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Obama climate plan calls for new fuel economy standards for heavy-duty vehicles post-2018; cleaner fuels and investment in advanced fossil energy

Among the transportation-related elements of US President Barack Obama’s new climate action plan, which he is outlining today in a speech at Georgetown University, is the development of new fuel economy standards for heavy-duty vehicles post-2018. In 2011, the Obama Administration finalized the first fuel economy standards for Model Year 2014-2018 for medium- and heavy-duty trucks, buses, and vans. (Earlier post.)

The plan as outlined also calls for further work on advanced biofuels, advanced batteries and fuel cell technologies in every transportation mode. In coming months, the plan notes, the Department of Transportation will work with other agencies to further explore strategies for integrating alternative fuel vessels into the US flag fleet.

The plan. President Obama’s plan, which sidesteps the need for Congressional involvement by relying on a wide variety of executive actions, has three main components:

  1. Reducing greenhouse gas emissions in the US.
  2. Preparing the US for the impacts of climate change.
  3. Leading international efforts for GHG emission reductions and adaptation.

Reducing greenhouse gas emissions in the US. The headliner in this segment is the issuance of a Presidential Memorandum directing the Environmental Protection Agency (EPA) to work “expeditiously” to complete CO2 emission standards for both new and existing power plants. The standards for new plants—already being developed by EPA—are to be done this fall. A proposal for existing plants is due in 2014, with targeted file rule in 2015.

The plan also calls for accelerating the permitting for renewable power generation on public lands and upgrading the grid. In terms of investment in innovation for cleaner energy, the plan calls for:

  • Investment in advanced fossil energy projects. In the coming weeks, DOE will issue a draft of a solicitation that would make up to $8 billion in (self-pay) loan guarantee authority available for a wide array of advanced fossil energy projects under its Section 1703 loan guarantee program. This solicitation is designed to support investments in innovative technologies that can cost-effectively meet financial and policy goals, including the avoidance, reduction, or sequestration of anthropogenic emissions of greenhouse gases. The proposed solicitation will cover a broad range of advanced fossil energy projects.

    DOE will take comment on the draft solicitation, with a plan to issue a final solicitation by the fall of 2013.

  • A Federal Quadrennial Energy Review. The QER will be led by the White House Domestic Policy Council and Office of Science and Technology Policy, supported by a Secretariat established at the Department of Energy, and involving the engagement of federal agencies and outside stakeholders. This review will focus on infrastructure challenges, and will identify the threats, risks, and opportunities for US energy and climate security, with the intent of enabling the federal government to translate policy goals into a set of sequenced and integrated actions and proposed investments over a four-year planning horizon.

  • New energy efficiency standards. In President Obama’s first term, the DOE established new minimum efficiency standards for dishwashers, refrigerators, and many other products. The new goal is that efficiency standards for appliances and federal buildings set in the first and second terms combined will reduce carbon pollution by at least 3 billion metric tons cumulatively by 2030—equivalent to nearly one-half of the CO2 emissions from the entire US energy sector for one year.

  • Reducing barriers to investment in energy efficiency. The Department of Agriculture’s Rural Utilities Service will finalize a proposed update to its Energy Efficiency and Conservation Loan Program to provide up to $250 million for rural utilities to finance efficiency investments by businesses and homeowners across rural America. The Department is also streamlining its Rural Energy for America program to provide grants and loan guarantees directly to agricultural producers and rural small businesses for energy efficiency and renewable energy systems.

    The Department of Housing and Urban Development’s efforts include a $23-million Multifamily Energy Innovation Fund designed to enable affordable housing providers, technology firms, academic institutions, and philanthropic organizations to test new approaches to deliver cost-effective residential energy.

    The Federal Housing Administration will convene representatives of the lending community and other key stakeholders for a mortgage roundtable in July to identify options for factoring energy efficiency into the mortgage underwriting and appraisal process upon sale or refinancing of new or existing homes.

  • Expanding the Better Buildings Challenge. The Better Buildings Challenge targets helping American commercial and industrial buildings becoming at least 20% more energy efficient by 2020. The Administration will expand the program to multifamily housing. In addition, the Administration is launching the Better Buildings Accelerators, a new track that will support and encourage adoption of State and local policies to cut energy waste, building on the momentum of ongoing efforts at that level.

