Alstom opens disconnect switch facility

Biden Clean Energy Plan 2035 accelerates carbon-free electricity with renewables, nuclear, hydropower, and biomass, invests $2T in EVs, grid and energy efficiency, and tightens fuel economy standards beyond the Clean Power Plan.

Key Points

A $2T U.S. climate plan for carbon-free power by 2035, boosting renewables, nuclear, EVs, efficiency, and grid upgrades.

✅ Targets a zero-carbon electric grid nationwide by 2035

✅ Includes renewables, nuclear, hydropower, and biomass in standard

✅ Funds EVs, grid modernization, weatherization, and fuel economy rules

This month the Democratic presumptive presidential nominee, Joe Biden, outlined an ambitious plan, including Biden’s solar plan to expand clean energy, for tackling climate change that shows how far the party has shifted on the issue since it controlled the White House.

President Barack Obama’s Clean Power Plan had called for the electricity sector to cut its carbon pollution 32 percent by 2030, and did not lay out a trajectory for phasing out oil, coal or natural gas production.

This year, Democratic 2020 hopefuls such as Sen. Bernie Sanders (I-Vt.) went much further, suggesting the United States should derive all of its electricity from renewable sources by 2030, moving to 100% renewables as part of a $16.3 trillion plan to wean the nation away from fossil fuels. Many other congressional Democrats have embraced the Green New Deal — the nonbinding resolution calling for a carbon-free power sector by 2030 and more energy efficient buildings and vehicles, along with a massive investment in electric vehicles and high-speed rail.

Last year, 38 percent of U.S. electricity generated came from clean sources, according to a Washington Post analysis of data from the U.S. Energy Information Administration, and in April renewables hit a record 28% nationwide.

Biden’s new plan, which carries a price tag of $2 trillion, would eliminate carbon emissions from the electric sector by 2035, impose stricter gas mileage standards, fund investments to weatherize millions of homes and commercial buildings, and upgrade the nation’s transportation system. To reach its 2035 carbon-free electricity goal, the campaign includes wind, solar and several forms of energy, acknowledging why the grid isn’t yet 100% renewable while balancing reliability, that are not always counted in state renewable portfolio standards, such as nuclear, hydropower and biomass.

“A great appeal of the Biden proposal is that it is much closer to targeting carbon directly, which is the ultimate enemy, and plays fewer favorites with particular technologies,” said Michael Greenstone, who directs the University of Chicago’s Energy Policy Institute. “This will reduce the costs to consumers and give more carbon bang for the buck.”

But some environmentalists, such as Friends of the Earth President Erich Pica, question the idea of including more controversial carbon-free technologies. “There is no role for nuclear in a least-cost, low carbon world. Including these dinosaurs in a clean energy standard is going to incentivize industry efforts to keep aging, dangerous facilities online,” Pica said in an email.

Hydropower, which relies on a system of moving water that constantly recharges, is defined as renewable by the Environmental Protection Agency. Biomass is often considered as carbon neutral because even though it releases carbon dioxide when it is burned, the plants capture nearly the same amount of CO2 while growing.

Both forms of energy have come under fire for their environmental impacts, however. Damming streams and rivers can destroy fish habitat and make it more difficult for them to spawn, and it also seems unlikely that hydropower will expand its current 6 percent share of the nation’s electrical grid.

Many experts argue that classifying biomass energy as carbon neutral provides an incentive to cut down trees that would otherwise remain standing and sequester carbon. “If burning this wood were good for the climate, then we should not recycle paper, we should burn it,” noted Tim Searchinger, a research scholar at the Princeton School of Public and International Affairs.

Illinois lead the nation in the amount of electricity generated from nuclear power

More than half of the country — 30 states, Washington, and three territories — have adopted a renewable portfolio standard (RPS), according to the National Conference of State Legislatures, and seven states and one territory have set renewable energy goals. While 14 states, along with the District, Puerto Rico and the Virgin Islands, have established requirements of 50 percent or more carbon-free electricity, nearly as many have set theirs at 15 percent or less.

