The document discusses a study that tested whether mortality rates increased in Appalachian coal mining communities as a result of the 1990 amendments to the Clean Air Act (CAA). The study found: 1) Mortality rates were significantly higher in counties that practiced mountaintop removal (MTR) mining compared to other Appalachian and non-Appalachian counties. 2) There was a significant interaction between MTR status and the post-CAA time period, indicating mortality rates increased more in MTR counties after the CAA amendments. 3) Elevated mortality persisted in MTR counties even after controlling for smoking, poverty, obesity, physician access and other factors. The results

1. Unintended consequences of the Clean Air Act: Mortality rates in
Appalachian coal mining communities
Michael Hendryxa,
*, Benjamin Hollandb
a
Department of Applied Health Science, School of Public Health, Indiana University, Bloomington, IN 47505, USA
b
Department of Environmental Health, School of Public Health, Indiana University, Bloomington, IN 47505, USA
A R T I C L E I N F O
Article history:
Received 9 February 2016
Received in revised form 28 April 2016
Accepted 29 April 2016
Available online xxx
Keywords:
Mountaintop removal
Clean Air Act
Unintended consequences
Mortality
Appalachia
A B S T R A C T
The 1990 amendments to the US Clean Air Act (CAA) encouraged the growth of mountaintop removal
(MTR) coal mining in Central Appalachia. This study tests the hypothesis that the amendments had
unintended impacts on increasing mortality rates for populations living in these mining areas. We used a
panel design to examine adjusted mortality rates for three groups (all-cause, respiratory cancer, and non-
cancer respiratory disease) between 1968 and 2014 in 404 counties stratified by MTR and Appalachian/
non-Appalachian status. The results showed significant interactions between MTR status and post-CAA
period for all three mortality groups. These differences persisted after control for time, age, smoking
rates, poverty, obesity, and physician supply. The MTR region in the post-CAA years experienced an excess
of approximately 1200 adjusted deaths per year. Although the CAA has benefits, energy policies have in
general focused on the combustion portion of the fossil fuel cycle. Other components of fossil fuel
production (e.g. extraction, transport, and processing) should be considered in the comprehensive
development of sustainable energy policy.
ã 2016 Elsevier Ltd. All rights reserved.
1. Introduction
Amendments to the Clean Air Act (CAA) were implemented in
1990 in the United States with the intent to reduce acid rain and
other pollution consequences of burning coal in power plants. Coal
reserves in the Central Appalachian region of the United States are
relatively low in sulfur content and became more financially
attractive after these amendments took effect (Copeland, 2015;
Milici, 2000). The motivation to use low sulfur coal consequently
increased mining in Central Appalachian areas that were not
suitable to conventional techniques À places where coal reserves
are located within steep mountaintops or ridges, often at depths of
hundreds of feet or in multiple thin beds. The approach developed
to reach these coals is a form of surface mining called mountaintop
mining or mountaintop removal mining.
Mountaintop removal (MTR) occurred on small scales in
Appalachia as early as the 1960s, but it became much more
prevalent in the 1990s (Copeland, 2015; Szwilski et al., 2000), and
by the current century it had become the largest driver of land-
cover alterations in the Central Appalachians (Lindberg et al.,
2011). In part, the increase in MTR beginning in the 1990s was
because the CAA amendments encouraged the use of low sulfur
coal predominant in Central Appalachia (Copeland, 2015; Milici,
2000). Speaking with respect to the 1990CAA amendments, the
Vice-President of the West Virginia Coal Association stated, “It is
because of the (Environmental Protection Agency’s) action with
respect to the acid rain provisions of the act that allowed for these
large mountaintop mines to develop and flourish.” (State Journal,
2013)
Mountaintop removal mining involves clearcutting forests and
using explosives and heavy machinery to remove up to hundreds
of feet of rock and soil above and between coal layers. The
excavated material creates an “immense quantity of excess spoil”
(Copeland, 2015) that is dumped into adjacent valleys, burying
headwater streams. A single valley fill may be over a 1000 feet
wide and a mile long. As early as 1992 the Environmental
Protection Agency (EPA) had estimated that 1200 miles of
Appalachian streams had been buried by surface mining. MTR
occurs in close proximity to human settlements and takes place in
hundreds of sites over a land area in Central Appalachia roughly
equal in size to the states of New Hampshire and Vermont
combined. The negative impacts of MTR are both socioeconomic
(Bell and York, 2010; Hendryx, 2011) and environmental
(Bernhardt et al., 2012; Bernhardt and Palmer, 2011; Lindberg
et al., 2011; Palmer et al., 2010), both of which may contribute to
* Corresponding author.
