Group considers appeal over transmission lines

IESO Fictitious Demand Error inflated HOEP in the Ontario electricity market, after embedded generation was mis-modeled; the OEB says double-counted load lifted wholesale prices and shifted costs via the Global Adjustment.

Key Points

An IESO modeling flaw that double-counted load, inflating HOEP and charges in Ontario's wholesale market.

✅ Double-counted unmetered load from embedded generation

✅ Inflated HOEP; shifted costs via Global Adjustment

✅ OEB flagged transparency; exporters paid more

For almost a year, the operator of Ontario’s electricity system erroneously counted enough phantom demand to power a small city, causing prices to spike and hundreds of millions of dollars in extra charges to consumers, according to the provincial energy regulator.

The Independent Electricity System Operator (IESO) also failed to tell anyone about the error once it noticed and fixed it.

The error likely added between $450 million and $560 million to hourly rates and other charges before it was fixed in April 2017, according to a report released this month by the Ontario Energy Board’s Market Surveillance Panel.

It did this by adding as much as 220 MW of “fictitious demand” to the market starting in May 2016, when the IESO started paying consumers who reduced their demand for power during peak periods. This involved the integration of small-scale embedded generation (largely made up of solar) into its wholesale model for the first time.

The mistake assumed maximum consumption at such sites without meters, and double-counted that consumption.

The OEB said the mistake particularly hurt exporters and some end-users, who did not benefit from a related reduction of a global adjustment rate applicable to other customers.

“The most direct impact of the increase in HOEP (Hourly Ontario Energy Price) was felt by Ontario consumers and exporters of electricity, who paid an artificially high HOEP, to the benefit of generators and importers,” the OEB said.

The mix-up did not result in an equivalent increase in total system costs, because changes to the HOEP are offset by inverse changes to a electricity cost allocation mechanism such as the Global Adjustment rate, the OEB noted.

A chart from the OEB's report shows the time of day when fictitious demand was added to the system, and its influence on hourly rates.

Peak time spikes
The OEB said that the fictitious demand “regularly inflated” the hourly price of energy and other costs calculated as a direct function of it.

For almost a year, Ontario's electricity system operator @IESO_Tweets erroneously counted enough phantom demand to power a small city, causing price spikes and hundreds of millions in charges to consumers, @OntEnergyBoard says. @5thEstate reports.

It estimated the average increase to the HOEP was as much as $4.50/MWh, but that price spikes, compounded by scheduled OEB rate changes, would have been much higher during busier times, such as the mid-morning and early evening.

“In times of tight supply, the addition of fictitious demand often had a dramatic inflationary impact on the HOEP,” the report said.

That meant on one summer evening in 2016 the hourly rate jumped to $1,619/MWh, it said, which was the fourth highest in the history of the Ontario wholesale electricity market.

“Additional demand is met by scheduling increasingly expensive supply, thus increasing the market price. In instances where supply is tight and the supply stack is steep, small increases in demand can cause significant increases in the market price.

The OEB questioned why, as of September this year, the IESO had failed to notify its customers or the broader public, amid a broader auditor-regulator dispute that drew political attention, about the mistake and its effect on prices.

“It's time for greater transparency on where electricity costs are really coming from,” said Sarah Buchanan, clean energy program manager at Environmental Defence.

“Ontario will be making big decisions in the coming years about whether to keep our electricity grid clean, or burn more fossil fuels to keep the lights on,” she added. “These decisions need to be informed by the best possible evidence, and that can't happen if critical information is hidden.”

In a response to the OEB report on Monday, the IESO said its own initial analysis found that the error likely pushed wholesale electricity payments up by $225 million. That calculation assumed that the higher prices would have changed consumer behaviour, while upcoming electricity auctions were cited as a way to lower costs, it said.

In response to questions, a spokesperson said residential and small commercial consumers would have saved $11 million in electricity costs over the 11-month period, even as a typical bill increase loomed province-wide, while larger consumers would have paid an extra $14 million.

That is because residential and small commercial customers pay some costs via time-of-use rates, including a temporary recovery rate framework, the IESO said, while larger customers pay them in a way that reflects their share of overall electricity use during the five highest demand hours of the year.

The IESO said it could not compensate those that had paid too much, given the complexity of the system, and that the modelling error did not have a significant impact on ratepayers.

