Symantec survey sees another kind of green

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Green IT initiatives have reached critical mass in the enterprise, according to Symantec Corp.'s annual green IT survey on worldwide perceptions and practices.

According to the 2009 Worldwide Green IT Report, 100 per cent of Canadian enterprises and 97 per cent of enterprises worldwide are discussing green IT strategies. Fifty-nine percent in Canada and 45 per cent worldwide have implemented them.

Reducing electricity consumption is a driver for 90 per cent of green efforts worldwide and 94 per cent in Canada, while reducing cooling costs is driver at 87 per cent of enterprises surveyed and 97 per cent in Canada.

The whole agenda of doing the right thing from an ecological point of view did not get lost in the shuffle, said Jose Iglesias, vice-president of global solutions for Symantec.

"Ninety-two per cent of Canadian respondents said that corporate still wants them to be green... despite the economic mess," he said.

Canada isn't exactly a leader in green IT, according to Jessica Vreeswijk, founder and director of Terrabtyes Consulting, a green IT consulting firm based in Victoria, B.C. "I've seen more come out of San Francisco than I see or hear in Canada," she said.

But green IT means different things to different people, according to Iglesias. "We were very careful to define what we mean by green IT," he said. The three main drivers, according to the survey, are reducing electricity consumption, reducing cooling costs and corporate intention to be "green."

Eighty-nine per cent of Canadian IT departments are now responsible or cross-charged for electricity costs, which marks a major shift in budgeting practices. "When we talked to CIOs a couple years ago, this was not the case," said James Brehm, senior consultant and director of the information and communication technology practice at Frost & Sullivan Ltd.

"People started taking a look at what's the big power consumer and oftentimes, it's the things that IT is responsible for. The big power cost isn't the fluorescent light above me, it's the PC in front of me that's plugged in," he said.

The typical respondent in Symantec's survey spends $21 million (US$19.3 million) to $27 million annually on data centre electricity, with Canadian business costs averaging $28 million each year. Realizing the significance of these costs and becoming responsible for them is likely one reason why IT is so focused on going green, according to Iglesias.

"All of a sudden, they've realized they have to pay for this electric bill, which many industry analysts say is the second largest operational expense for the IT budget, and they are having to look at ways of reducing charges," he said.

Green IT budgets are also on the rise, according to the survey, with 56 per cent of Canadian businesses and 73 per cent worldwide reporting an increase in green IT budgets over the next 12 months.

The fact that budgets for green IT are rising as part of the overall IT budget, when overall IT budgets are either staying flat or declining, is an indicator that not only is the whole topic of green IT important, but a way to lower other parts of enterprise cost structure, said Iglesias.

Brehm isn't surprised by the budget increase, due to rising interest in cloud computing and virtualization. "But truly, these people doing cloud computing and virtualization may not be going at it with the ecosystem in mind. They may be doing it with efficiencies in mind... I think green is oftentimes a benefit of doing things smarter," he said.

Enterprises are also willing to pay a premium for green IT products. Seventy six per cent of Canadian respondents are willing to pay at least 10 per cent more for an energy efficient product of equivalent functionality and 33 per cent would accept increases of at least 20 per cent. Two thirds of businesses worldwide are willing to accept the 10 per cent increase and 41 per cent would reportedly pay 20 per cent more.

But this doesn't mean enterprises are willing to buy an inferior product just because it has greener credentials, Iglesias pointed out. "If you pay 10 per cent premium on this product that allows you to save 15 per cent on the electric cost, then you are paying a premium for the product. Nevertheless, you are actually getting a return on that premium that you just paid. Also, if you are going in and part of your company's agenda is to be perceived as a green company, you are fulfilling that aspect of your company's agenda," he said.

"Rarely do you see a win-win situation where customers get a chance to save money and do the right thing," he added.

While studies like Symantec's are important to show attitudes and perceptions, being green is more than purchasing the right technology solutions, Vreeswijk pointed out. "I think all of those technical solutions they talk about, like power management and virtualization, all those things are really important in terms of business efficiency, but it's not quite enough to call yourself green," she said.

"We really need to look at management practices and how we approach IT in terms of what we purchase, how often we upgrade and extending the lifecycle of our assets... my only worry is that this will encourage buying more equipment or more technical solutions," she added.

