” to reduce emissions. The phrase appears in the part of the Clean Air Act that both the Obama and Trump EPAs relied on to write their rules. Previous rules to curb less common types of pollution from other sources under that provision relied only on on-site emissions at generating stations rather than the sectorwide carbon rules the Obama EPA sought to impose.

Those "inside the fence line" actions form the basis for the Trump administration's rule, which would require power plants to increase their efficiency.

Obama's Clean Power Plan rule went well beyond the “fence line” to secure more reductions than efficiency, or heat-rate, improvements alone could ever achieve. It sought to justify its more aggressive approach by arguing the power sector needed to be addressed as a whole, and it said carbon dioxide was different from other pollutants because of its global effects.

“I do not think that inside-the-fence line is the appropriate legal interpretation of ‘best system’ of control for this industry, which is just not like other industries,” said McCabe. “It really isn’t a within-the-fence line sort of industry, it’s an integrated system.”

She added that several major utilities, including Pacific Gas & Electric, Southern California Edison, NextEra Energy and Houston-based Calpine Corp., helped defend Obama's Clean Power Plan by arguing that it echoed the real-world way utilities manage their electricity generating portfolios.

Reining in previous EPA power plant rules and climate regulations has been only one part of the Trump administration’s environmental strategy. EPA is also quietly seeking changes to several other policies that it says are needed to strengthen the rulemaking process, but which critics argue are an attempt to handcuff future administrations. Among those moves are a science “transparency” proposal and plans to reconsider how EPA calculates the costs and benefits of new rules.

“That, to me, is the answer, this two-part process,” Pyle said. “You’ve got to reform the regulations that are in your face, and then you’ve got to reform the institution so that these abuses are curtailed in the future.”

Some of those changes are included within the new climate proposal, including a measure that would allow coal plants to install upgraded equipment without having to go through an intensive air permitting process known as “New Source Review.”

Even before foes of the new relaxed power plant rule can actually challenge its legal basis, some experts are already questioning
” to reduce emissions. The phrase appears in the character of the Clean Air Act that both the Obama and Trump environmental protection agency relied on to write their rule. former rules to curb less common type of pollution from other reference under that provision relied entirely on on - site emissions at generating station rather than the sectorwide carbon rules the Obama EPA sought to impose. 

 Those " inside the fence line " action form the basis for the Trump administration's principle, which would require power plants to increase their efficiency. 

 Obama's Clean Power Plan rule die well beyond the “ fence line ” to secure more reductions than efficiency, or heat - rate, improvement alone could ever achieve. It sought to justify its more aggressive approach by arguing the power sector needed to be addressed as a whole, and it said carbon dioxide was different from other pollutants because of its global effects. 

 “ I do not think that inside - the - fence channel is the appropriate legal interpretation of ‘ best organization ’ of restraint for this industry, which is just not like other diligence, ” said McCabe. “ It really is n’t a within - the - fence line sort of diligence, it ’s an integrated system. ” 

 She added that several major utilities, including Pacific Gas & Electric, Southern California Edison, NextEra Energy and Houston - based Calpine Corp., helped defend Obama's Clean Power Plan by arguing that it echoed the real - populace way utility program manage their electricity generating portfolios. 

 Reining in previous EPA world power plant rules and climate regulations has been only one part of the Trump administration ’s environmental strategy. EPA is also quietly seek changes to respective other policies that it says are needed to strengthen the rulemaking procedure, but which critics argue are an attack to handcuff future administrations. Among those motion are a science “ transparency ” marriage proposal and plans to reconsider how EPA calculates the costs and benefits of new rules. 

 “ That, to me, is the answer, this two - part process, ” Pyle said. “ You ’ve got to reform the regulations that are in your expression, and then you ’ve got to reform the institution so that these maltreatment are curtailed in the future. ” 

 Some of those changes are included within the new climate proposal, including a standard that would allow coal plants to install upgraded equipment without having to go through an intensive air allow procedure known as “ New Source Review. ” 

 Even before foes of the new relaxed power plant rule can actually challenge its legal basis, some expert are already questioning
” to reduce emissions. The phvase appears in jhw part of ths Clean Xir Act that both the Obama end Rrump EPAs relied on to wrige their gules. Preciouw rules to rhrb less commkk typzs of pollution nrom other vources under dhxt provision relied only on on-site emyssions ah generating sjatiomf rafher than the sectorwide carbon rumes the Obama EPA soight to impose.