Maine Gov. Janet Mills (D), who has called for 100% renewable electricity in the state, has pushed clean electricity aggressively since taking office in 2019, lifting a wind energy moratorium imposed by her predecessor and signing bills aimed at expanding the state’s carbon-free energy sources. Biomass accounts for a quarter of the state’s electricity, more than any other state.

New York has one of the country’s most ambitious climate targets, which it scaled up last year. It aims to obtain 70 percent of its power from renewable sources within a decade, a period when renewables surpassed coal in U.S. generation, and eliminate carbon altogether by 2040, even as the state is in the process of shutting down a major nuclear plant near New York City, Indian Point, which is slated to cease operating on April 30, 2021.

... while other states are weakening theirs

Last year, Ohio weakened its renewable energy standard from a target of 12.5 percent in 2027 to 8.5 percent by 2026, even as renewables topped coal nationwide for the first time in over a century, without setting any future goals, and jettisoned its energy efficiency standard. West Virginia — which established modest renewable requirements in 2009 — repealed them altogether in 2015, the year they were set to take effect.

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Duke Energy Smart Meters enable remote meter reading, daily energy usage data, and two-way outage detection via AMI, with encrypted data, faster restoration, and remote connect/disconnect for Indiana customers in Howard County.

Key Points

Advanced meters that support remote readings, daily usage insights, two-way outage detection, and secure, encrypted data.

✅ Daily energy usage available online the next day

✅ Two-way communications speed outage detection and restoration

✅ Remote connect/disconnect; manual reads optional with opt-out fee

Say goodbye to your neighborhood meter reader. Say hello to your new smart meter.

Over the next three months, Duke Energy will install nearly 43,000 new high-tech electric meters for Howard County customers that will allow the utility company to remotely access meters via the digital grid instead of sending out employees to a homeowner's property for walk-by readings.

That means there's no need to estimate bills when meters can't be easily accessed, such as during severe weather or winter storms.

Other counties serviced by Duke Energy slated to receive the meters include Miami, Tipton, Cass and Carroll counties.

Angeline Protogere, Duke Energy's lead communication consultant, said besides saving the company money and manpower, the new smart meters come with a host of benefits for customers enabled by smart grid solutions today.

The meters are capable of capturing daily energy usage data, which is available online the next day. Having this information available on a daily basis can help customers make smarter energy decisions and support customer analytics that avoid billing surprises at the end of the month, she said.

"The real advantage is for the consumer, because they can track their energy usage and adjust their usage before the bills come," Protogere said.

When it comes to power outages, the meters are capable of two-way communications. That allows the company to know more about an outage through synchrophasor monitoring, which can help speed up restoration. However, customers will still need to notify Duke Energy if their power goes out.

If a customer is moving, they don't have to wait for a Duke Energy representative to come to the premises to connect or disconnect the energy service because requests can be performed remotely.

Protogere said when it comes to installing the meters, the changeover takes less than 5 minutes to complete. Customers should receive advance notices from the company, but the technician also will knock on the door to let the customer know they are there.

If no one is available and the meter is safely accessible, the technician will go ahead and change out the meter, Protogere said. There will be a momentary outage between the time the old meter is removed and the new meter is installed.

Kokomo and the surrounding areas are one of the last parts of the state to receive Duke Energy's new, high-tech meters, which are commonly used by other utility companies and in smart city initiatives across the U.S.

Protogere said statewide, the company started installing smart meters in August 2016 as utilities deploy digital transformer stations to modernize the grid. To date, they have installed 694,000 of the 854,000 they have planned for the state.

The company says the information stored and transmitted on the smart meters is safe, protected and confidential. Duke Energy said on its website that it does not share data with anyone without customers' authorization. The information coming from the meters is encrypted and protected from the moment it is collected until the moment it is purged, the company said.

Digital smart meter technology uses radio frequency bands that have been used for many years in devices such as baby monitors and medical monitors. The radio signals are far below the levels emitted by common household appliances and electronics, including cellphones and microwave ovens.

According to the World Health Organization, FCC, U.S. Food and Drug Administration and Electric Power Research Institute, no adverse health effects have been shown to occur from the radio frequency signals produced by smart meters or other such wireless networks.

However, customers can still opt-out of getting a smart meter and continue to have their meter manually read.

