Climate 411

A New Step in the Fight to Reduce Toxic Mercury Pollution from Power Plants

By Graham McCahan / Published: October 15, 2014

(This post was written by EDF Senior Attorneys Graham McCahan and Tomas Carbonell)

Today, EDF and its allies joined the latest fight to protect the Environmental Protection Agency’s (EPA) Mercury and Air Toxics Standards.

We filed a brief asking the Supreme Court to deny the petitions that are seeking review of a lower court decision upholding the standards.

The Mercury and Air Toxics Standards (MATS) will require crucial and long-overdue emission reductions of toxic pollutants including mercury, arsenic, and acid gases from the single largest source of toxic air pollution in the U.S.— coal-fired power plants.

Starting in April 2015, when they go into effect, these standards will prevent thousands of premature deaths, heart attacks, and asthma attacks every year.

The Mercury and Air Toxics Standards were upheld by a panel of judges on the D.C. Circuit Court of Appeals in April 2014 against a variety of legal challenges.

Fortunately, most power plants in the U.S. are already on track to comply with these life-saving standards.

The U.S. Energy Information Administration reported that by the end of 2012 — or more than two years ahead of the April 2015 compliance deadline:

64.3% of the U.S. coal generating capacity in the electric power sector already had the appropriate environmental control equipment to comply with the MATS.

Unfortunately, some power companies and their industry partners continue to file legal attacks against the Mercury and Air Toxics Standards.

Our opponents are continuing their legal attacks in spite of the D.C. Circuit’s detailed opinion strongly upholding EPA’s authority to issue the Mercury and Air Toxics Standards and affirming the EPA’s well-reasoned determinations on key technical issues.

Industry interests and states have filed petitions asking the U.S. Supreme Court to review the D.C. Circuit’s decision.  Their petitions primarily emphasize the alleged costs of the Mercury and Air Toxics Standards — even though some of the same power companies have recognized that the standards include flexibilities that have helped them slash their compliance costs.

For instance, Southern Company CFO and Executive Vice President Arthur P. Beattie stated in 2012 that the amount the company projects for MATS compliance costs would be far lower than previously predicted:

[B]ecause of the new flexibility that [the company has] found in the final rules of the MATS regulation.” (Arthur P. Beatty, CFO and Executive Vice President of Southern Company,  Deutsche Bank Clean Tech, Utilities and Power Conference, May 15, 2012)

In fact, as the D.C. Circuit recognized in its decision, EPA’s cost-benefit analysis found that the Mercury and Air Toxics Standards would yield as much as $90 billion in annual health benefits once implemented — approximately nine times the anticipated cost of the rule.

The good news is that many people and organizations— including public health, equal justice, and environmental groups, plus a number of states and cities — are standing together to safeguard these protections for our communities and families.

Those groups include the American Academy of Pediatrics, American Lung Association, American Nurses Association, American Public Health Association, Chesapeake Bay Foundation, Citizens for Pennsylvania’s Future, Clean Air Council, Conservation Law Foundation, Environment America, Izaak Walton League of America, National Association for the Advancement of Colored People (NAACP), Natural Resources Council of Maine, Natural Resources Defense Council, Ohio Environmental Council, Physicians for Social Responsibility, Sierra Club, and Waterkeeper Alliance – along with EDF, of course.

That’s why today we joined together to file a brief with the Supreme Court asking the Justices not to reconsider the D.C. Circuit Court’s decision upholding these life-saving clean air protections.

Also posted in EPA litgation, Health, Policy / Read 2 Responses

EPA’s State-by-State Carbon Limits Indicate Smart Policy, Not Arbitrary Rulemaking

By EDF Blogs / Published: August 14, 2014

By Kate Zerrenner

EDF_FB_renewableEnergy_solar (1)In June, U.S. Environmental Protection Agency (EPA) announced – for the first time ever – standards to limit carbon emissions from U.S. power plants, known as the Clean Power Plan (CPP). Currently power plants emit 40 percent of U.S. carbon emissions, but under the proposed Clean Power Plan, the U.S. power sector will cut carbon pollution by 30 percent below 2005 levels.

