion to HB4124; same effect (Introduced)

IL HB2633 - Full repeal of Climate and Equitable Jobs Act (Introduced)

IL HB4088 - Full repeal of CEJA; companion to HB2633 (Introduced)

MD SB706 - Reduces RPS Tier 1 clean energy requirements through 2030 (Introduced)

MI SB0322 - Repeals 2023 clean energy standards (Introduced)

MI HB5711 - Eliminates clean and renewable energy standards; companion to SB0322 (Introduced)

MI HB5710 - Weakens integrated resource planning; strips permit override authority (Introduced)

MO HB2475 - Dilutes RPS by reclassifying nuclear and pumped storage as renewable; overrides 2008 voter mandate (Introduced)

MO HB2578 - Companion dilution bill; same effect (Introduced)

MO HB2807 - Modifies RPS provisions; part of five-bill session cluster (Introduced)

NH HB219 - Eliminates Class II solar carve-out; caps Class I renewable mandates at 15% (In Committee)

NH HB1721 - Limits new RPS enrollment; reduces compliance payment effectiveness (Introduced)

NH HB224 - Redirects Renewable Energy Fund toward ratepayer rebates; defunds clean energy investment (Introduced)

NJ S2463 - Withdraws from RGGI; repeals state climate law (Introduced)

NJ A4491 - Mandates state procurement of new natural gas plants (Introduced)

NJ S1710 - Highlands Water Protection Act exemptions; affects 5M people's drinking water (Introduced)

NY A09221 - Repeals building electrification requirements and decarbonization plans (Introduced)

RI S2080 - Repeals 2021 Act on Climate; eliminates citizen enforcement right opening in 2026 (Introduced)

RI H7531 - Companion repeal bill; same effect (Introduced)

VA SB69 - Repeals renewable energy mandates; declares only nuclear in public interest (Introduced)

VT H0159 - Repeals Renewable Energy Standard; 24 sponsors; REAL PROGRESS PAC formed before introduction (Introduced)

VT S0110 - Repeals Affordable Heat Act; converts Global Warming Solutions Act binding targets to aspirational; eliminates citizen suit enforcement (Introduced)

WV HB4556 - Eliminates net metering; removes primary driver of distributed solar adoption (Introduced)

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ALL STRENGTHENING - APRIL 20, 2026

MD SB341 / HB345 - Strengthens RPS; increases required solar REC procurement; expands portable solar authorization (Introduced)

MD SB669 - Extends small solar incentive program to 2031; doubles capacity cap from 270MW to 540MW (Introduced)

DC B26-0602 - Reforms grid interconnection to support clean energy deployment (Introduced)

NY S09008 - Comprehensive clean energy budget; solar targets, EV rebates, heat pump programs, interconnection reform (Introduced)

MA H4827 - Streamlined 12-month permitting for small clean energy facilities (Introduced)

DE SB9 - Strengthens state environmental protection authority (Introduced)

WA SB5466 - Improves electric transmission reliability and capacity for clean energy (In Committee)

AK HB153 / SB149 - Strengthens renewable portfolio standard in Republican-controlled legislature (Introduced)

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Undercurrent.is · Alphaville Studio