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Climate Change: Great news for global warm-ongers: New data show the world is on target to meet the Kyoto targets for reducing greenhouse gas emissions. The bad news: It took a major economic collapse to get it done.

The U.N. says the 40 signatories to the Kyoto treaty have, on average, cut their emissions to 5% below their levels of 1990 — just meeting the goals for 2008 to 2012. So on the surface, things look very good.

But the data are deceiving. As the publication the New Scientist noted, "Much of the 17% drop is a consequence of the economic downturn of eastern and central European nations in the 1990s."

"Downturn" is almost too polite a term. Take the period right after the collapse of communism in 1990, when many countries in the area were struggling to rebuild their economies after decades of top-down stagnation. This economic implosion led to a 37% drop in greenhouse gas emissions among the so-called "economies in transition" from 1990 to 2006.

In other words, it took a regional depression for Kyoto to meet its goals, as data from renowned economist Angus Maddison show.

For the seven main economies in Eastern Europe — Albania, Bulgaria, Czechoslovakia, Hungary, Poland, Romania and the former Yugoslavia — per-person output measured in 1990 dollars declined 17% in the first three years of the 1990s. The fall was so steep, it took the region until 1998 just to get back to 1990's average per-person GDP of $5,440.

It was even worse for Russia and the former Soviet Republics. Those economies contracted 43% from 1990 to 1998. It took them 17 years to regain the same level of output — $6,890, on average — as they had in 1990.

What has really happened is that major industrial economies aren't reducing their so-called greenhouse gas emissions at all. Indeed, the industrial economies excluding the former communist ones have actually increased greenhouse gas output by 9.9% since 1990. Supposed "progress" in meeting the Kyoto limits is an illusion.

The U.S., which has increased output by 14% since 1990, has actually performed better than most of Europe since 2000. We have never ratified the Kyoto treaty, so we come in for routine bashing because of our supposed dirty ways.

But many other countries that have signed the deal are doing far, far worse. Spain, for instance, is up a whopping 50.6%; Australia, 28.8%; and Ireland, the land of green, 25.6%. Canada, whose diplomats repeatedly score us for our ungreen ways, turns out to be quite a dirty bird itself, increasing greenhouse gases by 21.7%.

In all, 20 countries aren't living up to the agreement — including greener-than-thou Germany.

If it matters to everyone so much, why shouldn't the U.S. just go ahead and sign on to the Kyoto accords? Well, remember the Eastern European economies. They had to basically collapse in order to help the world meet its Kyoto goals. That's what it would take in the U.S., too.

This is the hidden truth about Kyoto: It isn't greenhouse gases the U.N. wants to control. It's big, successful capitalist economies like America's that it wants to rein in. (The world's fastest-growing polluters, India and China, are exempt.) The U.N. itself estimates that reducing global warming would require a permanent hit of at least 1.5% of world GDP — or roughly $1 trillion a year for decades to come.

For the U.S., the hit might be even more severe. Under Kyoto's strict requirements, according to forecasts from the U.S. Energy Department, the costs could reach as high as 4.1% of GDP — or about $570 billion a year. It would kill nearly 5 million jobs. Still want to sign on?

In two weeks' time, global warming bureaucrats from around the world plan to meet in Poznan, Poland, to plan their next move — including figuring out a way to get President-elect Obama aboard the Kyoto train. Obama vowed to "once again engage vigorously in these negotiations."

We hope that once he realizes this Kyoto deal is intended to economically damage the very people who put him in office, he'll have a change of heart.

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Investor: Hydro One has too many unknowns to be a good investment

Hydro One investment risk reflects Ontario government influence, board shakeup, Avista acquisition uncertainty, regulatory hearings, dividend growth prospects, and utility M&A moves in Peterborough, with stock volatility since the 2015 IPO.

 

Key Points

Hydro One investment risk stems from political control, governance turnover, regulatory outcomes, and uncertain M&A.

✅ Ontario retains near-50% stake, affecting autonomy and policy risk

✅ Board overhaul and CEO exit create governance uncertainty

✅ Avista deal, OEB hearings, local utility M&A drive outcomes

 

Hydro One may be only half-owned by the province on Ontario but that’s enough to cause uncertainty about the company’s future, thus making for an investment risk, says Douglas Kee of Leon Frazer & Associates.