Since this announcement, the usual suspects have attacked the CPP, calling its proposed state-by-state reduction standards arbitrary. Their claims couldn’t be further from reality. When EPA asked states for feedback on how to best craft this standard, states asked for two things: individual standards and flexibility. And that’s what they got. Anyone familiar with the proposed standards will know they are based on a consistent and objective methodology that takes into account each state’s unique energy portfolio and emissions, as well as built with maximum flexibility in mind.

At first glance, the climate-change-denying crowd dismissed the standards as arbitrary, because the limits vary from state to state. For example, Washington needs to reduce its emissions rate by 72 percent by 2030, while Kentucky only needs to cut its emissions rate by 18 percent over the same period. Texas lies somewhere in the middle with a 39 percent reduction required. So what gives?

How did EPA get those numbers?

Let’s unpack the methods that went into EPA’s carbon pollution limits. EPA’s vision for the plan was to give the states complete ownership and flexibility in reducing overall carbon emissions. EPA decided on a simple greenhouse gas performance metric for each state:

Total power plant emissions in one year ÷ Total electricity generation in one year
= Emissions reduction rate

The states have complete control and flexibility over how to meet the emissions reduction rate.

To figure out each state’s potential to reduce emissions, EPA analyzed the practical and affordable strategies that states and utilities are already using to reduce greenhouse gas emissions from the power sector, such as energy efficiency, improving power plant operations, and using more renewable energy. By analyzing state-specific data, EPA calculated practical targets for each state. Their analysis formally considers four “building blocks” for cleaner power:

  1. Improving the efficiency of existing power plants,
  2. Increasing use of the most efficient natural gas plants,
  3. Using more renewable energy, and
  4. Expanding demand-side energy efficiency—the same low-hanging fruit for which experts have been advocating for years.

States are already on their way

If we look at each state’s proposed reductions individually, it’s clear that EPA’s limits will not crash the economy or tear down the power sector. In fact, in many states it will not be difficult to meet EPA’s limits ahead of schedule.

Washington, with its seemingly onerous 72 percent reduction mandate, had already ordered its largest coal plant to shut down by 2025. Closing that coal plant alone will reduce the state’s emissions by 70 percent, because much of Washington’s electricity comes from hydro power. And Kentucky leaders have already devised a strategy to meet the state’s 18 percent reduction goal.

In Texas – my home state – we’re well on our way to meeting the 39 percent reduction standard set by EPA by simply amplifying current trends, namely relying on more West Texas wind, widening the use of efficient natural gas electricity, and taking advantage of the state’s solar potential. Now Texas leaders should craft the best framework for the state – one that has the potential to bring in billions of dollars directly to our state economy, create more homegrown jobs, and lower Texans’ electricity bills. If state leaders make another “principled stance” against the EPA, like they did with the greenhouse gas permits, we can only expect for Texas to fall behind other states as they race toward the trillion dollar clean energy economy. Come January, EDF urges the Legislature to take the bull by the horns and show the nation how Texas will continue to be a leader in energy.

It’s clear that EPA’s limits were developed with a specific and pragmatic methodology. Variation in reduction goals from one state to another reflects variation in the circumstances of individual states, which EPA wisely took into account. Those who condemn the rules as arbitrary are ignoring the actual basis for the rule.

This post first appeared on our Texas Clean Air Matters blog.

Also posted in Clean Power Plan, Energy / Read 1 Response

Why Support the Clean Power Plan? Testimony from the EPA Hearings

By EDF Blogs / Published: July 31, 2014

By Dan Upham

Across the country this week, the U.S. Environmental Protection Agency (EPA) held public hearings to solicit comments about its Clean Power Plan, which will put the first-ever national limits on the amount of climate pollution that can be emitted by power plants. EDF’s president, a senior attorney, and a clean energy specialist were among the hundreds of Americans who testified in support of the Plan. As these selections from EDF staff testimonies illustrate, the Plan offers moderate, flexible, and necessary measures to address climate change at the federal and state levels.

It’s necessary: The climate is changing across the U.S.

Image of the DC rally outside the EPA hearings. Source: Heather Shelby

“The stakes are high in Colorado as hotter temperatures, reduced winter snowpacks, and more frequent droughts are expected to decrease Colorado River streamflows.

Our treasured Rocky Mountain ecosystems are especially susceptible to climate change impacts, and high elevations have already experienced temperature increases at rates three times the global average.

Increased warming, drought, and insect outbreaks have increased wildfires and impacts to people and ecosystems throughout the West.” – Graham McCahan, a senior attorney with EDF’s U.S. Climate and Air legal team.