E-mail addresses: hendryx@indiana.edu (M. Hendryx), bendholl@umail.iu.edu
(B. Holland).
http://dx.doi.org/10.1016/j.envsci.2016.04.021
1462-9011/ã 2016 Elsevier Ltd. All rights reserved.
Environmental Science & Policy 63 (2016) 1–6
Contents lists available at ScienceDirect
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journal homepage: www.elsevier.com/locate/envsci

2. poor public health outcomes for nearby populations. Environ-
mental impacts of MTR include impaired air and water quality in
communities proximate to the mine sites (Kurth et al., 2014;
Kurth et al., 2015; Orem et al., 2012). MTR sites can be mined with
fewer employees per ton of coal extracted relative to other mining
forms, and the resulting environmental destruction makes the
land unattractive for alternative economic development. In
consequence, counties where MTR is practiced have lower
income levels, higher poverty rates, and higher unemployment
rates compared to other parts of the region (Hendryx, 2011;
Hendryx and Ahern, 2009).
The 1990 amendments to the CAA have resulted in a number of
benefits. Since its enactment, reductions in the US have been
observed for all six of the criteria air pollutants: particulate matter,
ozone, lead, carbon monoxide, nitrous oxides and sulfur dioxide.
According to the EPA, acid rain decreased 55% between 1990 and
2010 (EPA, 2015). These improvements in air quality translate to
improvements in public health, as pollutants from coal combustion
contribute to morbidity and premature mortality (Gohlke et al.,
2011; Laden et al., 2000; Lewtas, 2007).
However, well intended public policies sometimes have unin-
tendedandunanticipatednegativeconsequences(IOM,2001;Peters
et al., 2013). The CAA itself may have provided unintended
disincentives to promote development of cleaner power plants (List
et al., 2004). Other instances exist in areas of agriculture (Karp et al.,
2015), health care (Naylor et al., 2012; Song et al., 2013) and
education policy (Metos et al., 2015) where unintended negative
consequences resulted from well-meaning policy interventions.
Previous research on the public health impacts of mountaintop
removal mining has demonstrated that mortality rates are higher in
MTR communities compared to control communities in ways not
explained by age, smoking, obesity, socioeconomic status or other
risks. Elevated rates have been observed for all-cause mortality
(Hendryx, 2011; Hendryx and Ahern, 2009), heart, lung and kidney
disease (Hendryx, 2009), and some types of cancer (Ahern and
Hendryx, 2012). However, the previous mortality studies were
limited to a narrow range of years and did not examine possible CAA
effects. The current studyextends prior research by testing a specific
hypothesis regarding possible unintended consequences of the CAA.
We employ a panel analysis design to use counties as their own
controls to examine mortality rates pre- and post-CAA in MTR and
control areas. If CAA-dependent mortality differences are detected,
thentheyare notdueto sociodemographicdifferencesinMTRversus
other areas to the extent that the pre-CAA observations in the MTR
area serve as an internal control. We also have group comparisons to
examine CAA effects in the MTR region compared to other regions.
We examine mortality rates for a 47 year period from 1968 through
2014 to test whether all-cause mortality in MTR areas of Central
Appalachia increased in the post-CAAyears as thismethod of mining
became predominant.
2. Methods
2.1. Design
The study is a secondary analysis of publicly available county-
level data. Annual age-adjusted mortality rates for 1968–2014 are
investigated in relationship to mountaintop removal mining in
Central Appalachia and the implementation of the 1990 amend-
ments to the Clean Air Act (CAA).
The study area consists of the four states where mountaintop
removal mining has been practiced, including Kentucky, Tennessee,
Virginia and West Virginia. Counties within these states were
classified into three groups: those where any amount of mountain-
top removal coal mining had been practiced, other counties in
Appalachia without mountaintop removal, and the remaining non-
Appalachiancountiesinthosestates(thelatterusedasthereferentin
statistical models). The Appalachian non-MTR group provides a
control for general Appalachian effects. Mountaintop removal
counties were identified using satellite imagery as reported in
earlier papers (Esch and Hendryx, 2011) and confirmed using Energy
Information Administration data on tons of coal mined from surface
mines (EIA, 2016). Appalachian counties were identified based on
Appalachian Regional Commission designations in place in 2010.
2.2. Measures
Age-adjusted all-cause mortality rates for the four states were
obtained from the Centers for Disease Control and Prevention
(CDC, 2016). Mortality rates are per 100,000 persons and are age-
adjusted to the 2000 US population. Mortality rates were
reported for each county on an annual basis for the years
1968–2014.