The plan also outlines a series of actions against non-CO2 greenhouse gas emissions:

  • Hydrofluorocarbons. Hydrofluorocarbons (HFCs), which are primarily used for refrigeration and air conditioning, are potent greenhouse gases. In the United States, emissions of HFCs are expected to nearly triple by 2030, and double from current levels of 1.5% of greenhouse gas emissions to 3% by 2020.

    EPA will use its authority through the Significant New Alternatives Policy Program to encourage private sector investment in low-emissions technology by identifying and approving climate-friendly chemicals while prohibiting certain uses of the most harmful chemical alternatives. In addition, the President has directed his Administration to purchase cleaner alternatives to HFCs whenever feasible and transition over time to equipment that uses safer and more sustainable alternatives.

  • Methane. Methane currently accounts for roughly 9% of domestic greenhouse gas emissions and has a global warming potential that is more than 20 times greater than carbon dioxide. Since 1990, methane emissions in the United States have decreased by 8%.

    Under the President’s plan, EPA and the Departments of Agriculture, Energy, Interior, Labor, and Transportation will develop an interagency methane strategy. The group will focus on assessing current emissions data, addressing data gaps, identifying technologies and best practices for reducing emissions, and identifying existing authorities and incentive-based opportunities to reduce methane emissions.

    As part of the effort to develop an interagency methane strategy, the Obama Administration will work collaboratively with state governments, as well as the private sector, to reduce emissions across multiple sectors, improve air quality, and achieve public health and economic benefits.

Preparing the US for the impacts of climate change. The Administration will expand its current efforts to support adaptation into three major, interrelated initiatives: building stronger and safer communities and infrastructure; protecting the economy and natural resources; and managing climate impacts through advancing “the science of climate management”.

Among the many elements of this segment are:

  • Directing agencies to support climate-resilient investment;
  • Establishing a state, local, and tribal leaders task force on climate preparedness;
  • Supporting communities as they prepare for climate impacts;
  • Boosting the resilience of buildings and infrastructure;
  • Rebuilding and learning from Hurricane Sandy;
  • Identifying vulnerabilities of key sectors to climate change;
  • Promoting resilience in the health sector;
  • Promoting insurance leadership for climate safety;
  • Conserving land and water resources;
  • Maintaining agricultural sustainability;
  • Managing drought;
  • Reducing wildfire risks;
  • Preparing for future floods;
  • Developing actionable climate science (proposed $2.7 billion in FY 2014 budget);
  • Assessing climate-change impacts in the United States;
  • Launching a climate data initiative; and
  • Providing a toolkit for climate resilience.

Leading international efforts for GHG emission reductions and adaptation. The Obama Administration is proposing building on the 2009 Major Economies Forum on Energy and Climate by launching a major initiative this year focused on further accelerating efficiency gains in the buildings sector, which accounts for approximately one-third of global carbon pollutions from the energy sector.

The Administration will also seek to expand bilateral cooperation with major emerging economies. The Administration is also working with partner countries to put in place the systems and institutions necessary to reduce global land-use-related emissions.

The Administration will work towards greater penetration of renewables in the global energy mix on both a small and large scale, including through its participation in the Sustainable Energy for All Initiative and accelerating the commercialization of renewable mini-grids. Other efforts will include:

  • Natural Gas. Burning natural gas is about one-half as carbon-intensive as coal, which can make it a “bridge fuel” for many countries as the world transitions to even cleaner sources of energy. Toward that end, the Obama Administration is partnering with states and private companies to exchange lessons learned with international partners on responsible development of natural gas resources.

    The Unconventional Gas Technical Engagement Program shares best practices on issues such as water management, methane emissions, air quality, permitting, contracting, and pricing to help increase global gas supplies and facilitate development of the associated infrastructure that brings them to market.

    Going forward, the Administration will promote fuel-switching from coal to gas for electricity production and encourage the development of a global market for gas. Since heavy-duty vehicles are expected to account for 40% of increased oil use through 2030, it will encourage the adoption of heavy duty natural gas vehicles as well.

  • Nuclear Power. The United States will continue to promote the safe and secure use of nuclear power worldwide through a variety of bilateral and multilateral engagements.