“The Southeast is the region expected to be the most affected by increasing temperatures. Extremely hot days – 95°F or above – could cause a decrease in labor productivity by 3.2% in the construction, mining, utilities, transportation, and agricultural sectors. Extreme heat also is projected to cause 11,000 to 36,000 more deaths each year.” – Greg Andeck, EDF’s North Carolina senior manager, Clean Energy.

“The bottom line is that we cannot continue down the path of unlimited pollution.” – Fred Krupp, EDF’s president.

It’s flexible: It can work well in different states

“Strong carbon pollution standards are consistent with a strong clean energy economy in Colorado.

Solar and wind resources are cheaper than ever before. In 2012, rooftop solar panels cost approximately one percent of what they did 35 years ago, and the cost of solar panels fell by 60 percent from 2011 to 2013. This past May, Xcel Energy [a Colorado utility] announced that it is now acquiring renewable energy at prices that out-compete fossil fuels.” – Graham McCahan

“The plan would allow North Carolina to get credit for steps it already has taken to grow clean energy and invest in energy efficiency. Here are some examples:

  • North Carolina’s solar industry is now ranked 4th in the country in installed solar capacity, thanks to policies that make it easier for investors to finance projects.
  • North Carolina has more than 1,000 clean energy and energy efficiency companies that can help the state meet the Clean Power Plan.

North Carolina demonstrates how a state can move to a clean energy economy in a thoughtful, measured and cost-effective manner.” – Greg Andeck

It’s moderate (and affordable): The cost of inaction is high

“We know that transition to clean energy is not only possible, it’s affordable. In fact, every time EPA has used the Clean Air Act to limit air pollution, it has ended up boosting our economy. Overall, the benefits have outweighed the costs by thirty to one. And every past rule has saved lives – tens of thousands of them.

Hiding from challenges is not what Americans do. And it is certainly the wrong path for us and the generations to come.” – Fred Krupp

It’s imperative: Millions stand to benefit  

“For the millions of kids who will have fewer asthma attacks in the future.

For the workers who will find jobs in new and growing industries.

For the rate payers, who will see their electricity bills go down.

For all of those who will be protected from the most damaging impacts of climate change.

And for our children and grandchildren, who will know that our generation cared enough to leave them a safer, healthier world.” – Fred Krupp

This post first appeared on EDF Voices

Also posted in Clean Power Plan, Energy, Health, Jobs, Policy / Read 1 Response

EPA’s Authority to Limit Carbon Pollution from Power Plants Is Well Established and Widely Recognized

By Megan Ceronsky / Published: June 17, 2014

Gavel_iStock000003633182Medium(This post was written by EDF attorney Megan Ceronsky and legal fellow Peter Heisler)

The bedrock legal authority underlying the U.S. Environmental Protection Agency’s (EPA) Clean Power Plan is broadly recognized — by our nation’s highest court, states, power companies, academic experts and the EPA General Counsel serving during the President George H.W. Bush administration.

Our recent Climate 411 post chronicles the Supreme Court’s decisions affirming EPA’s authority to address carbon pollution from power plants under section 111 of the Clean Air Act.

In Massachusetts v. EPA (2007), the Court held that carbon dioxide is a pollutant under the Clean Air Act.  Then, in AEP v. Connecticut (2011), the Court explicitly recognized EPA’s authority to limit emissions of carbon dioxide from power plants pursuant to section 111, and acknowledged the agency’s ongoing efforts to do so.

Even before AEP was decided, however, legal researchers and academics had identified section 111 as a promising avenue for regulating carbon pollution from power plants and industrial facilities:

  • A 2009 report by the Congressional Research Service found that “Section 111 appears to provide a strong basis for EPA to establish a traditional regulatory approach to controlling greenhouse gas emissions from large stationary sources.”
  • A 2010 paper by Duke University’s Nicholas Institute for Environmental Policy Solutions observed that “[S]ection 111 appears to provide the EPA with the best means to create a system that … implements a cost-effective program that delivers meaningful emissions reductions, is consistent with both the statutory language of the Act and legal precedent, and is politically viable.”
  • A 2011 survey of the academic community found “widespread agreement” that “[section] 111 authorizes the use of many types of flexible approaches” to regulating carbon pollution.

