Selected category: Setting the Facts Straight

New Analysis: Clean Power Plan Compliance Within Reach for Litigating Companies

rp_scales_of_justice-300x280-300x280.png (EDF Attorneys Tomás Carbonell and Martha Roberts co-authored this post)

Tomorrow – Tuesday, September 27th – the U.S. Court of Appeals for the D.C. Circuit will hear argument about the historic Clean Power Plan.

The Clean Power Plan places the nation’s first limits on climate-disrupting pollution from the electricity sector, which is responsible for almost 40 percent of U.S. emissions of carbon dioxide.

Many utilities, power producers, and state regulators recognize the importance of addressing climate change – and support the Clean Power Plan. However, some in the electric industry have instead chosen to take a reactionary, obstructionist position against climate progress. They are participating in litigation against the Clean Power Plan. A wide array of prominent legal experts have concluded that these companies’ legal arguments are unsupported. Moreover, in many cases, opponents’ claims are even contrary to their own actions. (See Opening Brief of Petitioners on Procedural and Record-Based Issues, page 12, West Virginia v. EPA, No. 15-1363, D.C. Cir. Apr. 22, 2016)

EDF has just released a new analysis of this issue. It examines a diverse selection of power companies that are litigating against the Clean Power Plan, including Southern Company, American Electric Power, Big Rivers Electric Corporation, and Tri-State Generation & Transmission.

We find that:

  • Overall, power sector emissions of climate pollution are already 21 percent below 2005 levels. As a result, the sector is already two-thirds of the way towards meeting the 2030 emissions reduction requirements of the Clean Power Plan.
  • Even though these particular companies are opposing the Clean Power Plan in court, they are already using a variety of approaches to drive significant cost-effective reductions in climate pollution from their existing fossil-fuel powered units, thanks in large part to favorable economics for lower and zero-carbon generation.
  • These are the same practical, cost-effective methods that EPA identified as the “best system” of emission reduction for climate pollution from power plants, and that formed the basis for the emission limits in the Clean Power Plan.
  • With these investment decisions, power companies are well positioned to comply with the Clean Power Plan, even though they are making claims to the contrary in court.
  • These companies’ own actions affirm the reasonableness of the Clean Power Plan targets as well as EPA’s approach in setting the standard, even though the companies are repeatedly claiming otherwise in court.

This is not the first time some of these companies have advanced deeply flawed “sky is falling” claims about clean air safeguards. Back in the 1970’s, AEP published a series of Washington Post newspaper ads claiming:

There is no way on God’s green earth that the present sulfur-dioxide emissions standards can be met. (Washington Post, April 30, 1974, AEP Display Ad 13)

Not surprisingly, coal plants across the nation are routinely meeting sulfur dioxide limits far more stringent and at very low cost.

This was also true in 1990, when AEP told the Boston Globe that bipartisan solutions to address acid rain could lead to:

the potential destruction of the Midwest economy.

Of course, they then proceeded, along with the rest of the industry, to go out and comply at a small fraction of the costs predicted by EPA. This same story is playing out again today.

The Clean Air Act has achieved deep reductions in pollution and delivered benefits exceeding the costs by 30 to 1 – all while our economy has prospered, and all at a small fraction of the costs predicted by obstructionists in the power industry.

The Clean Power Plan is no different. As our analysis shows, day by day it becomes clearer that the reductions it requires are wholly consistent with driving trends in the industry, and that the benefits will far exceed any cost of compliance.

The full analysis is available here.

Also posted in Clean Air Act, Clean Power Plan, Economics, EPA litgation, Greenhouse Gas Emissions, Policy| Comments are closed

Climate denial has no place in the court

(This post was co-written by EDF’s Martha Roberts and Ilissa Ocko)

As federal courts consider the legal merits of the U.S. Environmental Protection Agency’s (EPA) Clean Power Plan — America’s first-ever national limits on carbon pollution from power plants – we find ourselves in a situation that might have felt familiar to Galileo, who was hauled before authorities for having the temerity to make conclusions based on science.

Three hundred seventy-four years after Galileo, flat-earth Clean Power Plan opponents are using the court’s time to challenge EPA’s rock solid conclusions about the scientific realities of climate change. They’re using misinformation and misrepresentation in an attempt to block EPA’s flexible and efficient approach to reducing the carbon pollution that is causing so much costly damage to our society.