In addition to total mortality, we also examined age-adjusted
mortality rates for two diagnostic classes, including respiratory
cancer, and all other non-cancer respiratory disease. These classes
were selected because of prior evidence that MTR activities
generate local air pollution (Kurth et al., 2014; Kurth et al., 2015)
and may promote poor health outcomes for these conditions
(Christian et al. 2011; Hendryx et al., 2008; Hendryx, 2009;
Hendryx and Luo, 2015). Toxicological data suggest ultrafine
particulate matter, a chief air pollutant from MTR mining, may
promote pulmonary inflammation, oxidative stress, and Ca++
influx within lung cells (Donaldson et al., 2004). These may act as
a mechanism for long-term, delayed, neoplastic promotion. In
instances of small numbers of cases in counties within single
years, the CDC suppresses the data values to protect patient
confidentiality. For this reason, we aggregated mortality rates for
these diagnostic groups into five-year blocks to increase case
numbers and eliminate suppressed values.
Data on covariates were obtained from the County Health
Rankings data for 2015 (County Health Rankings, 2016). Each
county had single cross-sectional measures for the adult smoking
rate, obesity rate, child poverty rate, and per capita supply of
primary care physicians. In a few instances where covariate data
were missing for the county, the missing observations were
replaced with state averages.
Descriptive summaries of annual age-adjusted mortality rates
were found for the three county groups (MTR, other Appalachian,
and other). Then, a panel design analysis was conducted to
investigate age-adjusted mortality rates in relationship to time,
county group, covariates, and implementation of the CAA amend-
ments of 1990. The years 1968–1989 were designated as pre-CAA
and the years 1990–2014 were designated as post-CAA. The
analyses were conducted using SAS version 9.4 Proc Mixed,
specifying the year as a repeated measure, and the county, county
group, and CAA dummy variable as class variables. An autore-
gressive value of 1 was specified to account for correlated mortality
rates from one year to the next. We first tested a model with main
effects for year, the CAA dummy variable, and county group. A
second model added covariates. A final model was estimated after
adding an interaction term between county group and the CAA
indicator. The final interaction term tests whether age-adjusted
mortality rates were significantly higher in the MTR areas in the
post-CAA period while controlling for covariates and year-to-year
trends.
3. Results
Data for a total of 404 counties were available for the analysis,
including 37 MTR counties, 149 other Appalachian counties, and
2 M. Hendryx, B. Holland / Environmental Science & Policy 63 (2016) 1–6

3. 218 remaining counties in the four states. Annual all-cause age-
adjusted mortality rates for the three groups are shown in Fig. 1.
The figure shows that mortality rates have been higher in MTR
counties throughout the time period, but that the difference
between MTR and other county groups appears to have increased
in more recent years. A reduction in annual mortality rates for all
three groups is evident from 1968 to about 1980, consistent with
national trends (Hoyert, 2012). The period roughly from 1980 to
the early 1990s shows little change for all groups, and in the latter
years the rates for the MTR counties remained flat while rates in
the other groups declined.
The rates in Fig. 1 correspond to Model 1 results with main
effects and no covariates summarized in the left hand column of
Table 1. Model 1 shows a significant yearly decline in mortality
rates overall, and a significant positive overall effect during the
post-CAA period. The model also shows significant effects for the
MTR and other Appalachian groups compared to the referent, with
a much larger mortality coefficient for the MTR area.
Model 2 adds covariates, and results show that the covariates
had significant effects but did not change the pattern for the other
effects, with one exception. The coefficient for the non-MTR
Appalachian counties switched from positive to negative. This
indicates that the covariates (smoking, poverty, obesity, and
physician supply) could account for higher mortality in the non-
MTR Appalachian region, but could only partially account for the
higher mortality in the MTR area.
Model 3 shows the effects of adding the interaction term. The
main effect for the post-CAA variable changed from positive to
negative. The main effects for both the MTR and non-MTR
Appalachian regions were also negative. The effects of the
covariates remained essentially unchanged. Compared to the
referent category in the interaction, four of the five groups showed
significantly elevated mortality rates. The largest estimate was for
the post-CAA MTR group, followed by the post-CAA non-MTR
Appalachian group. Although not shown in the Table, the 95%
confidence interval for the post-CAA, MTR estimate (16.30, 95%
CI = 15.03–17.57) was completely above the confidence intervals for
all of the remaining groups, including the post-CAA non-MTR
Appalachian estimate (13.72, 95% CI = 12.59–14.83), and the pre-
CAA MTR estimate (3.47, 95% CI = 1.65–5.28).
Analyses were repeated for the two diagnostic classes,
including respiratory cancer and other respiratory disease. Similar
significant model results were found for both groups. Table 2
shows the final Model 3 results adjusting for covariates for each
diagnostic class. Results show significant positive effects for higher
adjusted mortality rates in the MTR counties post-CAA. For
respiratory cancer, effects for the remaining county groups
compared to the non-Appalachian referent are negative. For other
non-cancer respiratory disease, the other county groups some-
times also show significant positive effects, but the coefficient for
the MTR-post CAA group (38.07) is and its 95% confidence interval
(34.86–41.27) falls completely above the CIs for the other county
groups (confidence intervals not shown in table).