  • Coal. The United States works with China, India, and other countries that currently rely heavily on coal for power generation to advance the development and deployment of cleaner coal technologies. In addition, the US leads the Carbon Sequestration Leadership Forum, which engages 23 other countries and economies on carbon capture and sequestration technologies. Going forward, the Administration will continue to use these bilateral and multilateral efforts to promote advanced coal technologies.

  • Energy Efficiency. The Obama Administration will work to expand its energy efficiency efforts focusing on several critical areas, including: improving building efficiency, reducing energy consumption at water and wastewater treatment facilities, and expanding global appliance standards.

The US will also work with trading partners to launch negotiations at the World Trade Organization towards global free trade in environmental goods, including clean energy technologies such as solar, wind, hydro and geothermal. It will also work in the Trade in Services Agreement negotiations towards achieving free trade in environmental services.

Other efforts include collaborating with partners around the world on eliminating fossil fuel tax subsidies; leading global sector public financing towards cleaner energy; and strengthening global resilience to climate change.

Comments

HarveyD

Pro-fossil fuel people will not like this multi- approach common sense plan to reduce pollution and increase energy efficiency etc.

Shale Gas extraction side effects will have to be better managed.

photosymbiont

The concept of the sequestration of carbon dioxide from coal power plant emissions is not backed up by scientific facts or engineering demonstrations.

The energy costs involved are so great that they would consume all the power produced by the coal plant - which is why nobody has ever built a working stand-alone prototype, not even one based on natural gas, which produces a good deal more energy per CO2 emitted (due to more C-H than C-C bonds).

That such unscientific notions should persist within the DOE, and be promoted by Bush and Obama (both have called for 'zero-emission' coal plants) is deeply disturbing. Something's gone wrong with independent science at the DOE.

Kit P

Nothing new here! Same old ineffective plan that will be ignored by everyone. I would be impressed if Obama could get China, India, Indonesia, and Brazil to name a few to stop building coal plants like hot cakes.

Oddest thing happens when you let people have electricity. Next thing they want is a double door fridge with an ice dispenser. The US just set a record for coal exports.

Engineer-Poet

Good!  That means the USA can start making some serious money from coal severance taxes.

HarveyD

Coal Producers Associations will never allow it.

Darius

In US lot of oil is used for heating. No word about that. It is so easy to replace it with biomass or NG. It would be small but real step of administration.

Only real alternative to mass coal incineration is nuclear. Too little emphasis on that direction and too much on 'clean coal'.

HarveyD

Alternatively, USA could use NG power plants (instead of coal fired power plants) + increased grid capacity and use SEER 26+ heat pumps for 75+ % of domestic heating and cooling.

Since HVAC can be reduced over night, the unused e-energy could charge many million electrified vehicles.

Kit P

"Coal Producers Associations will never allow it."

We have something in the US called the rule of law. POTUS has forgot about congress.

Aaron Turpen

Is this is same stupid Obama plan that couldn't get the number of counties in Hawaii right and the one that thinks that a 0.00004% increase in asthma attacks is somehow significant?

Ya, thanks but no thanks. I think we need someone intelligent and capable of basic research (at least the ability to Google, for hell's sakes) making decisions. Not that chump.

Trevor Carlson

How we approach residential energy use and efficiency will have the greatest impact.

The logical and pragmatic home-owners that have to pay full price for an alternative energy source will first reduce their energy need, maximize efficiency to the point that their lifestyle is changed before calculating and sizing their PV, wind, or hydro electricity generators.
That approach should be the preferred approach to promote with any legislation that encourages investment or provides grants.

The following doesn't do a lot to clear the approach up.

"The Department of Housing and Urban Development’s efforts include a $23-million Multifamily Energy Innovation Fund designed to enable affordable housing providers, technology firms, academic institutions, and philanthropic organizations to test new approaches to deliver cost-effective residential energy.

The Federal Housing Administration will convene representatives of the lending community and other key stakeholders for a mortgage roundtable in July to identify options for factoring energy efficiency into the mortgage underwriting and appraisal process upon sale or refinancing of new or existing homes."

How do they intend to "deliver cost-effective residential energy"? It doesn't specify more or less cost-effective and for whom, so these new approaches might be able to claim success by increasing the price of energy causing people to conserve more.

$23M is not a lot of money when you consider all the types of building in all the different climates for energy innovation of multi-family projects. Is that per month? Or is that a trust fund that only 5% of it will be available for projects per year?