Vreeswijk believes corporations will eventually implement green IT efforts for the sake of the environment, but that we're not there yet. IT is just learning what environmental responsibility means, she said.

"They don't know how to apply sustainability to IT yet. The things happening in IT are about cost savings. It's about reducing energy consumption to save money. It's not about being responsible in terms of making sure you're purchased in the way that's responsible," she said.

Seeing North America catch up with the rest of the world in green efforts is positive, according to Vreeswijk. "I've certainly seen an attitude change in the past year towards green IT, specifically in both Canada and the U.S.," she said.

Brehm is surprised to see enterprises reporting green as an essential. Vendors see green as an item on a checklist, he said. "But when it gets right down to it and they have to write a cheque, green is not something they are willing to pay extra for."

"It's all good and nice to do a survey and let people vote with their heart, but do those results ring true when you are voting with your pocketbook?" asked Brehm.

Enterprises are having a tough time right now with the economy and a lot of pressure has been put on the CIO and his staff, Brehm pointed out. "That's where the war is being fought right now. It's how do we get more efficient, how do we get more streamlined, how do we save power, how do we save cost, how do we re-utilize our machines... let's see how they are voting with their pocketbooks throughout the remainder of the year," he said.

There are two ways to get green, said Brehm. "One way is to keep everything you have and not go out and purchase it and hold onto it longer. The other way is to purchase new products and services that are green and more efficient."

The Symantec report is based on 1,052 responses from enterprise IT vice presidents, senior vice-presidents, directors, CIOs and CTOs worldwide. Applied Research conducted the survey in March 2009.

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BC Hydro launches program to help coronavirus-affected customers with their bills

BC Hydro COVID-19 Bill Relief provides payment deferrals, no-penalty payment plans, Crisis Fund grants up to $600, and utility bill assistance as customers face pandemic layoffs, social distancing, and increased home power usage.

 

Key Points

A BC Hydro program offering bill deferrals, no-penalty plans, and up to $600 Crisis Fund grants during COVID-19.

✅ Defer payments or set no-penalty payment plans

✅ Apply for up to $600 Customer Crisis Fund grants

✅ Measures to ensure reliable power and remote customer service

 

BC Hydro is implementing a program, including bill relief measures, to help people pay their bills if they’re affected by the novel coronavirus.

The Crown corporation says British Columbians are facing a variety of financial pressures related to the COVID-19 pandemic, as some workplaces close or reduce staffing levels and commercial power consumption plummets across the province.

BC Hydro said it also expects increased power usage as more people stay home amid health officials’ requests that people take social distancing measures, even as electricity demand is down 10% provincewide.

Under the new program, customers will be able to defer bill payments or arrange a payment plan with no penalty, though a recent report on deferred operating costs outlines long-term implications for the utility.

BC Hydro says some customers could also be eligible for grants of up to $600 under its Customer Crisis Fund, if facing power disconnection due to job loss, illness or loss of a family member, while in other jurisdictions power bills were cut for households during the pandemic.

The company says it has taken precautions to keep power running by isolating key facilities, including its control centre, and by increasing its cleaning schedule, a priority even as some utilities face burgeoning debt amid COVID-19.

It has also closed its walk-in customer service desks to reduce risk from face-to-face contact and suspended all non-essential business travel, public meetings and site tours, and warned businesses about BC Hydro impersonation scams during this period.

 

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Major U.S. utilities spending more on electricity delivery, less on power production

U.S. Utility Spending Shift highlights rising transmission and distribution costs, grid modernization, and smart meters, while generation expenses decline amid fuel price volatility, capital and labor pressures, and renewable integration across the power sector.

 

Key Points

A decade-long trend where utilities spend more on delivery and grid upgrades, and less on electricity generation costs.

✅ Delivery O&M, wires, poles, and meters drive rising costs

✅ Generation spending declines amid fuel price changes and PPI

✅ Grid upgrades add reliability, resilience, and renewable integration

 

Over the past decade, major utilities in the United States have been spending more on delivering electricity to customers and less on producing that electricity, a shift occurring as electricity demand is flat across many regions.