While acknowledging the effects of the mistake would vary among its customers, the IESO said the net market impact was less than $10 million, amid ongoing legislation to lower electricity rates in Ontario.

It said it would improve testing of its processes prior to deployment and agreed to publicly disclose errors that significantly affect the wholesale market in the future.

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Shenao Power Plant Controversy intensifies as the EPA, Taipower, and New Taipei officials clash over EIA findings, a marine conservation area, fisheries, public health risks, and protests against a coal-fired plant in Rueifang.

Key Points

Dispute over coal plant EIA, marine overlap, and health risks, pitting EPA and Taipower against New Taipei and residents.

✅ EPA approved EIA changes; city cites marine conservation conflict

✅ Rueifang residents protest; 400+ signatures, wardens oppose

✅ Debate centers on fisheries, public health, and coal plant impacts

The controversy over the Shenao Power Plant heated up yesterday as Environmental Protection Administration (EPA) and New Taipei City Government officials quibbled over the project’s potential impact on a fisheries conservation area and other issues, mirroring New Hampshire hydropower clashes seen elsewhere.

State-run Taiwan Power Co (Taipower) wants to build a coal-fired plant on the site of the old Shenao plant, which was near Rueifang District’s (瑞芳) Shenao Harbor.

The company’s original plan to build a new plant on the site passed an environmental impact assessment (EIA) in 2006, similar to how NEPA rules function in the US, and the EPA on March 14 approved the firm’s environmental impact difference analysis report covering proposed changes to the project.

#google#

That decision triggered widespread controversy and protests by local residents, environmental groups and lawmakers, echoing enforcement disputes such as renewable energy pollution cases reported in Maryland.

The controversy reached a new peak after New Taipei City Mayor Eric Chu on Tuesday last week posted on Facebook that construction of wave breakers for the project would overlap with a marine conservation area that was established in November 2014.

The EPA and Taipower chose to ignore the demarcation lines of the conservation area, Chu wrote.

Dozens of residents from Rueifang and other New Taipei City districts yesterday launched a protest at 9am in front of the Legislative Yuan in Taipei, amid debates similar to the Maine power line proposal in the US, where the Health, Environment and Labor Committee was scheduled to review government reports on the project.

More than 400 Rueifang residents have signed a petition against the project, including 17 of the district’s 34 borough wardens, Anti-Shenao Plant Self-Help Group director Chen Chih-chiang said.

Ruifang residents have limited access to information, and many only became aware of the construction project after the EPA’s March 14 decision attracted widespread media coverage, Chen said,

Most residents do not support the project, despite Taipower’s claims to the contrary, Chen said.

New Power Party Executive Chairman Huang Kuo-chang, who represents Rueifang and adjacent districts, said the EPA has shown an “arrogance of power” by neglecting the potential impact on public health and the local ecology of a new coal-fired power plant, even as it moves to revise coal wastewater limits elsewhere.

Huang urged residents in Taipei, Keelung, Taoyaun and Yilan County to reject the project.

If the New Taipei City Government was really concerned about the marine conservation area, it should have spoken up at earlier EIA meetings, rather than criticizing the EIA decision after it was passed, Environmental Protection Administration Deputy Minister Chan Shun-kuei told lawmakers at yesterday’s meeting.

Chan said he wondered if Chu was using the Shenao project for political gain.

However, New Taipei City Environmental Protection Department specialist Sun Chung-wei  told lawmakers that the Fisheries Agency and other experts voiced concerns about the conservation area during the first EIA committee meeting on the proposed changes to the Shenao project on June 15 last year.

Sun was invited to speak to the legislative committee by Chinese Nationalist Party (KMT) Legislator Arthur Chen.

While the New Taipei City Fisheries and Fishing Port Affairs Management Office did not present a “new” opinion during later EIA committee meetings, that did not mean it agreed to the project, Sun said.

However, Chan said that Sun was using a fallacious argument and trying to evade responsibility, as the conservation area had been demarcated by the city government.

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Hydro One-Avista Merger outlines a utility acquisition shaped by Washington regulators, Colstrip coal plant depreciation, and plans for renewables, clean energy, and emissions cuts, while Montana reviews implications for jobs, ratepayers, and a 2027 closure.

Key Points

A utility deal setting Colstrip depreciation and renewables, without committing to an early coal plant closure.