Since its IPO in November of 2015, Hydro One has seen its share of ups and downs, including a Q2 profit decline earlier this year, mostly downs at this point. Currently trading at $19.87, the stock has lost 11 per cent of its value in 2018 and 12 per cent over the last 12 months, despite a one-time gain boosting Q2 profit that followed a court ruling.

This year has been a turbulent one, to say the least, as newly elected Ontario premier Doug Ford made good this summer on his campaign promise re Hydro One by forcing the resignation of the company’s 14-person board of directors along with the retirement of its chief executive, an event that saw Hydro One shares fall amid the turmoil. An interim CEO has been found and a new 10-person board and chairman put in place, but Kee says it’s unclear what impact the shakeup will ultimately have, other than delaying a promising-looking deal to purchase US utility Avista Corp, with the companies moving to ask the U.S. regulator to reconsider the order.

 

Douglas Kee’s take on Hydro One stock

“We looked at Hydro One a couple of times two years ago and just decided that with the Ontario government’s still owning a big chunk of the company … there are other public companies where you get the same kind of yield, the same kind of dividend growth, so we just avoided it,” says Kee, managing director and chief investment officer with Leon Frazer & Associates, to BNN Bloomberg.

“The old board versus the new board, I’m not sure that there’s much of an improvement. It was politics more than anything,” he says. “The unfortunate part is that the acquisition they were making in the United States is kind of on hold for now. The regulatory procedures have gone ahead but they are worried, and I guess the new board has to make a decision whether to go ahead with it or not.”

“Their transmissions side is coming up for regulatory hearings next year, which could be difficult in Ontario,” says Kee. “The offset to that is that there are a lot of municipal distributions systems in Ontario that may be sold — they bought one in Peterborough recently, which was a good deal for them. There may be more of that coming too.”

Last month, Hydro One reached an agreement with the City of Peterborough to buy its Peterborough Distribution utility which serves about 37,000 customers for $105 million. Another deal to purchase Orillia Power Distribution Corp for $41 million has been cancelled after an appeal to the Ontario Energy Board was denied in late August. Hydro One’s sought-after Avista Corp acquisition is reported to be worth $7 billion.

 

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California faces huge power cuts as wildfires rage

California Wildfire Power Shut-Offs escalate as PG&E imposes blackouts amid high winds, Getty and Kincade fires, mass evacuations, Sonoma County threats, and a state of emergency, drawing regulatory scrutiny over grid safety and outage scope.

 

Key Points

Planned utility outages to curb wildfire risk during extreme winds, prompting evacuations and regulatory scrutiny.

✅ PG&E preemptive blackouts under regulator inquiry

✅ Getty and Kincade fires drive mass evacuations

✅ Sonoma County under threat amid high winds

 

Pacific Gas & Electric (PG&E) already faces an investigation by regulators after cutting supplies to 970,000 homes and businesses amid California blackouts that raised concerns.

It announced that another 650,000 properties would face precautionary shut-offs.

Wildfires fanned by the strong winds are raging in two parts of the state.

Thousands of residents near the wealthy Brentwood neighbourhood of Los Angeles have been told to evacuate because of a wildfire that began early on Monday.

Further north in Sonoma County, a larger fire has forced 180,000 people from their homes.

California's governor has declared a state-wide emergency.

 

What about the power cuts?

On Monday regulators announced a formal inquiry into whether energy utilities broke rules by pre-emptively cutting power to an estimated 2.5 million people, amid a blackouts policy debate that intensified, as wildfire risks soared.

They did not name any utilities but analysts said PG&E was responsible for the bulk of the "public safety power shut-offs", and later faced a Camp Fire guilty plea that underscored its liabilities.

The company filed for bankruptcy in January after facing hundreds of lawsuits from victims of wildfires in 2017 and 2018.

Of the 970,000 properties hit by the most recent cuts, under half had their services back by Monday, and some sought help through wildfire assistance programs, the Associated Press reported.

Despite criticism that the precautionary blackouts were too widespread and too disruptive, PG&E said more would come on Tuesday and Wednesday because further strong winds were expected.

The company said it had logged more than 20 preliminary reports of damage to its network from the most recent windstorm.

In a video posted to Twitter on Saturday, Governor Gavin Newsom said the power cuts were "infuriating everyone, and rightfully so".

 

Where are the fires now?

