Flemming: Even without TCI, cap-and-invest still looms large

By David Flemming

Last week, Jared Duval a member of the Climate Council and the Energy Action Network, testified virtually to the Senate Natural Resources and Energy Committee.

One striking admission: carbon taxes don’t work. “Carbon pricing has been really has historically proven ineffective at reducing fossil fuel use because people’s demand for those fuels is highly inelastic and it … can be very regressive. Having lower income and rural folks paying a higher share of that transition which is something that that we do not want,” he said.

David Flemming, policy analyst at the Ethan Allen Institute

Highly inelastic demand means Vermonters don’t drastically change the quantity of fossil fuels they purchase after a tax increase. Transportation and heat are not luxuries for most people on the lower income bracket. They are necessities.

Duval brought up the Climate Council’s alternative for reducing fossil fuels: “a cap-and-invest strategy which, unlike carbon pricing gives you the clarity of setting an emissions reduction cap that declines over time… the polluters, the fossil fuel suppliers, have to purchase allowances for those emissions. And then those funds go to the participating states to invest in emissions reducing activities.” Duval alludes to the section in the Climate Action Plan, which endorses an immediate requirement for legislative action to authorize the generation and collection of auction revenue from the sale of allowances in a transportation fuel cap and invest program, whether its TCI-P or a comparable approach.”

So, what’s the difference between “Carbon Pricing” and “Cap and Invest”? Both drive up the cost of gas and diesel for the consumer. With a carbon pricing (a straight carbon tax), most plans are sold as “revenue neutral”, meaning the money raised from the carbon tax is used to lower a tax somewhere else. For example, the VPIRG carbon tax of 2015 recommended using the revenue to lower the sales tax. The ESSEX carbon tax of recommended using the revenue to lower electric rates. However, under cap-and-invest, the government keeps the money and spends it on programs it deems important – in this case EV subsidies, charging stations, weatherization, etc. Cap and invest is lose/lose for the taxpayer.

Despite TCI being dead in the water, the Climate Council is still holding out for another “comparable approach.” Only time will tell what that looks like. A statewide credit auction seems most likely.

Under cap-and-invest, gas stations would be coerced into purchasing “allowances for emissions,” to stay in business. These allowances would function quite similarly to a tax. Rather than using a tax to decrease the number of gallons of gas sold, the bureaucracy would set a continuously decreasing number of gallons of gasoline that can be sold in Vermont annually. To obtain permission to sell this gasoline, sellers will enter a state auction.

Increasing the seller’s price ultimately results in an increase in a higher price at the pump. This is especially true when buyers are highly unresponsive to price/tax changes for necessities like gasoline. In such a scenario, economic theory suggests consumers will bear more of the tax burden than suppliers (excluding variables such as state borders).

But the wording of the Climate Plan makes it easy to believe that the government wants to keep this cap-and-invest money to pay for other climate action policies, similar to the first Vermont carbon tax from 2016.

If a statewide auction is set up, gas stations on Vermont’s border will have to consider two hefty competitors with artificial advantages, before they bid for gasoline: 1) centrally located Vermont gas stations, who can afford to pass on more of the government’s burden to their customers because they aren’t competing against out-of-state gas stations and 2) New Hampshire gas stations who currently pay gas taxes at $0.06/gallon less than Vermont, a gap which would grow larger under cap-and-invest. New York gas stations could factor in as well, if the cap-and-trade difference exceeds Vermont’s current $0.15/gallon tax advantage vs. NY.

Any cap-and-invest scheme would eventually make Vermont border gas stations so uncompetitive on price that they would go out of business, long before gasoline is banned entirely. If the cap-and-invest limit becomes zero gallons of gasoline, centrally located Vermont gas stations wouldn’t be far behind. At that point, one wonders if close-to-the-border Vermonters will be the only ones with gasoline powered cars, spending a Saturday drive filling up across the border. Symbols of fossil fuel defiance to the end, when everyone else is stuck with EVs.

To watch Duval’s testimony and comments from senators, click here.

David Flemming is a policy analyst for the Ethan Allen Institute. Reprinted with permission from the Ethan Allen Institute Blog.