I guess it doesn't matter because congress will have to approve of the "efforts" of HUD to grab more tax money. While I support the goal I have no confidence in any central planning administration to deliver cost effective results. The best approach would free the marketplace to find the most cost effective alternatives not dictate what projects get what level of funding.

ai_vin

POTUS has forgot about congress.

That is so funny.

Kit P

“That is so funny. ”

As sad as it might sound, a Canadian might be better informed about how American government than most of those born in the US. The first mistake Obama made was putting anti-coal legislation before congress that could not pass. Second Obama made numerous anti-coal statements during political speeches. Legislation that targets coal arbitrarily will get thrown out of court.

When Clinton targeted coal through the courts he failed. When Bush pushed and passed regulations on old power plants, the result was many old coal plants were shutdown.

ai_vin

No, it's funny because before President elect Obama even took office the Republicans had a plot to obstruct him reguardless of anything he offered. They put Party before Country. In secret meetings led by House GOP whip Eric Cantor and Senate minority leader Mitch McConnell in which they laid out their daring (though cynical and political) no-honeymoon strategy of all-out resistance to the popular President-elect during an economic emergency. “If he was for it,” former Ohio Senator George Voinovich explained, “we had to be against it.” Obama even went so far as to give them what they asked, use their ideas, and they still said "no."

Kit P

“reguardless of anything he offered ”

When it comes to energy and the environment Obama is all talk. He failed to offer up any substantive plan.

“put Party before Country ”

Obama stopped the scientific review by the NRC of the geological repository for high level nuclear waste in Nye County Nevada. Nye County Nevada supported the facility. Can anyone think of a better place to put waste than next to where we test nuclear weapons?

Obama owed Harry Reid who owes his office to gambling and prostitute interests. It called putting self before your party and your country.

ai_vin

Coal and the Bush Administration

Coal industry executives placed their bets on George W. Bush during the 2000 presidential campaign. Among others, Peabody Energy contributed $250,000 to the Republican National Committee in July 2000; West Virginia coal executive James "Buck" Harless gave $200,000 directly to Bush's campaign, while Peabody Energy and The Southern Company gave hundreds of thousands more. Also, during the 2000 elections, Peabody Energy, Burlington Northern, and The Southern Company founded Americans for Balanced Energy Choices, which kicked off a multimillion-dollar advertising campaign designed to promote coal energy and counter the influence of environmental groups.[1]

The coal industry's wager on Bush proved highly successful. In his first few months as president, Bush abandoned his campaign promise to force coal plants to reduce carbon emissions, appointed Irl Engelhardt (chairman of Peabody Energy) as an energy advisor to his transition team, and named former coal industry lobbyist J. Steven Griles Deputy Secretary of the Interior.[1](Griles resigned from this position in December 2004; in 2007, he pled guilty to obstruction of justice in the Jack Abramoff lobbying scandal, and was sentenced to ten months in prison.)

Bush also cut the budget of the Environmental Protection Agency from $8.1 billion in 2001 to $7.1 billion in 2008. These budget cuts dramatically limited the EPA's ability to enforce violations of the Clean Air Act: the number of civil suits by the EPA against polluters decreased by 70% between 2002 and 2006, and by late 2007 the EPA was employing only 172 criminal investigators, fewer than the legal minimum of 200 set by President George H.W. Bush. (Eric Schaeffer, the former head of the EPA's Office of Civil Enforcement, resigned in 2002 in protest of Bush's approach to environmental enforcement.)[15][16]

Perhaps most importantly, until 2007 President Bush refused - in the face of overwhelming scientific consensus[17] - to acknowledge that global climate change was caused by human activities. In June 2002, when the Bush Administration's Environmental Protection Agency stated that human activities were partly responsible for global climate change, Bush dismissed the report, calling it a product of "bureaucracy."[18] In October 2004, NASA scientist James Hansen strongly criticized the Bush Administration's approach to climate change policy, stating that "in my more than three decades in government, I have never seen anything approaching the degree to which information flow from scientists to the public has been screened and controlled as it is now."[19] In 2007, Bush began to acknowledge somewhat openly that global climate change was both a real phenomenon and was largely caused by human activities.[20] However, the Bush Administration continued to oppose mandatory limits on carbon emissions, and the U.S. delegation obstructed the adoption of any meaningful global climate change plans at the December 2007 United Nations Climate Change Conference in Bali, Indonesia.[21]