In Los Angeles, the Getty Fire has burned over 600 acres (242 ha) and about 10,000 buildings are in the mandatory evacuation zone.

At least eight homes have been destroyed and five others damaged.

"If you are in an evacuation zone, don't screw around," Mr Schwarzenegger tweeted. "Get out."

LA fire chief Ralph Terrazas said fire crews had been "overwhelmed" by the scale of the fires.

"They had to make some tough decisions on which houses they were able to protect," he said.

"Many times it depends on where the ember lands. I saw homes that were adjacent to homes that were totally destroyed, without any damage."

In northern California, schools remain closed in Sonoma County, where tens of thousands of homes and businesses are under threat.

Sonoma has been ravaged by the Kincade Fire, which started on Wednesday and has burned through 50,000 acres of land, fanned by the winds.

The Kincade Fire began seven minutes after a nearby power line was damaged, and power lines may have started fires according to reports, but PG&E has not yet confirmed if the power glitch started the blaze.

About 180,000 people have been ordered to evacuate, with roads around Santa Rosa north of San Francisco packed with cars as people tried to flee.

There are fears the flames could cross the 101 highway and enter areas that have not seen wildfires since the 1940s.

 

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DOE Announces $34 Million to Improve America?s Power Grid

DOE GOPHURRS Grid Undergrounding accelerates ARPA-E innovations to modernize the power grid, boosting reliability, resilience, and security via underground power lines, AI-driven surveying, robotic tunneling, and safer cable splicing for clean energy transmission and distribution.

 

Key Points

A DOE-ARPA-E program funding undergrounding tech to modernize the grid and improve reliability and security.

✅ $34M for 12 ARPA-E projects across 11 states

✅ Underground power lines to boost reliability and resilience

✅ Robotics, AI, and safer splicing to cut costs and risks

 

The U.S. Department of Energy (DOE) has earmarked $34 million for 12 innovative projects across 11 states to bolster and modernize the nation’s power grid, complementing efforts like a Washington state infrastructure grant announced to strengthen resilience.

Under the Grid Overhaul with Proactive, High-speed Undergrounding for Reliability, Resilience, and Security (GOPHURRS) program, this funding is focused on developing efficient and secure undergrounding technologies. The initiative is aligned with President Biden’s vision to strengthen America's energy infrastructure and advance smarter electricity infrastructure priorities, thereby creating jobs, enhancing energy and national security, and advancing towards a 100% clean electricity grid by 2035.

U.S. Secretary of Energy Jennifer M. Granholm emphasized the criticality of modernizing the power grid to facilitate a future powered by clean energy, including efforts to integrate more solar into the grid nationwide, thus reducing energy costs and bolstering national security. This development, she noted, is pivotal in bringing the grid into the 21st Century.

The U.S. electric power distribution system, comprising over 5.5 million line miles and over 180 million power poles, is increasingly vulnerable to weather-related damage, contributing to a majority of annual power outages. Extreme weather events, intensified by climate change impacts across the nation, exacerbate the frequency and severity of these outages. Undergrounding power lines is an effective measure to enhance system reliability for transmission and distribution grids.

Managed by DOE’s Advanced Research Projects Agency-Energy (ARPA-E), the newly announced projects include contributions from small and large businesses, national labs, and universities. These initiatives are geared towards developing technologies that will lower costs, expedite undergrounding operations, and enhance safety. Notable projects involve innovations like Arizona State University’s water-jet construction tool for deploying electrical cables underground, GE Vernova Advanced Research’s robotic worm tunnelling construction tool, and Melni Technologies’ redesigned medium-voltage power cable splice kits.

Other significant projects include Oceanit’s subsurface sensor system for avoiding utility damage during undergrounding and Pacific Northwest National Laboratory’s AI system for processing geophysical survey data. Prysmian Cables and Systems USA’s project focuses on a hands-free power cable splicing machine to improve network reliability and workforce safety, complementing state efforts like California's $500 million grid investment to upgrade infrastructure.

Complete descriptions of these projects can be found on the ARPA-E website, while a recent grid report card highlights challenges these efforts aim to address.

ARPA-E’s mission is to advance clean energy technologies with high potential and impact, playing a strategic role in America’s energy security, including military preparedness for grid cyberattacks as a priority. This commitment ensures the U.S. remains a global leader in developing and deploying advanced clean energy technologies.