Image courtesy of Public domain

6 thoughts on “Flemming: Even without TCI, cap-and-invest still looms large

  1. EXCERPT from:


    THETFORD; July 2, 2021 — A fire destroyed a 2019 Chevy Bolt, 66 kWh battery, battery pack cost about $10,000, or 10000/66 = $152/kWh, EPA range 238 miles, owned by state Rep. Tim Briglin, D-Thetford, Chairman of the House Committee on Energy and Technology.

    He had been driving back and forth from Thetford, VT, to Montpelier, VT, with his EV, about 100 miles via I-89
    He had parked his 2019 Chevy Bolt on the driveway, throughout the winter, per GM recall of Chevy Bolts
    He had plugged his EV into a 240-volt charger.
    His battery was at about 10% charge at start of charging, at 8 PM, and he had charged it to 100% charge at 4 AM; 8 hours of charging.
    Charging over such a wide range is detrimental for the battery. However, it is required for “range-driving”, i.e., making long trips. See Note

    NOTE: Range-driving is an absolute no-no, except on rare occasions, as it would 1) pre-maturely age/damage the battery, 2) reduce range sooner, 3) increase charging loss, and 4) increase kWh/mile, and 5) increase the chance of battery fires.

    Charging at 32F or less
    Li-ions would plate out on the anode each time when charging, especially when such charging occurred at battery temperatures of 32F or less.

    Here is an excellent explanation regarding charging at 32F or less. See URL

    Fire in Driveway: Firefighters were called to Briglin’s house on Tucker Hill Road, around 9 AM Thursday.
    Investigators from the Vermont Department of Public Safety Fire and Explosion Investigation Unit determined:

    1) The fire started in a compartment in the back of the passenger’s side of the vehicle
    2) It was likely due to an “electrical failure”. See Note

    NOTE: Actually, it likely was one or more battery cells shorting out, which creates heat, which burns nearby items, which creates a fire that is very hard to extinguish. See Appendix

    GM Recall of Chevy Bolts: In 2020, GM issued a worldwide recall of 68,667 Chevy Bolts, all 2017, 2018 and 2019 models, plus, in 2021, a recall for another 73,000 Bolts, all 2020, 2021, and 2022 models.
    GM set aside $1.8 BILLION to replace battery modules, or 1.8 BILLION/(68,667 + 73,000) = $12,706/EV.

    Owners were advised not to charge them in a garage, and not to leave them unattended while charging, which may take up to 8 hours; what a nuisance!
    I wonder what could happen during rush hour traffic, or in a parking garage, or at a shopping mall, etc.
    Rep. Briglin heeded the GM recall by not charging in his garage. See URLs

    – Cost of replacing the battery packs of 80,000 Hyundai Konas was estimated at $900 million, about $11,000 per vehicle. See URL
    – EV batteries should be charged from 20 to 80%, to achieve minimal degradation and long life, plus the charging loss is minimal in that range
    – Charging EVs from 0 to 20% charge, and from 80 to 100% charge:

    1) Uses more kWh AC from the wall outlet per kWh DC charged into the battery, and
    2) Is detrimental to the battery.
    3) Requires additional kWh for cooling the battery while charging.

    – EV batteries must never be charged, when the battery temperature is less than 32F; if charged anyway, the plating out of Li-ions on the anode would permanently damage the battery. See URL

  2. EXCERPT from:


    I installed three heat pumps by Mitsubishi, rated 24,000 Btu/h at 47F, Model MXZ-2C24NAHZ2, each with 2 heads, each with remote control; 2 in the living room, 1 in the kitchen, and 1 in each of 3 bedrooms.
    The HPs have DC variable-speed, motor-driven compressors and fans, which improves the efficiency of low-temperature operation.
    The HPs last about 15 years. Turnkey capital cost was $24,000

    My Well-Sealed, Well-Insulated House

    The HPs are used for heating and cooling my 35-y-old, 3,600 sq ft, well-sealed/well-insulated house, except the basement, which has a near-steady temperature throughout the year, because it has 2” of blueboard, R-10, on the outside of the concrete foundation and under the basement slab, which has saved me many thousands of space heating dollars over the 35 years.

    I do not operate my HPs at 15F or below, because HPs would become increasingly less efficient with decreasing temperatures.
    The HP operating cost per hour would become greater than of my efficient propane furnace. See table 3

    High Electricity Prices

    Vermont forcing, with subsidies and/or GWSA mandates, the build-outs of expensive RE electricity systems, such as wind, solar, batteries, etc., would be counter-productive, because it would:

    1) Increase already-high electric rates and
    2) Worsen the already-poor economics of HPs (and of EVs)!!