Indeed, states, power companies, and other stakeholders have all recently analyzed and supported EPA’s authority to limit carbon pollution from power plants:

  • Kentucky recognized EPA’s role in setting the benchmark that states will have to meet under section 111.
  • Pennsylvania said that section 111 was the “most appropriate” provision for regulating carbon dioxide emissions from power plants.
  • The nine Northeastern and Mid-Atlantic states participating in the Regional Greenhouse Gas Initiative “recommend[ed] that EPA use its authority under section 111 of the Clean Air Act to ensure significant overall reductions in carbon emissions.”
  • Fifteen states from across the country agreed that “EPA needs to seize [the] opportunity [for pollution reduction] because Section 111(d) standards are to be based on the ‘best system of emission reduction,’” including energy efficiency and renewable energy.
  • The Clean Energy Group, whose members include some of the largest generators of electricity in the country, noted that “EPA has significant discretion under section 111(d) in determining both the appropriate level of the standards for existing power plants, as well as the form of the regulations.”

Environmental law experts have also analyzed and endorsed EPA’s authority to regulate carbon pollution from power plants:

  • UCLA Law Professor Ann Carlson said “[I]t is important to be clear here: the President is required to issue the rules, required by law and by the interpretation of the law by the highest Court in the land.”
  • Harvard Professor Jody Freeman called critics’ claims to the contrary “weak,” explaining that “[t]he record clearly shows that Congress intended to ensure that harmful pollutants from existing power plants could not entirely escape regulation. These emissions qualify for regulation under 111(d) because they are not covered elsewhere in the law and account for nearly 40 percent of the nation’s total emissions of carbon dioxide, the principal driver of global warming.”
  • E. Donald Elliott, EPA General Counsel under President George H.W. Bush, noted that “the Supreme Court and other courts have upheld EPA’s authority to address this issue,” and “[a] system-wide approach provides needed flexibility and reduces costs, as well as encouraging investment in lower-emitting generation. EPA has wisely left the states a lot of discretion rather than mandating specific measures as some had wanted…”
  • Carol Browner, EPA Administrator during the Clinton administration, wrote that “EPA has authority under the 1990 Clean Air Act, an authority affirmed by the U.S. Supreme Court, to set these public health protections against carbon pollution.”

Finally, Leon G. Billings, who was the principal staff author of the Clean Air Act of 1970, shared his personal knowledge of the statute:

Critics of the move say that President Obama is making an end run around Congress, stretching the law to achieve by executive action what he could not accomplish through the legislative branch … This is flat wrong. More than four decades ago, Congress expressed its clear desire to regulate pollution from power plants, in the form of the Clean Air Act. I know, because I worked on the legislation, including the key part of the act — Section 111 — that the Obama administration is using to justify its move.

The legal community broadly recognizes EPA’s authority and obligation to address carbon pollution emitted by power plants. This is perhaps unsurprising, as all these statements simply echo what the Supreme Court has already held — that EPA’s efforts to reduce carbon pollution from power plants are firmly grounded in the law.

Also posted in Clean Power Plan, EPA litgation / Read 3 Responses

A First Look at the Clean Power Plan: Protecting Public Health and Cutting Carbon Pollution

By Megan Ceronsky / Published: June 4, 2014
Source: Flickr/ Rupert Ganzer

Source: Flickr/Rupert Ganzer

Earlier this week, our nation took a ground-breaking step by proposing to finally establish carbon pollution limits on existing power plants — the single largest source of climate-destabilizing pollution in the U.S. and one of the largest in the world.

We have national limits on the other air pollutants emitted by these plants, including mercury and arsenic and smog-forming pollutants — and we urgently need to secure strong limits on carbon pollution.

Here’s a first look at the proposed Clean Power Plan and its “building blocks” — the opportunity for state leadership, the profound public health benefits for our communities and families, and the good news about cost savings for customers.

The Proposed Pollution Reductions

The Clean Power Plan would reduce carbon pollution from existing fossil fuel-fired power plants by approximately 30 percent by 2030, and could curb emissions by as much as 27 percent by 2020.

EPA looked at the existing power plants in each state, and evaluated four time-tested, cost-effective emission reduction pathways:

  1. The potential to improve power plant efficiency
  2. The potential to rely more on lower-emitting power plants such as combined cycle natural gas and less on higher-emitting power plants
  3. The potential to deploy zero emitting generation resources like wind and solar
  4. The potential to capture end-use energy efficiency opportunities.