Yes, they’re still doing that in 2016.

The Usual Suspects

The latest assault takes the form of an amicus, or “friend of the court,” brief that was submitted last week to the U.S. Court of Appeals for the D.C. Circuit. It deploys selective reasoning and misleading arguments in an attempt to discredit evidence of climate change.

It’s numbingly familiar, but not surprising, to see Fred Singer’s name on the brief. A former tobacco industry mouthpiece, he’s been a mainstay for years in what’s been called the “parallel universe” of climate denial conferences.

It’s also no surprise that Peabody Energy — the world’s largest privately owned coal company — contested EPA’s rock solid climate science in an earlier submission to the court, given the company’s history of obfuscating the impacts of climate change in order to protect its profits.

The Real Motivation

This effort isn’t about debating science. It’s about using misinformation to obstruct climate progress. This attack is part of a longstanding effort to undermine EPA’s common sense solutions to limit harmful greenhouse gas pollution at all – despite that fact that the Supreme Court has repeatedly ruled that the Clean Air Act requires EPA to address climate pollution. Coal companies and their hired allies have relentlessly attacked EPA’s safeguards to protect human health and the environment from climate pollution.

Junk Science Amicus Brief

This junk science submission, authored by Singer and others, claims to be based on “real world empirical temperature data” (amicus brief, page 15) – but in truth it’s deceptively unscientific, cherry-picking dates and locations in an effort to rebut overwhelming evidence of rising surface temperatures.

Two obvious flaws demonstrate the problematic reasoning employed by the brief.

First, the authors contend that globally averaged surface temperature has not increased because:

The decade of the 1930s still has the most currently held high-temperature records for States within the United States. (amicus brief, page 31)

This point suffers from cherry picking data that seems to support their phony argument. Drawing a comparison between a long term globally averaged temperature trend (i.e., as related to anthropogenic climate change) and summertime regional temperature spikes in a select portion of the U.S. is inherently misleading (see Figure 1 below). The U.S. covers only two percent of the global surface area, and the Great Plains far less. Arguing that a small regional temperature anomaly undermines for the global temperature trend is scientifically untenable.

Figure 1: How Cherry-Picked Data Misrepresents the Larger Picture

Source: The U.S. Global Historical Climatology Network Dataset

Source: The U.S. Global Historical Climatology Network Dataset

The second flaw is an egregious error with respect to defining a linear trend. The authors break the temperature time series in half and display two distinct trend lines separated by a large step increase, as opposed to the scientifically appropriate approach of employing the entire time series to define a trend.

Figure 2. The Amicus Brief’s Broken Time Trend Global Average Temperature Anomalies

(amicus brief, page 7)

They do this to hide the trend. It’s a classic strategy used by the climate denial community to deny trends, known as the “escalator” (see Figure 3 below).

The authors argue that the absence of a trend in the latter portion of the record indicates a lack of evidence for an anthropogenic climate change signal during this time. However, their starting point for the latter half is during the 1997-1998 El Nino, one of the strongest such events on record. Given that El Nino has a significant warming influence on a given year’s global temperature, starting at this point in the record introduces a strong temperature bias — i.e. the authors purposely choose a starting point with an extremely high temperature in order to create the appearance of a plateau in the years that follow.

It’s a bit like beginning a chart of Barry Bonds’ home runs per season in 2001, when he hit 73. The authors fail to disclose that the globally averaged temperature exceeded the 1990’s average in every year of the first decade of the 21st century and that both 2014 and 2015 broke records as the hottest years ever recorded — further confirming their selection bias.

Figure 3: The Escalator — An Example of How One Can Manipulate a Trendline to Pretend That There Is No Trend

 escalator graphic


The brief also attempts to reject EPA’s conclusion that the atmosphere in the tropics warms faster than the surface as a response to rising carbon dioxide levels.

The brief presents data from only a single location in an attempt to rebut this conclusion — the tropical central and eastern Pacific Ocean, an area home to the El Nino Southern Oscillation (ENSO), the largest mode of natural interannual climate variability on the planet.

Using only one region (and in this case a single idiosyncratic point) to represent the entire global tropics is highly misleading and scientifically inappropriate. The data manifestly suffer from selection bias and are not representative of the full population of tropical climate data.