After adjusting for inflation, major utilities spent 2.6 cents per kilowatthour (kWh) on electricity delivery in 2010, using 2020 dollars. In comparison, spending on delivery was 65% higher in 2020 at 4.3 cents/kWh, and residential bills rose in 2022 as inflation persisted. Conversely, utility spending on power production decreased from 6.8 cents/kWh in 2010 (using 2020 dollars) to 4.6 cents/kWh in 2020.

Utility spending on electricity delivery includes the money spent to build, operate, and maintain the electric wires, poles, towers, and meters that make up the transmission and distribution system. In real 2020 dollar terms, spending on electricity delivery increased every year from 1998 to 2020 as utilities worked to replace aging equipment, build transmission infrastructure to accommodate new wind and solar generation amid clean energy transition challenges that affect costs, and install new technologies such as smart meters to increase the efficiency, reliability, resilience, and security of the U.S. power grid.

Spending on power production includes the money spent to build, operate, fuel, and maintain power plants, as well as the cost to purchase power in cases where the utility either does not own generators or does not generate enough to fulfill customer demand. Spending on electricity production includes the cost of fuels including natural gas prices alongside capital, labor, and building materials, as well as the type of generators being built.

Other utility spending on electricity includes general and administrative expenses, general infrastructure such as office space, and spending on intangible goods such as licenses and franchise fees, even as electricity sales declined in recent years.

The retail price of electricity reflects the cost to produce and deliver power, the rate of return on investment that regulated utilities are allowed, and profits for unregulated power suppliers, and, as electricity prices at 41-year high have been reported, these components have drawn increased scrutiny.

In 2021, demand for consumer goods and the energy needed to produce them has been outpacing supply, though power demand sliding in 2023 with milder weather has also been noted. This difference has contributed to higher prices for fuels used by electric generators, especially natural gas. The increased cost for fuel, capital, labor, and building materials, as seen in the U.S. Bureau of Labor Statistics’ Producer Price Index, is increasing the cost of power production for 2021. U.S. average electricity prices have been higher every month of this year compared with 2020, according to our Monthly Electric Power Industry Report.

 

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Air Conditioning Related Power Usage Set To Create Power Shortages In Many States

Texas Power Grid Blackouts loom as ERCOT forecasts record air conditioning load, tight reserve margins, peak demand spikes, and rising natural gas prices; heatwaves could trigger brownouts without added solar, storage, and demand response.

 

Key Points

Texas Power Grid Blackouts are outages when AC-driven peak demand and ERCOT reserves outstrip supply during heatwaves.

✅ ERCOT forecasts record AC load and tight reserve margins.

✅ Coal retirements cut capacity; gas and solar additions lag.

✅ Peak prices, brownouts likely without storage and demand response.

 

U.S. Air conditioning related electricity usage will break records and may cause blackouts across the U.S. and in Texas this summer. Power grid operators are forecasting that electricity supplies will exceed demands during the summer months.

Most of Texas will face severe electricity shortages because of hot temperatures, air conditioning, and a strong economy, with millions at risk of electricity shut-offs during extreme heat, Bill Magness the president of the Electric Reliability Council of Texas (ERCOT) told the Associated Press. Magness thinks the large numbers people moving to Texas for retirement will increase the demand for air conditioning and electricity use. Retired people are more likely to be home during the day when temperatures are high – so they are more likely to turn up the air conditioner.

Around 50% of all electricity in Texas is used for air conditioning and 100% of homes in Texas have air conditioners, Forbes reported. That means just a few hot days can strain the grid and a heatwave can trigger brownouts and blackouts, in a system with more blackouts than other developed countries on average.

The situation was made worse by Vistra Energy’s decision to close more coal-fired power plants last year, The Austin American Statesman reported. The closed plants; Big Brown, Sadow, and Monticello, generated around 4,100 megawatts (4.1 million watts) of electricity, enough generation capacity to power two million homes, The Waco Herald-Tribune reported.

 

Texas Electric Grid Might Not Meet Demand

Texas’s grid has never operated without those plants will make this summer a test of its capacity. Texas only has a 6% reserve of electricity that might fall will because of problems like downed lines or a power plant going offline.