    PART 1

    Energy Cost Reduction is Minimal

    – HP electricity consumption was from my electric bills
    – Vermont electricity prices, including taxes, fees and surcharges, are about 20 c/kWh.
    – My HPs provide space heat to 2,300 sq ft, about the same area as an average Vermont house
    – Two small propane heaters (electricity not required) provide space heat to my 1,300 sq ft basement
    – I operate my HPs at temperatures of 15F and greater; less $/h than propane
    – I operate my traditional propane system at temperatures of 15F and less; less $/h than HP

    – My average HP coefficient of performance, COP, was 2.64
    – My HPs required 2,489 kWh to replace 35% of my fuel.
    – My HPs would require 8,997 kWh, to replace 100% of my fuel.

    – The average Vermont house COP is about 3.34
    – The average Vermont house requires 2,085 kWh to replace 27.6% of its fuel, per VT-DPS/CADMUS survey. See URL

    Before HPs: I used 100 gal for domestic hot water + 250 gal for 2 stoves in basement + 850 gal for Viessmann furnace, for a total propane of 1,200 gal/y

    After HPs: I used 100 gal for DHW + 250 gal for 2 stoves in basement + 550 gal for Viessmann furnace + 2,489 kWh of electricity.

    My propane cost reduction for space heating was 850 – 550 = 300 gallon/y, at a cost of 2.339/gal = $702/y
    My displaced fuel was 100 x (1 – 550/850) = 35%, which is better than the Vermont average of 27.6%
    My purchased electricity cost increase was 2,489 kWh x 20 c/kWh = $498/y

    My energy cost savings due to the HPs were 702 – 498 = $204/y, on an investment of $24,000!!

    Amortizing Heat Pumps

    Amortizing the $24,000 turnkey capital cost at 3.5%/y for 15 years costs about $2,059/y.
    This is in addition to the amortizing of my existing propane system. I am losing money.

    Other Annual Costs

    There likely would be service calls and parts for the HP system, as the years go by.
    This is in addition to the annual service calls and parts for my existing propane system. I am losing more money.

    Energy Savings of Propane versus HPs

    Site Energy Basis: RE folks claim there would be a major energy reduction, due to using HPs. They compare the thermal Btus of 300 gallon of propane x 84,250 Btu/gal = 25,275,000 Btu vs the electrical Btus of 2,489 kWh of electricity x 3,412 Btu/kWh = 8,492,469 Btu.

    However, that comparison would equate thermal Btus with electrical Btus, which all engineers know is an absolute no-no.

    A-to-Z Energy Basis: A proper comparison would be thermal Btus of propane vs thermal Btus fed to power plants, i.e., 25,275,000 Btu vs 23,312,490 Btu, i.e., a minor energy reduction. See table 1A

    BTW, almost all RE folks who claim a major energy reduction from HPs, do not know how to compose this table, and yet they mandate others what to do to save the world from Climate Change.

  3. EXCERPT from:


    China has made electric buses and EVs a priority in urban areas to reduce excessive air pollution, due to: 1) coal-fired power plants, and 2) increased vehicle traffic.

    The US has much less of a pollution problem than China, except in its larger urban areas.
    The US uses much less coal, more domestic natural gas, and CO2-free nuclear is still around.

    New England has a pollution problem in its southern urban areas.
    Vermont has a minor pollution problem in Burlington and a few other urban areas.

    RE folks want to “Electrify Everything”; an easily uttered slogan

    It would require:

    – Additional power plants, such as nuclear, wind, solar, hydro, bio
    – Additional grid augmentation/expansion to connect wind and solar systems, and to carry the loads for EVs and heat pumps
    – Additional battery systems to store midday solar output surges for later use, i.e., DUCK-curve management.
    – Additional centralized, command/control/orchestrating (turning off/on appliances, heat pumps, EVs, etc.) by utilities to avoid overloading distribution and high voltage electric grids regarding:

    1) Charging times of EVs and operating times of heat pumps, and major appliances
    2) Demands of commercial/industrial businesses

    RE Folks Want More EVs and Buses Bought With “Free” Money

    RE folks drive the energy priorities of New England governments. RE folks want to use about $40 million of “free” federal COVID money and Volkswagen Settlement money to buy electric transit and school buses to deal with a minor pollution problem in a few urban areas in Vermont. RE folks urge Vermonters to buy:

    Mass Transit Buses
    Electric: $750,000 – $1,000,000 each, plus infrastructures, such as indoor parking, high-speed charging systems.
    Standard Diesel: $380,000 – $420,000; indoor parking and charging systems not required.