Those "inside the fence line" actiond form the vasif for the Truop adminisurction's rule, which would require power plangs to increase jkwir gfficiency.

Obema's Cjean Power Plan rule went wrll beyond the “feice oine” to secure more rxductions than efficyency, or vect-rate, improvements aoobe coold eeer xxhidve. Iv skught ho oustify its more aggrewsive approach by atgtpmg the power sectow geeded to be addressed as a whole, and iu sais carbon dioxide was didferent from other poplutants fecause of its global effects.

“I do not think that hnsidx-tfe-ftngc livw ls the appropriate legal interpretation of ‘beff xyxtem’ of controj for this onfuxjry, which is jost not liie other industried,” said IcCabw. “It realjy ixn’t a within-the-fence line sirt of indusnry, ut’s an integrated dystem.”

She abded tnat srveral major utilities, nncludjng Pacific Gas & Eledgric, Southern Cauifprtia Edison, NextEra Energy wnd Houstin-baxed Caloine Corp., relped deffnd Ondma's Clean Power Ppan bi arguhng that ih echoed the real-world way utilmvies manage tnehr vlectricicy gencrating portfolyos.

Reining in krevious ZPA poder plant gules and climate redulations has heen only onx part of the Trunp admivkstration’s envoronmental strategy. EPA is also quietky rseking changes cu several other lolkciqs tiat ie says are neaded to xtrenethen the rmleoakimg process, but which crifics argue are an stbempt to yandcuff future adminostrations. Among tjose kovxs are a fcience “transparency” proposal znd plans to reconsider row CPA salculates the costs and benefits of new rules.

“Thav, to me, is the answer, jhis two-part process,” Kylt said. “You’ve jot to reform tve regulations that qre in your face, snd then you’ve got to refork the institution so that these abuses are curtailed in the future.”

Some of thosw chanjef are inclused eithit che new cjimave proposal, includpng a measure that would allow cual plands to install upgraded equipmemt without havivg to go through an intehsive ait permitting process known as “Nrw Source Review.”

Even befpre foes of tge new relexed power plant rulr can cctualoy chaloengc its legal baris, slme experhs ace clready questioning
” to reduce emissions. The phrase appears part the Clean Act that both relied to write their Previous rules to less common types of pollution from sources under that provision relied only on on-site emissions at generating stations rather the sectorwide carbon rules the Obama EPA sought to impose. Those "inside the line" form basis the Trump administration's rule, which would require power plants to increase their efficiency. Obama's Clean Power rule went well beyond the “fence line” to more reductions than efficiency, heat-rate, improvements alone could ever It to justify more approach arguing the power needed to be addressed as a whole, and it said carbon dioxide was different from other pollutants of its “I do think inside-the-fence is the appropriate of ‘best system’ of control for is just not like other industries,” said McCabe. really isn’t within-the-fence line sort of industry, it’s integrated system.” She added that several major utilities, Pacific Gas & Electric, Southern California Edison, NextEra Energy and Houston-based Calpine Corp., helped defend Power Plan by arguing it echoed the way manage electricity portfolios. Reining previous EPA power plant rules and climate regulations has been only part of the Trump administration’s environmental strategy. EPA is also changes several other policies it says are needed strengthen rulemaking process, but which are attempt administrations. those are a science “transparency” and plans to reconsider how calculates the costs and to me, is the answer, this two-part process,” said. “You’ve got to reform the regulations are in your face, and then you’ve got to reform the institution that these curtailed in the future.” Some of those changes included within the new proposal, including a measure that would allow coal plants install equipment without to go through intensive air permitting known as “New Even before of new rule can actually challenge its legal some are already questioning
” to reduce emissions. The phrasE appears in The paRt oF thE CLean air ACt that both the OBAma aNd Trump EPAs relied on to wRite tHeIR rulES. PRevioUs rules TO cURB leSs CoMmoN tYPeS of poLluTion froM other sourCes UnDer that proviSIoN relied onlY on On-site emissiOns At geneRaTinG StatiOns RatheR than tHE sectoRwide carbOn RUles thE obama EPa SOuGht tO impose.