Indeed, the temperature time series shown in their analysis correlate extremely well with recently observed El Nino and La Nina events — suggesting that their index is simply a proxy for the El Nino/La Nina signal. Extracting a trend from an area with extremely large natural variability is inherently tenuous, because the large background variability swamps our ability to observe any other data trends.

Unfortunately, this is not the first time opponents have inaccurately distorted climate data in this case.

Earlier in this same crucial case, Peabody represented to the court that EPA’s claims of climate harms "substantially outrun the available evidence." (brief, page 7 footnotes)

Peabody’s efforts to justify these misleading allegations misrepresent scientific understanding of climate science in several major respects. Two core inconsistencies, among several, include:

  • Peabody’s biased assertion of hiatus in warming since 1998 — as mentioned earlier, beginning a trendline in 1998, an exceptionally warm year due to an unusually strong El Nino, is nonsensical and irrelevant to the long-term trend. Further, surface air temperatures are certainly still increasing. The 2000s were warmer than the 1990s, 2015 smashed all previous surface air temperature records, and heat uptake in the ocean has doubled over the last 20 years.
  • Flawed reasoning that increasing Antarctic sea ice disproves climate change — Antarctic sea ice is influenced by differences in fresh water supply and circulation in the Southern Ocean. Land ice that has taken thousands of years to accumulate in Antarctica is melting at a rapid rate due to warmer temperatures, changing the chemistry of the water and likely preventing the buildup of sea ice. Peabody’s submission ignored and omitted this crucial context.

Sadly, it’s not really news that Peabody is presenting misleading climate information. Peabody, the largest private-sector coal company in the world, was cited last fall by the New York Attorney General for violating investor protection laws by misrepresenting climate risk in its corporate filings. The Attorney General noted that Peabody “repeatedly denied in public financial filings to the Securities and Exchange Commission that it had the ability to predict the impact that potential regulation of climate change pollution would have on its business, even though Peabody and its consultants actually made projections that such regulation would have severe impacts on the company.”

Also posted in Basic Science of Global Warming, Clean Air Act, Clean Power Plan, EPA litgation, Policy, Science| Comments are closed

Polluters are Making the Same Old “Sky is Falling” Claims about the Clean Power Plan

The ink wasn’t even dry on the Clean Power Plan before some power companies filed lawsuits to challenge these historic public health protections.

One of their key complaints? How much the Clean Power Plan is allegedly going to cost.

In their court filing, these companies claimed that they’ll potentially need to spend “billions of dollars” to comply.

Click to expand infographic

This tactic is nothing new, and it’s something we often hear when the U.S. Environmental Protection Agency (EPA) issues a new regulation that will provide cleaner, healthier air for our communities and families.

But it’s almost always wrong.

In defiance of the “sky is falling” predictions, American industry innovates and figures out ways to comply with new, healthier standards at a fraction of the costs initially projected.

This is exactly what occurred with EPA’s life-saving Mercury and Air Toxics Standards, which are providing crucial reductions of toxic air pollutants including mercury, hydrochloric acid and arsenic from our nation’s power plants.

After EPA proposed the Mercury and Air Toxics Standards in 2011, FirstEnergy told its investors that it expected to spend between $2 billion and $3 billion dollars to comply with the clean air standards.

A little later that same year, FirstEnergy cut its estimate roughly in half — to between $1.3 billion and $1.7 billion.

Fast forward to February 2015 (just two months before the initial deadline to comply with the Mercury and Air Toxics Standards), and FirstEnergy announced that it would spend $370 million on compliance.

In other words, its highest initial cost estimate was more than eight times higher than its actual costs.

Similarly, AEP’s highest initial cost estimate for compliance with the Mercury and Air Toxics Standards was as much as two times higher than its later assessment of actual compliance costs.

These two companies are just a few of the power companies that have decreased their cost estimates for complying with the Mercury and Air Toxics Standards, and other public health and environmental standards, in recent years.

The tens of billions of dollars in expected health benefits from the Mercury and Air Toxics Standards has not decreased, though.

It will save thousands of lives every year, prevent heart attacks and asthma attacks, and help protect the hundreds of thousands of babies born in America every year who are exposed to unsafe levels of mercury in the womb.

It’s important that we keep in mind these misguided “sky is falling” claims about environmental compliance costs as EPA carries out its responsibilities under the nation’s clean air laws to address climate pollution from power plants.