✅ Washington sets 2027 depreciation for Colstrip units

✅ Montana reviews jobs, ratepayer impacts, community fund

✅ Avista seeks renewables; no binding shutdown commitment

The Washington power company Hydro One is buying will be ready to close its huge coal-fired generating station ahead of schedule, thanks to conditions put on the corporate merger by state regulators there.

Not that we actually plan to do that, the company is telling other regulators in Montana, where coal unit retirements are under debate, the huge coal-fired generating station in question employs hundreds of people. We’ll be in the coal business for a good long time yet.

Hydro One, in which the Ontario government now owns a big minority stake, is still working on its purchase of Avista, a private power utility based in Spokane. The $6.7-billion deal, which Hydro One announced in July, includes a 15 per cent share in two of the four generating units in a coal plant in Colstrip, Montana, one of the biggest in the western United States. Avista gets most of its electricity from hydro dams and gas but uses the Colstrip plant when demand for power is high and water levels at its dams are low.

#google#

Colstrip’s a town of fewer than 2,500 people whose industries are the power plant and the open-pit mines that feed it about 10 million tonnes of coal a year. Two of Colstrip’s generators, older ones Avista doesn’t have any stake in, are closing in 2022. The other two will be all that keep the town in business.

In Washington, they don’t like the coal plant and its pollution. In Montana, the future of Colstrip is a much bigger concern. The companies have to satisfy regulators in both places that letting Hydro One buy Avista is in the public interest.

Ontario proudly closed the last of our coal plants in 2014 and outlawed new ones as environmental menaces, and Alberta's coal phase-out is now slated to finish by 2023. When Hydro One said it was buying Avista, which makes about $100 million in profit a year, Premier Kathleen Wynne said she hoped Ontario’s “value system” would spread to Avista’s operations.

The settlement is “an important step towards bringing together two historic companies,” Hydro One’s chief executive Mayo Schmidt said in announcing it.

The deal has approval from the Washington Utilities and Transportation Commission staff but is subject to a vote by the group’s three commissioners. It doesn’t commit Avista to closing anything at Colstrip or selling its share. But Avista and Hydro One will budget as if the Colstrip coal burners will close in 2027, instead of running into the 2040s as their owners had once planned, a timeline that echoes debates over the San Juan Generating Station in New Mexico.

In accounting terms, they’ll depreciate the value of their share of the plant to zero over the next nine years, reflecting what they say is the end of the plant’s “useful life.” Another of Colstrip’s owners, Puget Sound Energy, has previously agreed with Washington regulators that it’ll budget for a Colstrip closure in 2027 as well.

Avista and Hydro One will look for sources of 50 megawatts of renewable electricity, including independent power projects where feasible, in the next four years and another 90 megawatts to supplement Avista’s supply once the Colstrip plant eventually closes, they promise in Washington. They’ll put $3 million into a “community transition fund” for Colstrip.

The money will come from the companies’ profits and cash, the agreement says. “Hydro One will not seek cost recovery for such funds from ratepayers in Ontario,” it says specifically.

“Ontario has always been a global leader in the transition away from dirty coal power and towards clean energy,” said Doug Howell, an anti-coal campaigner with the Sierra Club, which is a party to the agreement. “This settlement continues that tradition, paving the way for the closure of the largest single source of climate pollution in the American West by 2027, if not earlier.”

Montanans aren’t as thrilled. That state has its own public services commission, doing its own examination of the corporate merger, which has asked Hydro One and Avista to explain in detail why they want to write off the value of the Colstrip burners early. The City of Colstrip has filed a petition saying it wants in on Montana hearings because “the potential closure of (Avista’s units) would be devastating to our community.”

Don’t get too worked up, an Avista vice-president urged the Montana commission just before Easter.

“Just because an asset is depreciated does not mean that one would otherwise remove that asset from service if the asset is still performing as intended,” Jason Thackston testified in a session that dealt only with what the deal with Washington state would mean to Colstrip. We’re talking strictly about an accounting manoeuvre, not an operational commitment.

Six joint owners will have to agree to close the Colstrip generators and there’s “no other tacit understanding or unstated agreement” to do that, he said.

Besides Washington and Montana, state regulators in Idaho, including those overseeing the Idaho Power settlement process, Alaska and Oregon and multiple federal authorities have to sign off on the deal before it can happen. Hydro One hopes it’ll be done in the second half of this year.