EPA then added up these four “building blocks” to calculate the reduction that a State could achieve on average in its overall emission rate over 2020-2029 (the “interim” target), and what rate could be achieved in 2030:

 

State

2012 Emission Rate
(Fossil, Renewable, and 6% Nuclear) (lbs/MWh)

2020-2029 Interim Goal (lbs/MWh)

2030 State Goal (lbs/MWh)

Percent change from 2012 rate

Alabama

1,444

1,147

1,059

-27%

Alaska

1,351

1,097

1,003

-26%

Arizona

1,453

735

702

-52%

Arkansas

1,640

968

910

-45%

California

698

556

537

-23%

Colorado

1,714

1,159

1,108

-35%

Connecticut

765

597

540

-29%

Delaware

1,234

913

841

-32%

Florida

1,200

794

740

-38%

Georgia

1,500

891

834

-44%

Hawaii

1,540

1,378

1,306

-15%

Idaho

339

244

228

-33%

Illinois

1,895

1,366

1,271

-33%

Indiana

1,923

1,607

1,531

-20%

Iowa

1,552

1,341

1,301

-16%

Kansas

1,940

1,578

1,499

-23%

Kentucky

2,158

1,844

1,763

-18%

Louisiana

1,466

948

883

-40%

Maine

437

393

378

-14%

Maryland

1,870

1,347

1,187

-37%

Massachusetts

925

655

576

-38%

Michigan

1,696

1,227

1,161

-32%

Minnesota

1,470

911

873

-41%

Mississippi

1,130

732

692

-39%

Missouri

1,963

1,621

1,544

-21%

Montana

2,245

1,882

1,771

-21%

Nebraska

2,009

1,596

1,479

-26%

Nevada

988

697

647

-34%

New Hampshire

905

546

486

-46%

New Jersey

932

647

531

-43%

New Mexico

1,586

1,107

1,048

-34%

New York

983

635

549

-44%

North Carolina

1,646

1,077

992

-40%

North Dakota

1,994

1,817

1,783

-11%

Ohio

1,850

1,452

1,338

-28%

Oklahoma

1,387

931

895

-35%

Oregon

717

407

372

-48%

Pennsylvania

1,540

1,179

1,052

-32%

Rhode Island

907

822

782

-14%

South Carolina

1,587

840

772

-51%

South Dakota

1,135

800

741

-35%

Tennessee

1,903

1,254

1,163

-39%

Texas

1,298

853

791

-39%

Utah

1,813

1,378

1,322

-27%

Virginia

1,297

884

810

-38%

Washington

763

264

215

-72%

West Virginia

2,019

1,748

1,620

-20%

Wisconsin

1,827

1,281

1,203

-34%

Wyoming

2,115

1,808

1,714

-19%

State Flexibility & Innovation

Under the Clean Power Plan, states will control their own future.

States have the flexibility to deploy the emission reduction policies and pathways that make the most sense for them, maximizing cost-effectiveness and co-benefits for their citizens, so long as they achieved the required emission reductions.

Some states might choose to build their compliance plans around existing Renewable Energy Standards and energy efficiency programs. Others might choose to put in place an emission reduction trading program between power plants. Still others might choose to collaborate with other states to submit joint plans and capture the cost-effective emission reduction opportunities available across state boundaries.

Public Health Benefits

The public health benefits of the Clean Power Plan are extensive and will help ensure healthier and longer for our loved ones who suffer from heart and lung ailments, and for our children.

EPA’s analysis shows that the reductions in carbon pollution and the associated reductions in sulfur dioxide, oxides of nitrogen, and particulate matter that will happen as a result will generate health benefits of $55 to $93 billion per year in 2030.

The pollutants that contribute to the soot and smog that make people sick will be reduced by more than 25 percent in 2030 — avoiding 2,700 to 6,600 premature deaths and 140,000 to 150,000 asthma attacks per year.

From the soot and smog reductions alone — ignoring the important reductions in carbon pollution achieved — Americans will see 7 dollars in health benefits for every dollar invested through the Clean Power Plan.

Cleaner power will ensure healthier and longer lives for millions of Americans.