The time tested history of the Clean Air Act is quite the opposite of the “sky is falling” – the sky is clearing, and at far less than the costs predicted by industry.

Also posted in Clean Power Plan, Energy, Greenhouse Gas Emissions, Policy| Comments are closed

4 undeniable signs we're making progress on climate change

Seven months ago, I made a strong statement that may have left some people shaking their heads. I said that we can turn the corner on climate change – end the centuries-long rise in greenhouse gas emissions and see them peak and begin to decline – in just five short years.

As it turns out, 2015 is shaping up to be a year of giant steps toward that goal.

In a deeply reported New York Magazine piece, political writer Jonathan Chait calls it “the year humans finally got serious about saving themselves.” Says Chait, “The world is suddenly responding to the climate emergency with – by the standards of its previous behavior – astonishing speed.”

I agree. Here are four reasons I believe we’re headed in the right direction:

1. America is tackling greenhouse gas pollution

The United States remains among the world’s largest per-capita emitters of carbon dioxide and other heat-trapping pollutants. But thanks to this year’s action by the Environmental Protection Agency, America now has a Clean Power Plan that will cut emissions from power plants, our single largest source of carbon, by 32 percent over the next 15 years.

The era of unlimited climate pollution is over.

On the heels of the EPA’s Clean Power Plan came a proposed rule to cut methane from newly built facilities in the oil and gas industry. More needs to be done, but this is an important step in dealing with a potent greenhouse gas that accounts for 25 percent of Earth’s current warming.

These climate laws will help the U.S. meet our target to reduce emissions by 26-28 percent below 2005 levels by 2025, a commitment we made to the international community that is key to getting other large polluters to do their share.

We’ll need further reductions, but this is a very significant start.

2. China is building momentum for global action

The world’s No. 1 greenhouse gas emitter, China submitted its climate plan to the United Nations in June, confirming it will let emissions peak by 2030 – and possibly sooner. I know from my colleague Dan Dudek in China that “sooner” is possible because this is a country that’s serious about climate action.

Pollution is choking Chinese cities and threatening economic growth, but the country’s leaders also see opportunity in the emerging clean energy industry. China has pledged to have 20 percent of its energy come from wind, solar and other non-fossil energy sources within 15 years – a massive investment in a nation of 1.4 billion.

This year alone, China is expected to add 18 gigawatts of new solar capacity. By comparison, the U.S. recently surpassed 20 gigawatts total.

To have China and the U.S. making such significant commitments has transformed the dynamic going into the U.N. climate summit in Paris. Instead of making excuses for inaction, the leading emitters have launched a virtuous cycle of increasing ambition.

That changes everything.

3. Clean energy is lifting people out of poverty

One billion people worldwide still have no energy, and more than 1 billion live in extreme poverty. Turning the corner on climate cannot mean that economies can’t develop.

But just as some developing economies adopted cellular technology without ever having land lines, some will leap-frog the dirty energy phase of economic development and go straight to clean.

In fiscal 2014, the World Bank more than doubled lending for renewable energy projects to nearly $3.6 billion – or 38 percent of its total energy lending.

As Rachel Kyte, the bank’s vice president and special envoy for climate change, recently said, what poverty-stricken people of the world need now is a “a low-carbon revolution.”

And this is starting to happen. In 2014, the emerging economies of China, India, Brazil and South Africa invested $131 billion in clean energy, just 6 percent less than the developed world did.

4. Pope Francis is galvanizing world opinion 

When Pope Francis released his much-anticipated encyclical on environmental stewardship in June, he made an urgent moral appeal to the world.

As my colleague Paul Stinson noted at the time, “A leading voice without political boundaries, the pope has the ability to reach people who previously could not or would not face the reality of climate change.”

Pope Francis called on us to push harder to replace fossil fuel with renewable energy sources – and people are listening.

The day he speaks to Congress later this month, a climate rally is expected to draw many thousands to the nation’s capital in a unified call for action. Environmental Defense Fund will be there, too.

The momentum is growing. We’re on our way to turn the corner on climate change – and the race of our lives is on.

This post originally appeared on our EDF Voices blog.

Also posted in Clean Air Act, Clean Power Plan, Energy, Greenhouse Gas Emissions, International, Policy, Science| Comments are closed

Pope Francis and climate change: Thoughts from a Catholic environmentalist

Source: Flickr/Catholic Church

It’s not often that my Catholic faith intersects with my work communicating about international climate change issues.