 

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California's Next Electricity Headache Is a Looming Shortage

California Electricity Reserve Mandate requires 3.3 GW of new capacity to bolster grid reliability amid solar power volatility, peak demand, and wildfire-driven blackouts, as CPUC directs PG&E, Edison, and Sempra to procure resource adequacy.

 

Key Points

A CPUC order for utilities to add 3.3 GW of reserves, safeguarding grid reliability during variable renewables and peaks

✅ 3.3 GW procurement to meet resource adequacy targets

✅ Focus on grid reliability during peak evening demand

✅ Prioritizes renewables, storage; limits new fossil builds

 

As if California doesn’t have enough problems with its electric service, now state regulators warn the state may be short on power supplies by 2021 if utilities don’t start lining up new resources now.

In the hopes of heading off a shortfall as America goes electric, the California Public Utilities Commission has ordered the state’s electricity providers to secure 3.3 additional gigawatts of reserve supplies. That’s enough to power roughly 2.5 million homes. Half of it must be in place by 2021 and the rest by August 2023.

The move comes as California is already struggling to accommodate increasingly large amounts of solar power that regularly send electricity prices plunging below zero and force other generators offline so the region’s grid doesn’t overload. The state is also still reeling from a series of deliberate mass blackouts that utilities imposed last month to keep their power lines from sparking wildfires amid strong winds. And its largest power company, PG&E Corp., went bankrupt in January.

Now as natural gas-fired power plants retire under the state’s climate policies, officials are warning the state could run short on electricity on hot evenings, when solar production fades and commuters get home and crank up their air conditioners. “We have fewer resources that can be quickly turned on that can meet those peaks,” utilities commission member Liane Randolph said Thursday before the panel approved the order to beef up reserves.

The 3.3 gigawatts that utilities must line up is in addition to a state rule requiring them to sign contracts for 15% more electricity than they expect to need. Some critics question the need for added supplies, particularly after the state went on a plant-building boom in the 2000s.

But California’s grid managers say the risk of a shortfall is real and could be as high as 4.7 gigawatts, especially during heat waves that test the grid again. Mark Rothleder, with the California Independent System Operator, said the 15% cushion is a holdover from the days before big solar and wind farms made the grid more volatile. Now it may need to be increased, he said.

“We’re not in that world anymore,” said Rothleder, the operator’s vice president of state regulatory affairs. “The complexity of the system and the resources we have now are much different.”

The state’s three major utilities, PG&E, Edison International and Sempra Energy, will be largely responsible for securing new supplies. The commission banned fossil fuels from being used at any new power generators built to meet the requirement — though it left the door open for expansions at existing ones.

Some analysts argue California is exporting its energy policies to Western states, making electricity more costly and less reliable.

PG&E said in an emailed statement that it was pleased the commission didn’t adopt an earlier proposal to require 4 gigawatts of additional resources. Edison similarly said it was “supportive.” Sempra didn’t immediately respond with comment.

 

Extending Deadlines

The pending plant closures are being hastened by a 2020 deadline requiring California’s coastal generators to stop using aging seawater-cooling systems. Some gas-fired power plants have said they’ll simply close instead of installing costly new cooling systems. So the commission on Thursday also asked California water regulators to extend the deadline for five plants.

The Sierra Club, meanwhile, called on regulators to turn away from fossil fuels altogether, saying their decision Thursday “sets California back on its progress toward a clean energy future.”

The move to push back the deadline also faces opposition from neighboring towns. Redondo Beach Mayor Bill Brand, whose city is home to one of the plants in line for an extension, told the commission it wasn’t necessary, since California utilities already have plenty of electricity reserves.

“It’s just piling on to that reserve margin,” Brand said.

 

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U.S. Electric Vehicle Market Share Dips in Q1 2024

U.S. EV Market Share Dip Q1 2024 reflects slower BEV adoption, rising PHEV demand, affordability concerns, charging infrastructure gaps, tax credit shifts, range anxiety, and automaker strategy adjustments across the electric vehicle market.

 

Key Points

Q1 2024 EV and hybrid share slipped as BEV sales lag, PHEVs rise, and affordability and charging concerns temper demand.