Electricity Rates & Reliability

EPA’s analysis also shows that there will be sufficient power generation capacity across the United States under this framework to meet demand.

The flexibility provided to States will allow them to design plans to secure reductions in carbon pollution without any risk to power reliability.  As has been true for the past 40 years, we will reduce air pollution and maintain reliable power.

Because the Clean Power Plan will spur investments in demand-side energy efficiency, in 2030 electricity bills are expected to be 8 percent lower than they would have been without the plan.

Under the Clean Power Plan we will have cleaner, safer power, lower electricity bills, cleaner air, and healthier lives.

Cleaner power for a stronger America.

Also posted in Clean Power Plan, Energy, Greenhouse Gas Emissions / Read 2 Responses

Power plant rule a tipping point for clean energy economy

By EDF Blogs / Published: June 3, 2014

By Cheryl Roberto, Associate Vice President, Clean Energy Program

For those of us (and all of you) who’ve been urging the government to implement meaningful climate policy, the release yesterday of a plan to cut carbon emissions from power plants has been a long time coming. But it finally came.

The U.S. Environmental Protection Agency’s proposed carbon pollution rule for existing fossil-fueled power plants – also known as the Clean Power Plan – are a huge win for our climate.

We also think it could go down in history as the tipping point in our nation’s transition to a clean energy economy. Here’s why:

Old, dirty power plants will be retired

The nation’s fleet of coal-fired power plants is the single largest source of carbon pollution in the U.S. and one of the largest in the world. Placing carbon regulations on this source of electricity for the first time in history will transform our energy system.

Utilities have acknowledged that it doesn’t make economic sense to pour money into retrofitting and retaining older, less-reliable coal-fired power plants when they need to focus investments on newer and more reliable plants.

This means that many of the most highly-polluting coal-fired power plants that provide electricity to our homes and businesses today will be retired. It presents a unique opportunity for clean energy solutions to fill the gap in generating capacity.

It may be one of the largest market opportunities in history to drive…clean energy on a national level.

Increasing our use of homegrown, renewable power sources and investing in proven tools such as energy efficiency, smart grids and demand response (which compensates electricity customers for conserving energy) will help fill this gap while reducing our reliance on fossil fuels that pollute the environment and contribute to climate change.

States will lead the way

EPA’s approach provides clear guidance for what limits and metrics must be met, but leaves states the flexibility to design solutions to meet those requirements as they see fit. This will encourage all states (even those which do not embrace the climate challenge) to look at clean energy technology as an attractive option when they seek to comply with the law.

Federal limits on carbon pollution from existing power plants are exactly the clarity states need to lead us to clean, reliable and affordable energy for all Americans – now and in the future.

Entrepreneurs, investors ready to jump in

What’s more, the new EPA plan – once it’s final – will give entrepreneurs, corporations and venture capitalists the market signal they need to go full steam ahead with low-carbon innovations. It may be one of the largest market opportunities in history to drive the development and implementation of clean energy on a national level.

At Environmental Defense Fund, we’re right in the middle of many of these promising solutions, working with state legislators and regulators to clear outdated rules that mire us in the past and discourages innovators.

Paving the way for a cleaner, healthier future

We’re working with financial institutions to develop new funding opportunities for clean energy investments that will help raise the estimated $10.5 trillion needed over the next two decades to transition our world to a clean energy economy.

We’re working with energy research pioneer Pecan Street Inc.in Austin, TX to test customer energy management solutions such as rooftop solar, home energy storage, learning thermostats and time-of-use energy pricing (which incentivizes people to use electricity during periods of low, or “off-peak” energy demand).

And we’re pushing to make energy efficiency a cornerstone of America’s energy policy.

It may not be as sexy as fuel cells and solar panels, butbuilding a more efficient energy system — from power plants to transmission lines to homes and buildings — is the most affordable and cleanest path forward.

The United States is expected to spend about $2 trillion over the next two decades to replace our outdated electric infrastructure. These new regulations are a step in the right direction toward ensuring that these investments are spent on our future and not entrenching us in our past.

EPA’s proposed rule means good jobs, economic development and a healthier planet.

And as a pioneer at the forefront of this movement, EDF is determined to make sure we stay on track.

This blog first appeared on EDF Voices

Also posted in Clean Power Plan, Energy, Green Jobs, Greenhouse Gas Emissions / Read 1 Response