    School Buses
    Electric: $330,000 – $375,000, plus infrastructures
    Standard Diesel: about $100,000

    This article shows the 2 Proterra transit buses in Burlington, VT, would reduce CO2 at very high cost per metric ton, and the minor annual operating cost reduction would be overwhelmed by the cost of amortizing $million buses that last about 12 to 15 years.

    The $40 million of “free” money would be far better used to build zero-energy, and energy-surplus houses for suffering households; such housing would last at least 50 to 75 years.

    NOTE: Per Economics 101, spending huge amounts of borrowed capital on various projects that 1) have very poor financials, and 2) yield minor reductions in CO2 at high cost, is a recipe for:

    1) Low economic efficiency, and
    2) Low economic growth, on a state-wide and nation-wide scale, which would:

    – Adversely affect Vermont and US competitiveness in markets, and
    – Adversely affect living standards and 3) inhibit unsubsidized/efficient/profitable job creation.

    Real Costs of Government RE Programs Likely Will Remain Hidden

    Vermont’s government engaging in electric bus demonstration programs, financed with “free” money, likely will prove to be expensive undertakings, requiring hidden subsidies, white-washing and obfuscation.

    Lifetime spreadsheets, with 1) turnkey capital costs, 2) annual cashflows, 3) annual energy cost savings, 4) annual CO2 reductions, and 5) cost of CO2 reduction/metric ton, with all assumptions clearly stated and explained, likely will never see the light of day.

    Including Amortizing Capital Cost for a Rational Approach to Projects

    RE folks do not want to include amortizing costs, because it makes the financial economics of their dubious RE projects appear dismal. This is certainly the case with expensive electric buses. If any private-enterprise business were to ignore amortizing costs, it would be out of business in a short time.

    Capital cost of electric school bus, plus charger, $327,500 + $25,000 = $352,500
    Battery system cost, $100,000, for a 100-mile range.
    Capital cost of diesel school bus, $100,000
    Additional capital cost “to go electric” 352500 – 100000 = $252,500

    Lifetime, A-to-Z Analysis Includes Combustion, Upstream, Embodied and Downstream CO2

    Most CO2 analyses, on an energy use basis, significantly understate CO2 emissions. Much more realistic CO2 analyses would be on a lifetime, A-to-Z basis. Such analyses have been performed for at least 75 years in business. Engineering colleges have standard project economics courses in their curricula. Lifetime, A-to-Z analyses regarding energy projects would include:

    1) Upstream CO2 of energy for extraction, processing and transport to a user
    2) Embodied CO2 of expensive batteries, from extraction of materials to installation in a bus
    3) Embodied CO2 of $352,500 electric buses vs $100,000 diesel buses
    4) Embodied CO2 of balance-of-system components
    5) Embodied CO2 of much more expensive electric bus parking facilities, with a Level 2 or high-speed charger for each bus, than for a diesel bus parking facility with a diesel pump.
    6) Downstream CO2 of disposal of batteries, etc.

    Any CO2 advantage of electric buses vs diesel buses would be less, on a lifetime, A-to-Z basis. The cost of CO2 reduction of electric buses would increase from about $1,700/metric ton (energy only basis) to about $2,000/Mt (lifetime, A-to-Z basis).

  4. EXCERPT from:


    This article describes the efficiency of electric vehicles, EVs, and their charging loss, when charging at home and on-the-road, and the economics, when compared with efficient gasoline vehicles.

    In this article,

    Total cost of an EV, c/mile = Operating cost, c/mile + Owning cost, c/mile, i.e., amortizing the difference of the MSRPs of an EV versus an equivalent, efficient gasoline vehicle; no options, no destination charge, no sales tax, no subsidies.