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Hospital Electricity Reliability underpins ICU operations, ventilators, medical devices, and diagnostics, reducing power outages risks via grid power and backup generators, while energy poverty and blackouts magnify COVID-19 mortality in vulnerable regions.

Key Points

Hospital electricity reliability is steady power that keeps ICU care, ventilators and medical devices operating.

✅ ICU loads: ventilators, monitors, infusion pumps, diagnostics

✅ Grid power plus backup generators minimize outage risk

✅ Energy poverty increases COVID-19 mortality and infection

Robert Bryce, Contributor

During her three-year career as a registered nurse, my friend, C., has cared for tuberculosis patients as well as ones with severe respiratory problems. She’s now caring for COVID-19 patients at a hospital in Ventura County, California, where debates about keeping the lights on continue amid the state’s energy transition. Is she scared about catching the virus? “No,” she replied during a phone call on Thursday. “I’m pretty unflappable.”

What would scare her? She quickly replied, “a power outage,” a threat that grows during summer blackouts when heat waves drive demand. About a year ago, while working in Oregon, the hospital she was working in lost power for about 45 minutes. “It was terrifying,” she said. 

C., who wasn’t authorized by her hospital to talk to the media, and thus asked me to only use the initial of her first name, said that COVID-19 patients are particularly reliant on electrical devices. She quickly ticked off the machines: “The bed, the IV machine, vital signs monitor, heart monitor, the sequential compression devices...” COVID-19 patients are hooked up to a minimum of five electrical devices, she said, and if the virus-stricken patient needs high-pressure oxygen or a ventilator, the number of electrical devices could be two or three times that number. “You name it, it plugs in,” she said.  

Today In: Energy

The virus has infected some 2.2 million people around the world and killed more than 150,000,including more than 32,000 people here in the U.S. While those numbers are frightening, it is apparent that the toll would be far higher without adequate supplies of reliable electricity. Modern healthcare systems depend on electricity. Hospitals are particularly big consumers. Power demand in hospitals is about 36 watts per square meter, which is about six times higher than the electricity load in a typical American home, and utilities are turning to AI to adapt to electricity demands during surges. 

Beating the coronavirus is all about electricity. Indeed, nearly every aspect of coronavirus detection, testing, and treatment requires juice. Second, it appears that the virus is more deadly in places where electricity is scarce or unreliable. Finally, if there are power outages in virus hotspots or hospitals, a real risk in a grid with more blackouts than other developed countries, the damage will be even more severe. 

As my nurse friend in Ventura County made clear, her ability to provide high-quality care for patients is wholly dependent on reliable electricity. The thermometers used to check for fever are powered by electricity. The monitors she uses to keep track of her patients, as well as her Vocera, the walkie-talkie that she uses to communicate with her colleagues, runs on batteries. Testing for the virus requires electricity. One virus-testing machine, Abbott Labs’ m2000, is a 655-pound appliance that, according to its specification sheet, runs on either 120 or 240 volts of electricity. The operating manual for a ventilator made by Hamilton Medical is chock full of instructions relating to electricity, including how to manage the machine’s batteries and alarms. 

While it may be too soon to make a direct connection between lack of electricity and the lethality of the coronavirus, the early signs from the Navajo reservation indicate that energy poverty amplifies the danger. The sprawling reservation has about 175,000 residents, but it has a higher death toll from the virus than 13 states. About 10 percent of Navajos do not have electricity in their homes and more than 30 percent lack indoor plumbing. 

The death rate from the virus on the reservation now stands at 3.4 percent, which is nearly twice the global average. In the middle of last week, the entire population of Native American tribes in the U.S. accounted for about 1,100 confirmed cases of the virus and about 44 deaths. Navajos accounted for the majority of those, with 830 confirmed cases of coronavirus and 28 deaths. 

On Saturday night, the Navajo Times reported a major increase, with 1,197 positive cases of COVID-19 on the reservation and 44 deaths. Other factors may contribute to the high infection and mortality rates on the reservation, including  high rates of diabetes, obesity, and crowded residential living situations. That said, electricity and water are essential to good hygiene and health authorities say that frequent hand washing helps cut the risk of contracting the virus. 

The devastation happening on Navajoland provides a window into what may happen in crowded, electricity-poor countries like India, Pakistan, and Bangladesh. It also shows what could happen if a tornado or hurricane were to wipe out the electric grid in virus hotspots like New Orleans, as extreme weather increasingly afflicts the grid nationwide. Sure, most American hospitals have backup generators to help assure reliable power. But those generators can fail. Further, they usually burn diesel fuel which needs to be replenished every few days. 