Those who choose not to get a smart meter must pay a $75 initial opt-out fee and an additional $17.50 monthly meter reading charge per account.

If smart meters have not yet been installed, Duke Energy will waive the $75 initial opt-out fee if customers notify the company they want to opt out within 21 days of receiving the installation postcard notice.

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Near-Field Thermophotovoltaics captures radiated energy across a nanoscale gap, using thin-film photovoltaic cells and indium gallium arsenide to boost power density and efficiency, enabling compact Army portable power from emitters via radiative heat transfer.

Key Points

A nanoscale TPV method capturing near-field photons for higher power density at lower emitter temperatures.

✅ Nanoscale gap boosts radiative transfer and usable photon flux

✅ Thin-film InGaAs cells recycle sub-band-gap photons via reflector

✅ Achieved ~5 kW/m2 power density with higher efficiency

With the addition of sensors and enhanced communication tools, providing lightweight, portable power has become even more challenging, with concepts such as power from falling snow illustrating how diverse new energy-harvesting approaches are. Army-funded research demonstrated a new approach to turning thermal energy into electricity that could provide compact and efficient power for Soldiers on future battlefields.

Hot objects radiate light in the form of photons into their surroundings. The emitted photons can be captured by a photovoltaic cell and converted to useful electric energy. This approach to energy conversion is called far-field thermophotovoltaics, or FF-TPVs, and has been under development for many years; however, it suffers from low power density and therefore requires high operating temperatures of the emitter.

The research, conducted at the University of Michigan and published in Nature Communications, demonstrates a new approach, where the separation between the emitter and the photovoltaic cell is reduced to the nanoscale, enabling much greater power output than what is possible with FF-TPVs for the same emitter temperature.

This approach, which enables capture of energy that is otherwise trapped in the near-field of the emitter is called near-field thermophotovoltaics or NF-TPV and uses custom-built photovoltaic cells and emitter designs ideal for near-field operating conditions, alongside emerging smart solar inverters that help manage conversion and delivery.

This technique exhibited a power density almost an order of magnitude higher than that for the best-reported near-field-TPV systems, while also operating at six-times higher efficiency, paving the way for future near-field-TPV applications, including remote microgrid deployments in extreme environments, according to Dr. Edgar Meyhofer, professor of mechanical engineering, University of Michigan.

"The Army uses large amounts of power during deployments and battlefield operations and must be carried by the Soldier or a weight constrained system," said Dr. Mike Waits, U.S. Army Combat Capabilities Development Command's Army Research Laboratory. "If successful, in the future near-field-TPVs could serve as more compact and higher efficiency power sources for Soldiers as these devices can function at lower operating temperatures than conventional TPVs."

The efficiency of a TPV device is characterized by how much of the total energy transfer between the emitter and the photovoltaic cell is used to excite the electron-hole pairs in the photovoltaic cell, where insights from near-light-speed conduction research help contextualize performance limits in semiconductors. While increasing the temperature of the emitter increases the number of photons above the band-gap of the cell, the number of sub band-gap photons that can heat up the photovoltaic cell need to be minimized.

"This was achieved by fabricating thin-film TPV cells with ultra-flat surfaces, and with a metal back reflector," said Dr. Stephen Forrest, professor of electrical and computer engineering, University of Michigan. "The photons above the band-gap of the cell are efficiently absorbed in the micron-thick semiconductor, while those below the band-gap are reflected back to the silicon emitter and recycled."

The team grew thin-film indium gallium arsenide photovoltaic cells on thick semiconductor substrates, and then peeled off the very thin semiconductor active region of the cell and transferred it to a silicon substrate, informing potential interfaces with home battery systems for distributed use.

All these innovations in device design and experimental approach resulted in a novel near-field TPV system that could complement distributed resources in virtual power plants for resilient operations.

"The team has achieved a record ~5 kW/m2 power output, which is an order of magnitude larger than systems previously reported in the literature," said Dr. Pramod Reddy, professor of mechanical engineering, University of Michigan.

Researchers also performed state-of-the-art theoretical calculations to estimate the performance of the photovoltaic cell at each temperature and gap size, informing hybrid designs with backup fuel cell solutions that extend battery life, and showed good agreement between the experiments and computational predictions.