    CO2 reduction of equivalent vehicles, on a lifetime, A-to-Z basis = CO2 emissions of an efficient gasoline vehicle, say 30 to 40 mpg – CO2 emissions of an EV


    Real-World Concerns About the Economics of EVs

    It may not be such a good idea to have a proliferation of EVs, because of:

    1) Their high initial capital costs; about 50% greater than equivalent gasoline vehicles.
    2) The widespread high-speed charging facilities required for charging “on the road”.
    3) The loss of valuable time when charging “on the road”.
    4) The high cost of charging/kWh, plus exorbitant penalties, when charging “on-the-road”.

    High-Mileage Hybrids a Much Better Alternative Than EVs

    The Toyota Prius, and Toyota Prius plug-in, which get up to 54 mpg, EPA combined, would:

    1) Have much less annual owning and operating costs than any EV, for at least the next ten years.
    2) Have minimal wait-times, as almost all such plug-ins would be charging at home
    3) Be less damaging to the environment, because their batteries would have very low capacity, kWh
    4) Impose much less of an additional burden on the electric grids.

    Hybrid vehicles, such as the Toyota Prius, save about the same amount of CO₂ as electric cars over their lifetime, plus:

    1) They are cost-competitive with gasoline vehicles, even without subsidies.
    2) They do not require EV chargers, do not induce range anxiety, can be refilled in minutes, instead of hours.
    3) Climate change does not care about where CO₂ comes from. Gasoline cars are only about 7% of global CO2 emissions. Replacing them with electric cars would only help just a little, on an A to Z, lifetime basis.

    “Electrify Everything”; an easily uttered slogan

    It would require:

    – Additional power plants, such as nuclear, wind, solar, hydro, bio
    – Additional grid augmentation/expansion to connect wind and solar systems, and to carry the loads for EVs and heat pumps
    – Additional battery systems to store midday solar output surges for later use, i.e., DUCK-curve management.
    – Additional command/control-orchestrating (turning off/on appliances, heat pumps, EVs, etc.) by utilities to avoid overloading distribution and high voltage electric grids regarding:

    1) Charging times of EVs and operating times of heat pumps
    2) Operating times of major appliances
    3) Demands of commercial/industrial businesses

    CO2 Reduction of an EV, based on real-world values

    According to the Haas study, EVs are driven an average of 7,000 miles/y, compared to 12,000 miles/y for the US and VT LDV mix.
    The difference holds for: 1) all-electric and plug-in hybrid vehicles, 2) single- and multiple-vehicle households, and 3) inside and outside California. See URL

    This means, as a fleet, EVs would reduce much less CO2 /y, than envisioned by the dream scenarios of RE folks.

    However, despite the lesser CO2 reduction, EVs are a way to significantly reduce CO2 emissions over the next 10 years.

    In 2020, about 123.73 billion gallons of finished motor gasoline were consumed in the United States.
    In 2020 EVs and plug-in hybrids reduced gasoline consumption by 0.5 billion gallon.
    It would take decades to achieve a 60 billion reduction due to EVs and plug-in hybrids.

    However, increasing the mileage, mpg, of the VT LDV mix from 22.715 to 35 mpg, such as with highly reliable, very-long-range, 54 mpg, non-plug-in Toyota hybrids, could be achieved at far less cost, and would reduce CO2 at least as much as EVs. See URLs.

    EV sales have been trending towards longer ranges. See table 3
    EVs, with longer ranges, such as Teslas, are driven more miles per year, on average.
    Thus, we can expect the 7,000 miles/y to increase over time.
    This article used 9,000 miles/y

  5. EXCERPT from:


    The Vermont House overrode Governor Scott’s veto of GWSA, and sent it to the Vermont Senate for an override vote
    GSWA converts the aspirational goals of the CEP, into mandated goals, with penalties, taxes, fees and surcharges.
    GWSA had been called “must pass this Session”.

    Capital Costs to Implement the Vermont Comprehensive Energy Plan

    In 2015, Energy Action Network, EAN, an umbrella organization for RE businesses, etc., had estimated it would take at least $1.25 BILLION per year for 35 years to implement the CEP by 2050, not counting many $billions for 1) financing costs and 2) replacement costs of short-live systems (wind, solar, batteries, EVs, heat pumps) during these 35 years.

    GWSA to Subsidize Job Creation in RE Sectors

    Vermont has a very poor climate for traditional, private-enterprise job creation. Forbes, et al., rate Vermont near the bottom. There are too many onerous taxes, fees and surcharges, and rules and regulations, that have caused businesses to 1) not grow in Vermont, 2) leave Vermont, and 3) not even come to Vermont.