That’s changed now that Pope Francis is expected to release a statement of official church teaching this summer on the environment and climate change. It’s making headlines again this week, as the pope convenes a summit on climate change.

Known as an encyclical, it’s expected to reflect on Catholic teaching as it applies to the world today, and focus on the moral obligation to protect creation and humankind – especially the world’s most vulnerable people.

That Pope Francis – dubbed the “rock star pope” – will make such a statement on environmental protection is not surprising to those familiar with his and the Catholic Church’s position on the environment, the latter of which has long taught the importance of humans taking care of the Earth.

Caring for Earth part of our faith

The encyclical will formally be on “ecology,” with climate change playing a central role.

Climate touches everything, including people. Pollution that causes global warming also triggers asthma. Warmer temperatures mean crops and people’s livelihoods are jeopardized, while diseases such as West Nile and Lyme disease spread. Sea-level rise means people lose their homes.

These effects can still make climate change seem unrelated to the faith, far in the future and overwhelming. But Pope Francis is calling on us to see that it’s none of those.

Similarly, when I taught Sunday school to young children, we didn’t address the complexities of Catholic theology. We focused on Catholics’ belief that God provided humans with nature and its animals, trees and air for us to enjoy and protect.

The poor feel brunt of climate change

As an environmentalist, I’ve helped bring attention to my Environmental Defense Fund colleagues’ work with people who are feeling the impact of climate change first-hand.

In Brazil, the country with the world’s largest Catholic community, indigenous groups are already experiencing changes in the Amazon’s rainfall and river levels, fire patterns and climate systems they used to depend on for growing crops. And in India, farmers and rural women are already experiencing weather events consistent with a changing climate.

We know there are solutions to climate change. The United States and the world made important advances on climate and energy in the past year, and we believe we can stop the rise in greenhouse gas emissions and see them begin to decline in thenext five years.

Timing of pope’s document critical

The encyclical is a call to action for all of us to read the document and think more deeply about our relationship with the world. It asks us to consider what we can do – personally, in our community and parish, at the state and national level, and internationally.

The release of the encyclical comes in advance of international climate negotiations in Paris this December, where countries will seek to build an international agreement to reduce greenhouse gas emissions that cause climate change.

By staking out the Vatican’s position on climate change, the pope is telling the world that protecting the environment is not a niche issue – it’s a human, personal and moral issue.

This post originally appeared on our EDF Voices blog.

Also posted in Partners for Change, Policy, What Others are Saying| Comments are closed

NERC's Report is Flawed: We Can Reduce Climate Pollution and Ensure Electric Reliability

power-poles-503935_1920If reducing climate pollution from power plants were a football game, the U.S. team would be halfway to the goal line while fans were still singing the national anthem.

That is, we have already gotten about halfway to the expected goals of the Clean Power Plan – before the rule is even final.

The Clean Power Plan is the U.S. Environmental Protection Agency’s (EPA) historic effort to place the first-ever limits on climate pollution from our country’s existing fleet of fossil fuel-fired power plants. When it’s finalized this summer, it’s expected to call for a 30 percent reduction in carbon emissions compared to 2005 levels — but U.S. power plant emissions have already fallen 15 percent compared to 2005 levels.

That’s because renewable energy, energy efficiency resources, and natural gas generation have been steadily deployed and growing for years. Even conservative estimates forecast continued growth of these resources — which makes last week’s report from the North American Electric Reliability Corporation (NERC) seem really strange.

NERC’s report about the Clean Power Plan’s impacts on electric grid reliability makes predictions that starkly contrast from the progress we’re already seeing.

How did this departure from reality happen?

It’s due in large part to severely flawed assumptions underlying NERC’s analysis, which yield unrealistic results.

Those flawed assumptions cause NERC to greatly overstate the generation mix changes required to meet the Clean Power Plan. The NERC Assessment’s assumptions regarding energy efficiency, renewable energy deployment, and retirement modeling are at odds with both recent experience and current trends.

Unrealistically Low Energy Efficiency Gains

NERC assumes that demand for electricity will grow at an average of one percent per year through 2030, even after accounting for growth in energy efficiency investments. That growth rate is more than 40 percent higher than the U.S. Energy Information Administration (EIA) predicts.