The essential point here is that our hospitals and critical health care machines aren’t running on solar panels and batteries. Instead, they are running on grid power that’s being provided by reliable sources — coal, natural gas, hydro, and nuclear power — which together produce about 89 percent of the electricity consumed in this country, even as Russian hacking of utilities highlights cyber risks. The pandemic — which is inflicting trillions of dollars of damage on our economy and tens of thousands of deaths — underscores the criticality of abundant and reliable electricity to our society and the tremendous damage that would occur if our health care infrastructure were to be hit by extended blackouts during the fight to stop COVID-19.

In a follow-up interview on Saturday with my friend, C., she told me that while caring for patients, she and her colleagues “are entirely dependent on electricity. We take it for granted. It’s a hidden assumption in our work,” a reminder echoed by a grid report card that warns of dangerous vulnerabilities. She quickly added she and her fellow nurses “aren’t trained or equipped to deal with circumstances that would come with shoddy power. If we lost power completely, people will die.”

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UK Renewables Surpass Nuclear Milestone as wind farms and solar panels outpace atomic output, cutting greenhouse gas emissions. BEIS data show low-carbon power generation rising while onshore wind subsidies and auction timelines face policy debate.

Key Points

It is the quarter when UK wind and solar generated more electricity than nuclear, signaling cleaner, low-carbon growth.

✅ BEIS reports wind and solar at 18.33 TWh vs nuclear 16.69 TWh

✅ Energy sector emissions fell 8% as coal use dropped

✅ Calls grow to reopen onshore wind support via CFD auctions

Wind farms and solar panels, with wind leading the power mix during key periods, produced more electricity than the UK’s eight nuclear power stations for the first time at the end of last year, official figures show.

Britain’s greenhouse gas emissions also continued to fall, dropping 3% in 2017, as coal use fell and the use of renewables climbed, though low-carbon generation stalled in 2019 according to later data.

Energy experienced the biggest drop in emissions of any UK sector, of 8%, while pollution from transport and businesses stayed flat.

Energy industry chiefs said the figures showed that the government should rethink its ban on onshore wind subsidies, a move that ministers have hinted could happen soon.

Lawrence Slade, chief executive of the big six lobby group Energy UK, said: “We need to keep up the pace ... by ensuring that the lowest cost renewables are no longer excluded from the market.”

Across the whole year, low-carbon sources of power – wind, solar, biomass and nuclear – provided a record 50.4% of electricity, up from 45.7% in 2016, when wind beat coal for the first time.

But in the fourth quarter of 2017, high wind speeds, new renewables installations and lower nuclear output saw wind and solar becoming the second biggest source of power for the first time.

Wind and solar generated 18.33 terawatt hours (TWh), with nuclear on 16.69TWh, and the UK later set a new record for wind power during 2019, the figures published by the Department for Business, Energy and Industrial Strategy show.

But renewables still have a long way to go to catch up with gas, the UK’s top source of electricity at 36.12TWh, which saw its share of generation fall slightly, though at times wind became the main source as capacity expanded.

Greenpeace said the figures showed the government should capitalise on its lead in renewables and “stop wasting time and money propping up nuclear power”.

Horizon Nuclear Power, a subsidiary of the Japanese conglomerate Hitachi, is in talks with Whitehall officials for a financial support package from the government, which it says it needs by midsummer.

By contrast, large-scale solar and onshore wind projects are not eligible for support, after the Conservative government cut subsidies in 2015.

However the energy minister, Claire Perry, recently told House Magazine that “we will have another auction that brings forward wind and solar, we just haven’t yet said when”.

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Affordable Clean Energy Rule Lawsuit pits EPA and coal industry allies against health groups over Clean Power Plan repeal, greenhouse gas emissions standards, climate change, public health, and state authority before the D.C. Circuit.

Key Points

A legal fight over EPA's ACE rule and CPP repeal, weighing emissions policy, state authority, climate, and public health.

✅ Challenges repeal of Clean Power Plan and adoption of ACE.

✅ EPA backed by coal, utilities; health groups seek stricter limits.

✅ D.C. Circuit to review emissions authority and state roles.

The largest trade association representing coal interests in the country has joined other business and electric utility groups in siding with the EPA in a lawsuit challenging the Trump administration's repeal of the Clean Power Plan.

