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Investor Presentaiton

22 23 longstanding agency "practice may shed light on the extent of power" Congress delegated, failure to assert "power by those who presumably would be alert to exercise it" is telling. FTC v. Bunte Bros., 312 U.S. 349, 352 (1941). EPA's first Section 111(d) regulations contemplated on-site measures "construction or installation of emission control equipment or process change.” 40 C.F.R. § 60.21(h)(3). Consistent with that view, EPA did not use Section 111(d) before the CPP to require measures other than on-the-scene technologies. See, e.g., 61 Fed. Reg. 9,905, 9,914 (Mar. 12, 1996) (standards for landfill gas emissions based on gas collection and control systems). The only potential outliers allowed sources to use outside- the-fenceline measures to comply with standards derived from inside-the-fenceline "control technology available at the time." 70 Fed. Reg. at 28,616-17, rule vacated by New Jersey, 517 F.3d 574; see also 60 Fed. Reg. at 65,402. In other words, although EPA had at times given incentives to use cost-effective trading options, it had not compelled owners to shift capital to other sources in a gambit to restructure the industry. Thus, the CPP used a “decades- old statute" to justify sweeping regulations of a new kind. Ala. Ass'n, 141 S. Ct. at 2486. Courts are rightly suspicious of claims to "discover in a long-extant statute an unheralded power to regulate a significant portion of the American economy." UARG, 573 U.S. at 324 (cleaned up). The majority downplayed the CPP's novelty by pointing to prior EPA regulations that could have had "some generation-shifting effect" because they affected the "cost of doing business for particular plants." JA.151. That approach conflates a rule's ripple effects with its primary aim. Authority to take steps with “implications
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