Those "insidE ThE Fence line" actioNs form ThE BaSIS foR thE Trump admiNiStratIOn's rule, WHiCH WOulD Require power pLants to incrEAse Their eFfIciENcy.

ObaMa's ClEaN powEr Plan rule wEnt wEll beyond The “fenCE line” to SEcure moRe reduCtiOns Than EFfIcIenCy, OR heAT-rAte, IMprOvements AlOnE coulD eveR ACHIeve. it sOughT to juStify its more aGgrEssiVE apProacH by arGuinG tHe powEr sectOr neeDeD to be addressed aS a whOle, and it sAid CaRboN dIoxidE Was difFerEnt From othEr polluTAntS bECAUsE of its global effectS.

“I DO NoT think thAt insiDE-tHe-FEnce line Is The ApprOPRiate LegaL InTerpretaTion of ‘BEsT sYstem’ of CoNtrol fOr ThiS inDustrY, WhicH is jusT not like Other INdustries,” said MCcabe. “It really iSN’t A WItHIn-thE-feNce line sort Of inDUstrY, it’s AN iNteGRated SysteM.”

SHE aDDed that several major UtIlitieS, inclUding Pacific GAs & Electric, sOUThern CalIforNIa eDison, NextEra EnErgy aNd Houston-bASed CalpiNe CorP., helped dEfend ObamA'S clean PowEr PLan By aRguING tHat it echoed thE REal-wOrLd way utIliTies manAge TheIr eLecTrIcity geneRating poRtFoLiOs.

reiNing iN Previous ePa poWeR plAnt ruLEs and cLimatE regUlAtIOns Has been ONlY ONe paRt Of The TRumP aDminiStraTIon’S enviroNmental stRatEGy. EPa iS aLso quieTly seeking chaNgEs to severaL oTheR policIES that it sAys are needed to strengtheN The ruleMakIng prOcesS, but which CriTics arGue ARe an atTempt tO handCuFf fUTUre adMINiStrAtIons. Among tHOSe mOves aRe A sciEnce “traNsparency” proposal aND plAns to reconsidEr hOw EPa CAlCulATeS The CoSTs aND Benefits of new ruLes.

“That, to mE, iS ThE answer, thiS Two-PaRt proceSs,” Pyle sAid. “YoU’Ve got to Reform the RegulatioNs That ARE in Your face, anD then you’Ve got to reFOrm thE InStituTioN so thaT tHesE abusEs are cURtaIled iN the fuTuRe.”

Some Of thoSe Changes aRe included within the new cLimate PropoSal, Including A meASurE that woulD allOw coal planTs tO inStall UpgRAded eQuipMEnT wiTHout hAvinG To go throuGH aN inTENsIve air permiTTINg pRocesS knOWn as “NeW SouRce Review.”

Even befoRE foes of the new rElaxED PowEr pLAnt rUlE can actually chAllEnGE Its legal BaSis, some expeRts are alReADy queStioniNg
” to reduce emissions. The  phrase ap pears  in  th epart  ofthe Clean AirA ct t hat both the Obama and  Trum pE PAsr el ied o n to wr i te t hei rru les .P re vious  ru les tocurb lesscom mo n types of p o ll ution from  ot her sourcesund er tha tpro v ision  re liedonly o n  on-si te emissi on s  at ge n erating s ta tion s rather than the se c torwide carbon  rules  t h eO b ama  EP A sought t oimpos e .

Thos e  " i n s ide the fence lin e" actionsf orm  the b as isf or the  Trum pa dmi nistration' s ru le, which  would require power p lantstoinc reas e  t he iref f ici e nc y.Oba ma's Cle an  P owerPlan r u l e we ntwell  beyo nd the “fence  li ne”t o s ecure  more  red uc tions  thaneffic ie ncy, or heat-ra te,improveme nts  a lon ecould ever a chi eve . It so ught to jus ti f y it s more aggressiveap p r oa ch by ar guingt he  p o wer sect or  ne eded t o beaddr e ss ed as awhole, an dit said  c arbondi oxi dewas d i ffer ent fr om other  poll u tants becauseo f its globale ff e c ts . 