A Vistra subsidiary called Luminant has added around 8,000 megawatts of generation capacity from natural-gas burning plants, The Herald-Tribune reported. Luminant also plans to open a giant solar power plant in Texas to increase grid capacity.

The Texas grid already reached peak capacity in May because of unexpectedly high demand and technical problems that reflect more frequent outages in many states, Houston Public Media reported. Grid capacity fell because portions of the system were offline for maintenance.

Some analysts have suggested starting schools after Labor Day to shift peak August demand, potentially easing stress on the grid.

 

 

Electricity Reserves are Tight in Texas

Electricity reserves will be very tight on hot summer days in Texas this summer, Magness predicted. When the thermometer rises, people crank up the air conditioner which burns more electricity.

The grid operator ERCOT anticipates that Texas will need an additional 1,600 megawatts of electricity this summer, but record-high temperatures can significantly increase the demand. If everything is running correctly, Texas’s grid can produce up to 78,184 megawatts of electricity.

“The margin between absolute peak power usage and available peak supply is tighter than in years past,” Andrew Barlow, a spokesman for Texas’s Public Utility Commission admitted.

Around 90% of Texas’s grid has enough generating capacity, ERCOT estimated. That means 10% of Texas’s power grid lacks sufficient generating capacity which increases the possibility of blackouts.

Even if the electricity supply is adequate electricity prices can go up in Texas because of higher natural gas prices, Forbes reported. Natural gas prices might go up over the summer because of increased electricity demands. Texas uses between 8% and 9% of America’s natural gas supply to generate electricity for air conditioning in the summer.

 

Be Prepared For Blackouts This Summer.

Texas’s problems might affect other regions including neighboring states such as Oklahoma, Arkansas, Louisiana, and New Mexico and parts of Mexico, as lawmakers push to connect Texas’s grid to the rest of the nation to improve resilience because those areas are connected to the same grid. Electricity from states like Colorado might be diverted to Texas in case of power shortages there.

Beyond the U.S., Canadian electricity grids are increasingly exposed to harsh weather that can ripple across markets as well.

Home and business owners can avoid summer blackouts by tapping sources of Off-Grid electricity. The two best sources are backup battery storage and solar panels which can run your home or business if the grid runs dry.

If you have family members with health problems who need air conditioning, or you rely on a business or freelance work that requires electricity for income, backup power is vital. Those who need backup electricity for their business should be able to use the expense of installing it as a tax deduction.

Having backup electricity available might be the only way for Texans to keep cool this summer.

 

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Entergy Creates COVID-19 Emergency Relief Fund to Help Customers in Need

Entergy COVID-19 Emergency Relief Fund provides financial assistance to ALICE households, low-income seniors, and disabled customers via United Way grants for rent, mortgage, utilities, food, and bill payment support during COVID-19, alongside a disconnect moratorium.

 

Key Points

A shareholder-funded program offering essential grants and bill support to Entergy customers affected by COVID-19.

✅ Shareholders commit $700,000; grants distributed via United Way partners.

✅ Focus on ALICE families, low-income seniors, and disabled customers.

✅ Disconnects suspended; bill tools and LIHEAP advocacy underway.

 

In an effort to help working families experiencing financial hardships as a result of the coronavirus pandemic, the Entergy Charitable Foundation has established the COVID-19 Emergency Relief Fund, recognizing the need for electricity across communities.

"The health and safety of our customers, employees and communities is Entergy's top priority," said Leo Denault, chairman and CEO of Entergy Corporation. "For more than 100 years, Entergy has never wavered in our commitment to supporting our customers and the communities we serve. This pandemic is no different. During this challenging time, we are helping lessen the impact of this crisis on the most vulnerable in our communities. I strongly encourage our business partners to join us in this effort."

As devastating and disruptive as this crisis is for everyone, we know from past experience that those most heavily impacted are ALICE households (low-wage working families) and low-income elderly and disabled customers, who often face energy insecurity during such events - roughly 40%-50% of Entergy's customer base.

"We know from experience that working families and low-income elderly and disabled customers are hardest hit during times of crisis," said Patty Riddlebarger, vice president of Entergy's corporate social responsibility. "We are working quickly to make funds available to community partners that serve vulnerable households to lessen the economic impact of the COVID-19 crisis and ensure that families have the resources they need to get by during this time of uncertainty."