✅ BEV share fell to 7.0% as affordable models remain limited

✅ PHEV sales rose 50% YoY, easing range anxiety concerns

✅ Policy shifts and charging gaps weigh on consumer adoption

 

The U.S. electric vehicle (EV) market, once a beacon of unbridled growth, appears to be experiencing a course correction. Data from the U.S. Energy Information Administration (EIA) reveals that the combined market share of electric vehicles (battery electric vehicles, or BEVs) and hybrids dipped slightly in the first quarter of 2024, marking the first decline since the onset of the COVID-19 pandemic, even as EU EV share rose during lockdowns in 2020.

This news comes as a surprise to many analysts who predicted continued exponential growth for the EV market. While overall sales of electric vehicles surged into 2024 and did increase by 7% compared to Q1 2023, this growth wasn't enough to keep pace with the overall rise in vehicle sales. The result: a decline in market share from 18.8% in Q4 2023 to 18.0% in Q1 2024.

Several factors may be contributing to this shift. One potential culprit is a slowdown in battery electric vehicle sales. BEVs saw their share of the market dip from 8.1% to 7.0% in the same period. This could be attributed to a lack of readily available affordable options, with many popular EV models still commanding premium prices and concerns that EV supply may miss demand in the near term.

Another factor could be the rising interest in plug-in hybrid electric vehicles (PHEVs). PHEV sales witnessed a significant jump of 50% year-over-year, reflecting how gas-electric hybrids are getting a boost from major automakers, potentially indicating a consumer preference for vehicles that offer both electric and gasoline powertrain options, addressing concerns about range anxiety often associated with BEVs.

Industry experts offer mixed interpretations of this data. Some downplay the significance of the dip, attributing it to a temporary blip, even though EVs remain behind gas cars in total sales. They point to the ongoing commitment from major automakers to invest in EV production and the potential for new, more affordable models to hit the market soon.

Others express more concern, citing Europe's recent EV slump and suggesting this might be a sign of maturing consumer preferences. They argue that simply increasing the number of EVs on the market might not be enough. Automakers need to address issues like affordability, charging infrastructure, and range anxiety to maintain momentum.

The role of government incentives also remains a question mark. The federal tax credit for electric vehicles is currently set to phase out gradually, potentially impacting consumer purchasing decisions in the future. Continued government support, through incentives or infrastructure development, could be crucial in maintaining consumer interest.

The coming quarters will be crucial in determining the long-term trajectory of the U.S. EV market, especially after the global electric car market's rapid expansion in recent years. Whether this is a temporary setback or a more lasting trend remains to be seen. Addressing consumer concerns, ensuring a diverse range of affordable EV options, and continued government support will all be essential in ensuring the continued growth of this critical sector.

This development also presents an opportunity for traditional automakers. By capitalizing on the growing PHEV market and addressing consumer concerns about affordability and range anxiety, they can carve out a strong position in the evolving automotive landscape.

 

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Trump unveils landmark rewrite of NEPA rules

Trump NEPA Overhaul streamlines environmental reviews, tightening 'reasonably foreseeable' effects, curbing cumulative impacts, codifying CEQ greenhouse gas guidance, expediting permits for pipelines, highways, and wind projects with two-year EIS limits and one lead agency.

 

Key Points

Trump NEPA Overhaul streamlines reviews, trims cumulative impacts, keeps GHG analysis for foreseeable effects.

✅ Limits cumulative and indirect impacts; emphasizes foreseeable effects

✅ Caps EIS at two years; one-year environmental assessments

✅ One lead agency; narrower NEPA triggers for low federal funding

 

President Trump has announced plans for overhauling rules surrounding the nation’s bedrock environmental law, and administration officials refuted claims they were downplaying greenhouse gas emissions, as the administration also pursues replacement power plant rules in related areas.

The president, during remarks at the White House with supporters and Cabinet officials, said he wanted to fix the nation’s “regulatory nightmare” through new guidelines for implementing the National Environmental Policy Act.

“America is a nation of builders,” he said. But it takes too long to get a permit, and that’s “big government at its absolute worst.”

The president said, “We’re maintaining America’s world-class standards of environmental protection.” He added, “We’re going to have very strong regulation, but it’s going to go very quickly.”

NEPA says the federal government must consider alternatives to major projects like oil pipelines, highways and bridges that could inflict environmental harm. The law also gives communities input.