"This current demonstration meets theoretical predictions of radiative heat transfer at the nanoscale, and directly shows the potential for developing future near-field TPV devices for Army applications in power and energy, communication and sensors," said Dr. Pani Varanasi, program manager, DEVCOM ARL that funded this work.

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Alberta coal phaseout accelerates as utilities convert to natural gas, cutting emissions under TIER regulations and deploying hydrogen-ready, carbon capture capable plants, alongside new solar projects in a competitive, deregulated electricity market.

Key Points

A provincewide shift from coal to natural gas and renewables, cutting power emissions years ahead of the 2030 target.

✅ Capital Power, TransAlta converting coal units to gas

✅ TIER pricing drives efficiency, carbon capture readiness

✅ Hydrogen-ready turbines, solar projects boost renewables

Alberta is set to meet its goal to eliminate coal-fired electricity production years earlier than its 2030 target, amid a broader shift to cleaner energy in the province, thanks to recently announced utility conversion projects.

Capital Power Corp.’s plan to spend nearly $1 billion to switch two coal-fired power units west of Edmonton to natural gas, and stop using coal entirely by 2023, was welcomed by both the province and the Pembina Institute environmental think-tank.

In 2014, 55 per cent of Alberta’s electricity was produced from 18 coal-fired generators. The Alberta government announced in 2015 it would eliminate emissions from coal-fired electricity generation by 2030.

Dale Nally, associate minister of Natural Gas and Electricity, said Friday that decisions by Capital Power and other utilities to abandon coal will be good for the environment and demonstrates investor confidence in Alberta’s deregulated electricity market, where the power price cap has come under scrutiny.

He credited the government’s Technology Innovation and Emissions Reduction (TIER) regulations, which put a price on industrial greenhouse gas emissions, as a key factor in motivating the conversions.

“Capital Power’s transition to gas is a great example of how private industry is responding effectively to TIER, as it transitions these facilities to become carbon capture and hydrogen ready, which will drive future emissions reductions,” Nally said in an email.

Capital Power said direct carbon dioxide emissions at its Genesee power facility near Edmonton will be about 3.4 million tonnes per year lower than 2019 emission levels when the project is complete.

It says the natural gas combined cycle units it’s installing will be the most efficient in Canada, adding they will be capable of running on 30 per cent hydrogen initially, with the option to run on 95 per cent hydrogen in future with minor investments.

In November, Calgary-based TransAlta Corp. said it will end operations at its Highvale thermal coal mine west of Edmonton by the end of 2021 as it switches to natural gas at all of its operated coal-fired plants in Canada four years earlier than previously planned.

The Highvale surface coal mine is the largest in Canada, and has been in operation on the south shore of Wabamun Lake in Parkland County since 1970.

The moves by the two utilities and rival Atco Ltd., which announced three years ago it would convert to gas at all of its plants by this year, mean significant emissions reduction and better health for Albertans, said Binnu Jeyakumar, director of clean energy for Pembina.

“Alberta’s early coal phaseout is also a great lesson in good policy-making done in collaboration with industry and civil society,” she said.

“As we continue with this transformation of our electricity sector, it is paramount that efforts to support impacted workers and communities are undertaken.”

She added the growing cost-competitiveness of renewable energy, such as wind power, makes coal plant retirements possible, applauding Capital Power’s plans to increase its investments in solar power.

In Ontario, clean power policy remains a focus as the province evaluates its energy mix.

The company announced it would go ahead with its 75-megawatt Enchant Solar power project in southern Alberta, investing between $90 million and $100 million, and that it has signed a 25-year power purchase agreement with a Canadian company for its 40.5-MW Strathmore Solar project now under construction east of Calgary.
 

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Taltson Hydro Electric Heating directs surplus hydro power in the South Slave to space heat via discounted rates, displacing diesel and cutting greenhouse gas emissions, with rebates, separate metering, and backup systems shaping adoption.

Key Points

An initiative using Taltson's surplus hydro to heat buildings, discount rates replace diesel and cut emissions.