    Vermont’s population is stagnant. Ambitious, younger people leave, older, more-needy people stay.
    Well-paying, steady jobs, with decent benefits, are hard to come by in Vermont, except in government and education.

    GWSA would create an expensively subsidized, industrial development policy that would:

    1) Require major increases in the current levels of various subsidies to all sorts of RE businesses for decades.
    2) Produce expensive, mostly weather-dependent, unreliable, variable/intermittent, wind/solar electricity.
    3) Very expensively “create jobs” that would not exist without the subsidies, the expense of other Vermonters.

    The GWSA “industrial development policy” would be an expensive substitute for traditional, private-enterprise job creation, which has proven so difficult in Vermont, largely because of historic, socialistic mindsets within the Legislature, which prefer to protect/enlarge/perpetuate vote-getting pet projects, instead of creating the proper conditions for a vibrant private sector that produces hi-tech products, employs highly-skilled, tax-paying workers, in steady jobs, with good benefits.

    GSWA Requires Major Annual Spending Increases

    Annual spending on RE would have to increase from the current $210 million/y (includes $60+ million for Efficiency Vermont) to at least $1.25 billion per year, to implement the CEP.

    If the RE subsidies were “freebie” federal subsidies, they would subsidize and grow RE businesses, and create jobs.
    However, federal subsidies increase and decrease, and come and go.

    If the subsidies were “state” subsidies, such as for 1) heat pumps, 2) electric vehicles, and 3) above-market, feed-in rates for solar, such as net-metering at 21.7 c/kWh and Standard Offer at 21.7 c/kWh, they would be extracted from Vermont ratepayers, taxpayers and tourists, which, as has been proven, would create jobs in the RE sectors, but would, as has been proven, eliminate jobs, or prevent jobs from being created, in almost all private-enterprise sectors.

    That would further worsen the near-zero, real-growth Vermont economy, and prolong the adverse employment conditions of the “Virus economy”.

    Brief Summary of GWSA

    The Agency of Natural Resources, ANR, led by Peter Walke (who is a member of EAN), has to create the rules and regulations, and penalties for non-compliance, which would be subject for review by a “SUPREME COUNCIL”, i.e., mostly appointed RE profiteers with ties to RE companies.

    GWSA states, if the ANR measures would not sufficiently reduce Vermont’s carbon dioxide, CO2, as scheduled per CEP, any entity, such as the Conservation Law Foundation, would be allowed to sue the state government, with lawyer’s fees reimbursed, if the suit is upheld in Court.

    GWSA states, the legislature and any Governor’s administration would play no role other than the legislature voting to provide the money, extracted from more and more impoverished, already-struggling, Virus-unemployed Vermonters, to implement it all.

    I foresee:

    1) A growing bureaucracy embroiled in one litigious brouhaha after another
    2) Vermonters becoming more and more oppressed and impoverished in the pursuit of impossible climate goals
    3) Vermont becoming less and less attractive as a place to do business, to visit, and to live.
    4) GWSA inflicting decades of torture of Vermonters to achieve nothing regarding the climate, other than “feel-good/virtue-signaling”.

  6. Excerpt from:


    Vermont has a Comprehensive Energy Plan, CEP. The capital cost for implementing the CEP would be in excess of $1.0 billion/y from 2017 to 2050, 33 years, as stated in Energy Action Network annual report for 2015.

    It would take $1.25 billion/y from 2022 to 2050, 28 years, and probable much more to overcome the Biden 5 to 6 percent inflation. See URLs.

    Excluded are financing and replacements of short-life systems, such as EVs (10y), heat pumps (15y), battery systems (15y), etc.

    Vermont Gross Emissions

    9.04 MMt in 2012
    10.19 MMt in 2015
    9.76 MMt in 2016
    9.41 MMt in 2017, estimated
    9.02 MMt in 2018, estimated

    The decrease from 2015 is almost entirely due to the VT-DPS using an artificial/political basis, i.e., not a physical basis, for calculating the CO2 of the Vermont electrical sector. That basis is MARKET BASED, i.e., based on “paper” power purchase agreements, PPAs, utilities have with owners of in-state and out-of-state electricity generating plants. It is explained in detail in this article.

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