In late 2008, the Bush Administration began pressuring the Environmental Protection Agency to weaken pollution regulations for coal plants and allow them to increase emissions without adding controls. The new rules are tied to a plant's hourly emissions rate, and are intended to help extend the life span of older power plants without requiring them to install expensive pollution controls. Under the proposed regulations, even if a power plant's total yearly emissions increased, it would be considered to be running more cleanly if its hourly emissions were equal to or less than its historical maximum.[22]

A spokesman for the EPA said that the agency is committed to finalizing the rule by the time Bush leaves office in January 2009. Power companies have lobbied for weakened emissions regulations for many years, and the proposal was part of Vice President Dick Cheney's 2001 energy plan. The EPA is also considering another eleventh-hour rule that would permit more power plants to be built close to national parks and wilderness areas.[23]

The coal boom

This considerably more coal-friendly regulatory environment under the Bush Administration - combined with rising oil prices and volatile natural gas prices (the U.S. price of a barrel of crude oil rose from $21.77 in Jan. 2001 to $88.41 in Jan. 2008,[24] while the price of natural gas fluctuated wildly and unpredictably during that same period[25]) - resulted in a dramatic expansion in utility plans for new coal-fired power plants.

Between 1992 and 2006, the capacity of all new U.S. coal-fired power plants totaled approximately 8,500 megawatts, a fairly modest amount of construction.[26] However, soon after Bush's presidency began - and especially after large increases in natural gas prices - energy utilities began submitting an increasing number of [proposals for new coal-fired power plants]. In October 2007, a report by the U.S. Department of Energy's National Energy Technology Laboratory found that 45 coal-fired plants, with a total capacity of 23,240 megawatts, were either under construction or had already been approved by regulators; a further 76 plants, with a total capacity of 48,440 megawatts, were in various stages of the development process.[27] This total potential capacity of 71,680 megawatts represented 743% increase over the total capacity of 8,500 megawatts of all plants built between 1992 and 2006. Financial advisors, reporters, and environmentalists alike began to speak of a new "coal boom."[28][29][30][31]

Growing environmental backlash

However, during Bush's second presidential term, a rapidly growing proportion of the U.S. population began to view global climate change with increasing concern. According to a 2007 Yale University study, 56% of Americans considered global warming to be a very serious problem, compared with 40% in 2004; the 2007 poll also found that 68% of Americans agreed that global warming can be controlled by human actions. Furthermore, the study reported that that 86% of Americans thought that it was a good idea to increase funding for renewable energy research - and that 76% of Americans said that they trusted scientists at major universities on environmental issues, compared with 38% who said that they trusted President Bush.[2]

Hurricane Katrina - which killed 1,836 people and caused roughly $81.2 billion in damage when it hit coastal Louisiana and Mississippi in August 2005 - was a major factor in causing this shift in public opinion. According to a 2006 Zogby poll, 74% of Americans said that they were more convinced that global warming was a reality then than they had been in 2004, and 68% thought that global climate change was partly responsible for causing the hurricane.[32] This shift in public opinion was further bolstered in October 2007, when former U.S. Vice-President Al Gore was awarded the Nobel Peace Prize for his campaign in favor of governmental action to limit greenhouse gas emissions.

This shift in public opinion on climate change more generally has also translated into increasing support for the growing movement against coal-fired power plants in the U.S. An October 2007 poll by the Opinion Research Corporation found that 75% of Americans would support a five-year moratorium on new coal-fired power plants if it was accompanied by increased investment in renewable power research; when asked what type of energy they would prefer their utility to use to power their house, only 3% opted for coal-fired power.[33] (This increasing tendency to blame coal-fired power plants for contributing to global climate change is strongly scientifically supported: the 2.12 billion metric tons of carbon dioxide emitted by U.S. coal-fired power plants in 2006 represented 36.1% of U.S. carbon dioxide emissions, and 7.8% of global carbon dioxide emissions.[34])