The suit -- filed by the American Lung Association and the American Public Health Association -- seeks to force the U.S. Environmental Protection Agency to drop a new rule-making process that critics claim would allow higher levels of greenhouse gas emissions, further contributing to the climate crisis and negatively impacting public health.

The new rule, which the Trump administration calls the "Affordable Clean Energy rule" (ACE), "would replace the 2015 Clean Power Plan, which EPA has proposed to repeal because it exceeded EPA's authority. The Clean Power Plan was stayed by the U.S. Supreme Court and has never gone into effect," according to an EPA statement.

EPA has also moved to rewrite wastewater limits for coal power plants, signaling a broader rollback of related environmental requirements.

America's Power -- formerly the American Coalition for Clean Coal Electricity -- the U.S. Chamber of Commerce, the National Mining Association, and the National Rural Electric Cooperative Association have filed motions seeking to join the lawsuit. The U.S. Court of Appeals for the District of Columbia Circuit has not yet responded to the motion.

Separately, energy groups warned that President Trump and Energy Secretary Rick Perry were rushing major changes to electricity pricing that could disrupt markets.

"In this rule, the EPA has accomplished what eluded the prior administration: providing a clear, legal pathway to reduce emissions while preserving states' authority over their own grids," Hal Quinn, president and chief executive officer of the mining association, said when the new rule was released last month. "ACE replaces a proposal that was so extreme that the Supreme Court issued an unprecedented stay of the proposal, having recognized the economic havoc the mere suggestion of such overreach was causing in the nation's power grid."

Around the same time, a coal industry CEO blasted a federal agency's decision on the power grid as harmful to reliability.

The trade and business groups have argued that the Clean Power Plan, set by the Obama administration, was an overreach of federal power. Finalized in 2015, the plan was President Obama's signature policy on climate change, rooted in compliance with the Paris Climate Treaty. It would have set state limits on emissions from existing power plants but gave wide latitude for meeting goals, such as allowing plant operators to switch from coal to other electric generating sources to meet targets.

Former EPA Administrator Scott Pruitt argued that the rule exceeded federal statutory limits by imposing "outside the fence" regulations on coal-fired plants instead of regulating "inside the fence" operations that can improve efficiency.

The Clean Power Plan set a goal of reducing carbon emissions from power generators by 32 percent by the year 2030. An analysis from the Rhodium Group found that had states taken full advantage of the CPP's flexibility, emissions would have been reduced by as much as 72 million metric tons per year on average. Still, even absent federal mandates, the group noted that states are taking it upon themselves to enact emission-reducing plans based on market forces.

In its motion, America's Power argues the EPA "acknowledged that the [Best System of Emission Reduction] for a source category must be 'limited to measures that can be implemented ... by the sources themselves.'" If plants couldn't take action, compliance with the new rule would require the owners or operators to buy emission rate credits that would increase investment in electricity from gas-fired or renewable sources. The increase in operating costs plus federal efforts to shift power generation to other sources of energy, thereby increasing costs, would eventually force the coal-fired plants out of business.

In related proceedings, renewable energy advocates told FERC that a DOE proposal to subsidize coal and nuclear plants was unsupported by the record, highlighting concerns about market distortions.

"While we are confident that EPA will prevail in the courts, we also want to help EPA defend the new rule against others who prefer extreme regulation," said Michelle Bloodworth, president and CEO of America's Power.

"Extreme regulation" to one group is environmental and health protections to another, though.

Howard A. Learner, executive director of the Environmental Law & Policy Center of the Midwest, defended the Clean Power Plan in an opinion piece published in June.

"The Midwest still produces more electricity from coal plants than any other region of the country, and Midwesterners bear the full range of pollution harms to public health, the Great Lakes, and overall environmental quality," Learner wrote. "The new [Affordable Clean Energy] Rule is a misguided policy, moves our nation backward in solving climate change problems, and misses opportunities for economic growth and innovation in the global shift to renewable energy. If not reversed by the courts, as it should be, the next administration will have the challenge of doing the right thing for public health, the climate and our clean energy future."

When it initially filed its lawsuit against the Trump administration's Affordable Clean Energy Rule, the American Lung Association accused the EPA of "abdicat[ing] its legal duties and obligations to protect public health." It also referred to the new rule as "dangerous."

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