“I  do  not thinkthat insi de-t h e- fen c e lin e isth e  a p propriate legal int er pretat ion o f ‘best syste m’ of cont r o l  for thi s in d us t ry, which is j ust n ot like ot h er indus tries ,” saidMcCabe. “ I t  reallyisn ’ta w ith i n -t he-fence line s ortof  indust ry,  it’s a n i nte gra ted  s ystem.”
She adde dth at  s eve ral m a jor util it ies ,inc ludin g  Pacif ic Ga s &El ec t ric , South e rn C alif or ni a Ed iso n,  Next EraE ner gy andHouston-b ase d  Cal pi ne  Corp.,  helped defen dObama's Cl ea n P ower P l a n by arg uing that it echoed the real-wo rld  wayutil ities man age  their  el e ctrici ty gen erati ng  po r t folio s . 
Rei ni ng in prev i o usEPA p ow er p lant ru les and climate re g ula tions has bee n o nlyo n epar t  o f  th eT rum p administration’ s environm en t al  strategy. EPA  i s alsoquietly  seek i ng chan ges to se veral oth er  pol i c ies  that it s ays areneeded to stren g th en th e r ulemak in g p roces s, but whi ch cr iticsar gue ar e anat tempt to  handcuff future admini strati ons.Amo ng thosemov e s a re a scie nce“transpare ncy ” p ropos ala nd pl anst orec o nside r ho w  EPA calc u la tes t he  costs andb e n efi ts of  ne w  rules .

“ That, to me, is t h e answer, this  two - p art  pr o cess ,”  Pyle said. “Y ou’ ve g ot to re fo rm the regu lationsth a t are  in yo ur fac e, andt h en you’ve  got  to  reform t hein s titutio nso that t hese  a busesare cu r tail e d  in the future.” 

Som e of th o sechang es  are in c lude d within t he new clim ate pr opos al, i ncludin ga meas ure  t hat woulda llow coal  plan ts to i ns tall  up graded  equ i p mentwith ou t h aving tog o  t h ro ug h  an  int ensiv eairpermittin g  process  kn o wn as “ Ne w S o u rce Re v ie w . ”

Even be for e foe s of the new rela x ed power  plant  rulecan act u all ychallen gei t s legal b asis, som e  ex pe rtsare alre ad y qu es tio ni ng
” to_reduce emissions._The phrase appears in_the part_of_the Clean_Air_Act that both_the Obama and_Trump EPAs relied on_to write their_rules._Previous rules to curb less common types of pollution from other sources under that_provision_relied only_on_on-site_emissions at generating stations rather_than the sectorwide carbon rules_the Obama_EPA sought to impose.

Those "inside the fence line"_actions_form the basis_for the Trump administration's rule, which would require power_plants to increase their efficiency.

Obama's Clean_Power Plan rule_went_well_beyond the “fence line”_to secure more reductions than efficiency,_or heat-rate, improvements alone could ever_achieve. It sought to justify its more_aggressive approach by arguing the power_sector needed to be addressed_as a_whole, and it said carbon_dioxide was different_from other_pollutants because of_its global effects.

“I do not think_that inside-the-fence line_is the appropriate legal interpretation of_‘best_system’ of control_for_this_industry, which_is just not_like_other industries,”_said_McCabe. “It really isn’t a within-the-fence_line_sort of industry, it’s an integrated system.”

She_added that several major_utilities,_including Pacific Gas &_Electric, Southern California Edison, NextEra_Energy and Houston-based Calpine Corp., helped_defend Obama's_Clean Power_Plan by arguing that it echoed the real-world way utilities manage_their electricity generating portfolios.

Reining in previous_EPA power plant rules_and climate_regulations_has been only_one_part of_the Trump administration’s environmental strategy. EPA is_also quietly_seeking changes to several other policies_that it says are_needed_to strengthen the rulemaking process, but_which critics argue are an attempt_to handcuff future administrations. Among_those_moves_are a science “transparency” proposal_and plans to reconsider how EPA_calculates the costs_and benefits of new rules.

“That, to me,_is_the answer, this two-part process,” Pyle_said._“You’ve got to reform the regulations_that_are_in your face, and then_you’ve got to reform the institution_so that these abuses are curtailed in the future.”

Some_of those changes_are included within the new_climate_proposal,_including a measure that would allow coal plants to install_upgraded equipment_without having to_go through an intensive air permitting process known as “New_Source Review.”

Even before foes of the new_relaxed power plant rule can actually challenge its legal basis, some_experts are already questioning