The Council on Environmental Quality has not updated the implementing rules in decades, and both energy companies and environmentalists want them reworked, even as some industry groups warned against rushing electricity pricing changes under related policy debates.

But they patently disagree on how to change the rules.

A central fight surrounds whether the government considers climate change concerns when analyzing a project.

Environmentalists want agencies to look more at “cumulative” or “indirect” impacts of projects. The Trump plan shuts the door on that.

“Analysis of cumulative effects is not required,” the plan states, adding that CEQ “proposes to make amendments to simplify the definition of effects by consolidating the definition into a single paragraph.”

CEQ Chairwoman Mary Neumayr told reporters during a conference call that definitions in the current rules were the “subject of confusion.”

The proposed changes, she said, do in fact eliminate the terms “cumulative” and “indirect,” in favor of more simplified language.

Effects must be “reasonably foreseeable” and require a “reasonably close causal relationship” to the proposed action, she added. “It does not exclude considerations of greenhouse gas emissions,” she said, pointing to parallel EPA proposals for new pollution limits on coal and gas power plants as context.

Last summer, CEQ issued proposed guidance on greenhouse gas reviews in project permitting. The nonbinding document gave agencies broad authority when considering emissions (Greenwire, June 21, 2019).

Environmentalists scoffed and said the proposed guidance failed to incorporate the latest climate science and look at how projects could be more resilient in the face of severe weather and sea-level rise.

The proposed NEPA rules released today include provisions to codify the proposed guidance, which has also been years in the making.

Other provisions

Senior administration officials sought to downplay the effect of the proposed NEPA rules by noting the underlying statute will remain the same.

“If it required NEPA yesterday, it will require NEPA under the new proposal,” an official said when asked how the changes might apply to pipelines like Keystone XL.

And yet the proposed changes could alter the “threshold consideration” that triggers NEPA review. The proposal would exclude projects with minimal federal funding or “participation.”

The Trump plan also proposes restricting an environmental impact statement to two years and an environmental assessment to one.

Neumayr said the average EIS takes 4 ½ years and in some cases longer. Democrats have disputed those timelines. Further, just 1% of all federal actions require an EIS, they argue.

The proposal would also require one agency to take the lead on permitting and require agency officials to “timely resolve disputes that may result in delays.”

In general, the plan calls for environmental documents to be “concise” and “serve their purpose of informing decision makers.”

Both Interior Secretary David Bernhardt and EPA Administrator Andrew Wheeler, whose agency moved to rewrite coal power plant wastewater limits in separate actions, were at the White House for the announcement.

Reaction

An onslaught of critics have said changes to NEPA rules could be the administration’s most far-reaching environmental rollback, and state attorneys general have mounted a legal challenge to related energy actions as well.

The League of Conservation Voters declared the administration was again trying to “sell out the health and well-being of our children and families to corporate polluters.”

On Capitol Hill, House Speaker Nancy Pelosi (D-Calif.) said during a news conference the administration would “no longer enforce NEPA.”

“This means more polluters will be right there, next to the water supply of our children,” she said. “That’s a public health issue. Their denial of climate, they are going to not use the climate issue as anything to do with environmental decisionmaking.”

Sen. Sheldon Whitehouse (D-R.I.) echoed the sentiment, saying he didn’t need any more proof that the fossil fuel industry had hardwired the Trump administration “but we got it anyway.”

Energy companies, including firms focused on renewable energy development, are welcoming the “clarity” of the proposed NEPA rules, even as debates continue over a clean electricity standard in federal climate policy.

“The lack of clarity in the existing NEPA regulations has led courts to fill the gaps, spurring costly litigation across the sector, and has led to unclear expectations, which has caused significant and unnecessary delays for infrastructure projects across the country,” the Interstate Natural Gas Association of America said in a statement.

Last night, the American Wind Energy Association said NEPA rules have caused “unreasonable and unnecessary costs and long project delays” for land-based and offshore wind energy and transmission development.

Trump has famously attacked the wind energy industry for decades, dating back to his opposition to a Scottish wind turbine near his golf course.

The president today said he won’t stop until “gleaming new infrastructure has made America the envy of the world again.”

When asked whether he thought climate change was a “hoax,” as he once tweeted, he said no. “Nothing’s a hoax about that,” he said.

The president said there’s a book about climate he’s planning to read. He said, “It’s a very serious subject.”

 

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