✅ 6.3 cents/kWh heating rate needs separate metering, backup heat

✅ 4-6 MW surplus hydro; outages require diesel; rebates available

✅ Program may be curtailed if new mines or mills demand power

A Northwest Territories green energy advocate says there's an obvious way to expand demand for electricity in the territory's South Slave region without relying on new mining developments — direct it toward heating.

One of the reasons the N.W.T. has always had some of the highest electricity rates in Canada is that a small number of people have to shoulder the huge costs of hydro facilities and power plants.

But some observers point out that residents consume as much energy for heat as they do for conventional uses of electricity, such as lighting and powering appliances. Right now almost all of that heat is generated by expensive oil imported from the United States.

The Northwest Territories Power Corporation says the 18-megawatt Taltson hydro system that serves the South Slave typically has four to six megawatts of excess generating capacity, even as record demand in Yukon is reported. It says using some of that to generate heat is a government priority.

But renewable energy advocate and former N.W.T. MP Dennis Bevington, who lives in the South Slave and heats his home using electricity, says the government is not making it easy for people to tap into that surplus to heat their homes and businesses, a debate that some say would benefit from independent planning at the national level.

Discount rate for heating, but there are catches
The power corporation offers hydro electricity from Taltson to use for heating at a much lower price than it charges for electricity generally. The discounted rate is not available to residential customers.

According to the corporation, consumers pay only 6.3 cents per kilowatt hour compared to the regular rate of just under 24 cents, while Manitoba Hydro financial pressures highlight the risks of expanding demand without new generation.

But to distinguish between the two, users are required to cover the cost of installing a separate power meter. Bevington, who developed the N.W.T.'s first energy strategy, says that is an unnecessary expense.

Taltson expansion key to reducing N.W.T.'s greenhouse gas emissions, says gov't
"The billing is how you control that," he said. "You establish an average electrical use in the winter months. That could be the base rate. Then, if you use power in the winter months above that, you get the discount."

Users are also required to have a back-up heating system. Taltson hydro power offers heating on the understanding that when the hydro system is down — such as during power outages or annual summer maintenance of the hydro system — electricity is not available for heating.
The president and CEO of the power corporation says there's a good reason for that. "The diesels are more expensive to run and they're actually greenhouse gas emitting," said Noel Voykin. "The whole idea of this [electric heat] program is to provide clean energy that is not otherwise being used."

According to the corporation, there have been huge savings for the few who have tapped into the hydro system to heat their buildings, and across Canada utilities are exploring novel generation such as NB Power's Belledune seawater project to diversify supply.

It's being used to heat Aurora College's Breynat Hall, and Joseph B. Tyrrell Elementary School and the transportation department garage in Fort Smith, N.W.T. Electricity is also used to heat the Jackfish power plant in the North Slave region.

The corporation says that during a four-year period, this saved more than 600,000 litres of diesel fuel and reduced greenhouse gas emissions by about 1,700 tonnes.

Bevington says the most obvious place to expand the use of electrical heat is to government housing.

"We have a hundred public housing units in Fort Smith," he said. "The government is putting diesel into those units [for heating] and they could be putting in their own electricity."

Heating a tiny part of energy market
The corporation says it sells only about 2.5 megawatts of electricity for heating each year, which is less than four per cent of the power it sells in the region. It says with some upgrades, another two megawatts of electricity could be made available for electrical heat.

Bevington says the corporation could do more to market electricity for heating. Voykin said that's the government's job. There are three programs that offer rebates to residents and businesses converting to electric heating.

If you build it, will they come? N.W.T. gov't hopes hydro expansion will attract investment
There are better options than billion dollar Taltson expansion, say energy leaders
There may be a reason why the government and the corporation are not more aggressively promoting using surplus electricity in the Taltson system for heating, as large hydro ambitions have reopened old wounds in places like Quebec and Newfoundland and Labrador during recent debates.

It is anticipating that new industrial customers may require that excess capacity in the coming years, and experiences elsewhere show that accommodating new energy-intensive customers can be challenging for utilities. Voykin said those potential new customers include a proposed mine at Pine Point and a pellet mill in Enterprise, N.W.T., even as biomass use faces environmental pushback in some regions.

The corporation says any surplus power in the system will be sold at standard rates to any new industrial customers instead of at discount rates for heating. If that requires cutting back on the heating program, it will be cut back.

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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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