To support our most vulnerable customers, Entergy shareholders are committing $700,000 to the COVID-19 Emergency Relief Fund to help qualifying customers with basic needs such as food and nutrition, rent and mortgage assistance, and other critical needs, alongside measures like Texas utilities waiving fees that ease household costs, until financial situations become more stable. Grants from the fund will be provided to United Way organizations and other nonprofit partners across Entergy's service area that are providing services to impacted households.

Company shareholders will also match employee contributions to the COVID-19 relief efforts of local United Way organizations up to $100,000 to maximize impact.

In addition to establishing the COVID-19 Emergency Relief Fund, Entergy is taking additional steps to support and protect our customers during this crisis, similar to PG&E's pandemic response measures, including:

With support from our regulators, we are temporarily suspending customer disconnects, as seen in New Jersey and New York policies, as we continue to monitor the situation.

We are working with our network of community advocates, as the industry coordination with federal partners continues, to request a funding increase of the Low Income Home Energy Assistance Program to help alleviate financial hardships caused by COVID-19 on vulnerable households.

We are developing bill payment solutions and tools to help customers pay their accumulated balances once the disconnect moratorium is lifted.

Already in place to support vulnerable customers is Entergy's The Power to Care program, which provides emergency bill payment assistance to seniors and disabled individuals. To mark the 20th anniversary of Entergy's low-income customer initiative, the limit of shareholders' dollar for dollar match of customer donations was increased from $500,000 to $1 million per year. Shareholders continue to match employee donations dollar for dollar with no limit.

 

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Bruce nuclear reactor taken offline as $2.1B project 'officially' begins

Bruce Power Unit 6 refurbishment replaces major reactor components, shifting supply to hydroelectric and natural gas, sustaining Ontario jobs, extending plant life to 2064, and managing radioactive waste along Lake Huron, on-time and on-budget.

 

Key Points

A 4-year, $2.1B reactor overhaul within a 13-year, $13B program to extend plant life to 2064 and support Ontario jobs.

✅ Unit 6 offline 4 years; capacity shift to hydro and gas

✅ Part of 13-year, $13B program; extends life to 2064

✅ Creates jobs; manages radioactive waste at Lake Huron

 

The world’s largest nuclear fleet, became a little smaller Monday morning. Bruce Power has began the process to take Unit 6 offline to begin a $2.1 billion project, supported by manufacturing contracts with key suppliers, to replace all the major components of the reactor.

The reactor, which produces enough electricity to power 750,000 homes and reflects higher output after upgrades across the site, will be out of service for the next four years.

In its place, hydroelectric power and natural gas will be utilized more.

Taking Unit 6 offline is just the “official” beginning of a 13-year, $13-billion project to refurbish six of Bruce Power’s eight nuclear reactors, as Ontario advances the Pickering B refurbishment as well on its grid.

Work to extend the life of the nuclear plant started in 2016, and the company recently marked an operating record while supporting pandemic response, but the longest and hardest part of the project - the major component replacement - begins now.

“The Unit 6 project marks the next big step in a long campaign to revitalize this site,” says Mike Rencheck, Bruce Power’s president and CEO.

The overall project is expected to last until 2033, and mirrors life extensions at Pickering supporting Ontario’s zero-carbon goals, but will extend the life of the nuclear plant until 2064.

Extending the life of the Bruce Power nuclear plant will sustain 22,000 jobs in Ontario and add $4 billion a year in economic activity to the province, say Bruce Power officials.

About 2,000 skilled tradespeople will be required for each of the six reactor refurbishments - 4,200 people already work at the sprawling nuclear plant near Kincardine.

It will also mean tons of radioactive nuclear waste will be created that is currently stored in buildings on the Bruce Power site, along the shores of Lake Huron.

Bruce Power restarted two reactors back in 2012, and in later years doubled a PPE donation to support regional health partners. That project was $2-billion over-budget, and three years behind schedule.

Bruce Power officials say this refurbishment project is currently on-time and on-budget.

 

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Coal, Business Interests Support EPA in Legal Challenge to Affordable Clean Energy Rule

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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