It also fails to reflect likely energy efficiency growth. An analysis by McKinsey & Company found that implementing only those efficiency measures that pay for themselves would reduce the nation’s total end-use energy consumption by 23 percent by 2020.

Arbitrary and Unrealistic Projections on Wind and Solar Expansion  

NERC predicts expansions of wind and solar power that are far below those observed in recent years.

U.S. solar capacity stood at 20.5 gigawatts at the end of 2014. The NERC Assessment predicts an addition of 13 to 20 gigawatts of solar energy between 2016 and 2030 — when solar capacity is expected to grow by 20 gigawatts over the next two years alone.

The U.S. wind industry is also expected to add 18 gigawatts of new capacity in the next two years.

NERC’s low-ball assumptions greatly limit renewable energy deployment in their study. This in turn greatly increases the burden on other compliance options, namely coal-to-gas generation shifting.

Failure to Account for Dynamic Grid Reliability Management Tools

NERC assumes that the Clean Power Plan will drive coal power plant retirements over its entire life-span. However, numerous studies — including one by the Brattle Group and three by the Analysis Group, show that total output and emissions from coal units can decrease without retiring units that are needed to operate on occasion in order to maintain electric reliability.

There are also numerous tools and processes available to grid operators to ensure reliability in light of dynamic market, technological and regulatory change, including capacity and energy markets, resource adequacy forecasting, and reliability must-run contracts.

These instruments, for example, have worked well to maintain adequate capacity during the recent wave of coal-fired power plant retirements, so much so that the electric grid has added an average of roughly 30 gigawatts of total power every year since 2000. The NERC Assessment, however, finds only 11 to12 gigawatts of total power will be added every year – a significant departure from the past 15 years of evidence.

A History of Inaccurate Assessments

This report is not the first time that NERC has issued an inaccurate assessment of threats to reliability.

NERC has assessed previous public health and environmental safeguards, each time raising reliability concerns that were not borne out in reality.

  • In 2011, NERC issued its Long-Term Reliability Assessment, which looked at the Mercury and Air Toxics Standards, the Cross State Air Pollution Rule, the Clean Water Act Cooling Water Intake Structures rule, and the Coal Combustion Residuals rule. NERC raised numerous reliability concerns about these protections, which the EPA noted at the time were flawed and exaggerated. None of NERC’s concerns have manifested during implementation of these standards.
  • In a 2011 companion study, NERC issued its Potential Impacts of Future Environmental Regulations about the Mercury and Air Toxics Standards and a number of other regulations. NERC again raised reliability concerns, none of which have occurred in practice.
  • In its 2007 Long-Term Reliability Assessment, NERC predicted several regions, including New England and New York State, would drop below target capacity margins, threatening reliability. NERC’s prediction was based on a number of factors, including proposed environmental protections. Some power generators used the report to oppose to the Regional Greenhouse Gas Initiative. NERC’s predicted reliability shortfalls did not occur, nor has the Regional Greenhouse Gas Initiative caused reliability issues – even while emissions fell almost 50 percent below the region-wide emissions cap.
  • In 2000, NERC drafted a review of EPA’s nitrogen oxide emissions standards for eastern power plants, knows as the NOx SIP Call. Yet again, NERC predicted a number of reliability concerns that did not occur after the rule was implemented.

NERC has repeatedly produced analyses indicating that public health and environmental safeguards will come at the expense of electric reliability – and these analyses have consistently been contradicted by reality. In fact, emission standards have never caused a reliability problem in the more than four decades that EPA has been administering the Clean Air Act.

NERC’s newest report is no better. It gives no solid reasons to doubt that the Clean Power Plan will be compatible with a reliable electric grid.  

For a clearer picture of the link between reliability and environmental protections, read this post by my colleague Cheryl Roberto, a former Commissioner of the Ohio Public Utilities Commission and electric system operator.

You might also like EDF’s fact sheet about the Clean Power Plan and the latest flawed NERC report.

The progress made in the past demonstrates that our nation is already approaching the goal line under the Clean Power Plan. The tremendous flexibility that the Clean Power Plan provides to states and power companies alike, together with time-tested grid management tools, provides the framework we need to reach the goal line — protecting our communities and families from dangerous carbon pollution, strengthening our economy, and providing a steady flow of cost-effective electricity.

Also posted in Clean Air Act, Clean Power Plan, Energy, Policy| Comments are closed
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