Along with this shift in public opinion, campaigns organized by a growing grassroots movement against the construction of new coal-fired power plants has forced many corporations and politicians to abandon new coal-fired power projects.[5] Numerous environmental groups - such as the Sierra Club, Rainforest Action Network, Rising Tide, Clean Energy Action, Mountain Justice Summer, and Earth First!, as well as smaller local groups - have organized high profile protests and direct actions against new and existing coal-fired power plants.[5] The result has been a slough of recent plant cancellations: during 2007, 59 coal-fired power projects, with a total planned capacity of at least 28,364 megawatts, were cancelled or put on hold indefinitely. The general public has often strongly supported these cancellations: for instance, after the recent high-profile cancellation of Sunflower Energy's Holcomb Power Plant expansion by state environmental regulators in October 2007 due to concerns about global warming, a poll of Kansans found that 62% agreed with the decision to cancel the expansion.[4] Also, a recent poll of Iowans found that 80% thought that state regulators should focus on energy conservation and fuel efficiency, rather than approving new coal-fired power plants.[3]

http://www.sourcewatch.org/index.php/U.S._coal_politics#Coal_and_the_Bush_Administration

ai_vin

http://www.huffingtonpost.com/2012/01/26/coal-power-plants-closing-firstenergy_n_1234611.html

The Obama administration was under court order to issue a new rule, after a court threw out an attempt by the Bush administration to exempt power plants from controls for toxic air pollution.

Two factors have made it easier for utilities to shut old coal plants in recent years. Power demand has been weakening in recent years because of the slow economy and energy efficiency programs. And natural gas prices, which have fallen to decade-low levels in recent weeks, have allowed utilities to switch from coal to natural gas without impacting customer bills. Meanwhile, demand from China and elsewhere has driven up the price of coal.

Kit P

The Huffinton Post and sourcewatch are not credible sources of information. A Candian want to explian US policy based on reading junk.

ai_vin

Show me your sources.

Kit P

"Show me your sources."

What fact that I presented did you not agree with?

That tactic of long unrelated cut and paste blaming someone other than the current POTUS is odd.

ai_vin

Predictable.

Kit P

"Predictable."

I have asked before but ai vin refuses to answer. Where do you work?

You made a claim about working but won't tell what you do. Cashing your government welfare check is not work.

I predict that ai vin will continue to make unfounded snide remarks about productive people.

HarveyD

KitP ...the most productive people are the Chinese workers.

They built a 42 Km bridge in 24 months for less than $1.5B. The same bridge would have cost at least 5X more in USA and close to 10X more in Canada due to lower worker's productivity mainly due to our higher pay. Secondly, it would have taken 2X to 3X longer.

They are also building over 10,000 Km/year of high speed rails and high speed e-trains. We take more than 15 years to build 100 Km at 10X+ the building cost.

Chinese workers can make a dress shirt for $1.17 while we need $11.50 for the same piece of work. The productivity ratio is almost 10:1 in favor of the Chinese worker.

Walmart, Target, Costco etc know the difference and that's why they sell many $$B of mostly Made in China goods.

ai_vin

I refuse to answer insults. So instead I'll see if we can't get this back on topic: If anybody is still interested in why Obama has to work around Congress instead of with it;

http://thinkprogress.org/climate/2013/06/26/2202141/the-anti-science-climate-denier-caucus-113th-congress-edition/

And here's a list of their statements showing their denial;

http://thinkprogress.org/climate-denier-caucus/

Kit P

“KitP ...the most productive people are the Chinese workers. ”

I do not think Harvey understands productivity. For example, if I had a business where invested a chain saw, hydraulic splinter, a pickup truck, I could supply about a 100 homes with heat assuming they had efficient wood stoves. At my fist nuke plant we supplied power to a million homes so it worked out to about 1000 homes per worker. Now with improvements in productivity is more like 2000 homes.

Because I am more productive, I can be paid more.

American farmers and coal miners are very productive. I vested a family dairy farm owned by two brothers that had 1000 cows compared to 100 cow on the dairy farm that my wife grew up on. Another friend had a farm down the road. Modern farms use computers to manage details to increase productivity.

Food and energy is a small fraction of the family budget in productive countries. As the per capita GDP of China (current very low) increase, people can afford more meat. American farmers sell cheap animal feed which is a coproduct of ethanol production.

The key to productivity is electricity. Targeting the production of power with coal is national suicide.

Engineer-Poet

The original vision of nuclear power was to target steam coal... by under-pricing it.

It worked until the coal interests managed to hobble nuclear with many regulations with some effect on safety, but massive effects on cost.

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