We conducted a final analysis to estimate the number of excess
adjusted all-cause deaths that occurred in the MTR region in the
post-CAA period. To do this we found least squares means for the
two way county group*CAA interaction, controlling for main
600
700
800
900
1000
1100
1200
1300
1400
1500
1968
1970
1972
1974
1976
1978
1980
1982
1984
1986
1988
1990
1992
1994
1996
1998
2000
2002
2004
2006
2008
2010
2012
2014
MTR Other Appalachian Non-Appalachian
Pre-CAA Post-CAA
Fig. 1. Age-adjusted total mortality rates per 100,000 by county group, 1968–2014.
Table 1
Summary of model results, dependent variable is total age-adjusted mortality per 100,000.
Model 1 Model 2 Model 3
Independent variables Coefficient (SE) P< Coefficient (SE) P< Coefficient (SE) P<
Year À9.41 (0.22) 0.0001 À9.28 (0.20) 0.0001 À17.24 (0.41) 0.0001
Post-CAA 34.12 (5.45) 0.0001 34.15 (5.20) 0.0001 À214.9 (10.10) 0.0001
Pre-CAA (referent) – – –
MTR counties 134.40 (6.96) 0.0001 53.42 (6.93) 0.0001 À43.57 (12.32) 0.001
Other Appalachian counties 13.65 (4.19) 0.0001 À24.10 (4.13) 0.0001 À61.66 (7.67) 0.0001
Other counties (referent) – – –
Smoking rate – 303.4 (36.07) 0.0001 302.1 (24.03) 0.0001
Obesity rate – 459.8 (61.94) 0.0001 466.8 (52.69) 0.0001
Poverty rate – 369.2 (28.25) 0.0001 378.2 (24.03) 0.0001
Per capita primary care physicians – 0.16 (0.06) 0.02 0.18 (0.05) 0.001
Year*MTR*Post-CAA – – 16.30 (0.65) 0.0001
Year*MTR*Pre-CAA – 3.47 (0.93) 0.0002
Year*Other App.*Post-CAA – 13.72 (0.57) 0.0001
Year*Other App.*Pre-CAA – 1.05 (0.58) 0.07
Year*Other counties*Post-CAA – 12.00 (0.5) 0.0001
Year*Other counties*Pre-CAA (referent) – – –
AIC fit 230314.3 199573.8 198720.2
Model 1: Main effects and no covariates. Null model likelihood ratio test chi-square = 7031.4 (df = 1), p < 0.0001.
Model 2: Covariates added. Null model likelihood ratio test chi-square = 5502.0 (df = 1), p < 0.0001.
Model 3: Interaction term added. Null model likelihood ratio test chi-square = 4117.7 (df = 1), p<0.0001. The overall effect of the three-way interaction term was significant
with chi-square = 981.4 (df = 5), p < 0.0001.
M. Hendryx, B. Holland / Environmental Science & Policy 63 (2016) 1–6 3

4. effects of year, CAA, county group and the covariates. The estimates
provided in Table 3 show annual age-adjusted deaths per
100,000 by county group and CAA period.
The result for the MTR region in the post-CAA period,
1158.7 deaths per year, is approximately 98 deaths more per
100,000 per year compared to the pre-CAA MTR effect, and
approximately 101 deaths more per 100,000 per year compared to
the other Appalachian counties in the post-CAA period. Given that
the population of the 37 counties where MTR is practiced totals
1,204,469 people as provided in the County Rankings Data, this
equates to an estimate of 1180 to 1217 additional deaths
experienced every year in the MTR region in the post-CAA period,
controlling for age and other covariates.
4. Discussion
The results of the study indicate that mortality rate disparities
in mountaintop removal coal mining areas of Appalachia became
significantly more pronounced in the years after the introduction
of the 1990 amendments to the Clean Air Act. Counties outside of
the MTR zone in these Central Appalachian states experienced a
decline in total age-adjusted mortality rates that was not matched
by declines in the MTR zone. This divergence becomes most
apparent about 10 years after the CAA revisions encouraged the
growth of MTR mining. The 10 year delay may reflect longer term
consequences of exposures over time.
Death rates were higher in the MTR region throughout the
entire study period. Even before this area of Central Appalachia
began to engage in large scale MTR, it was already characterized by
relatively heavy amounts of coal mining using older techniques,
including underground and other surface mining methods. Prior to
the widespread practice of MTR, these areas were experiencing
health disadvantages related perhaps to the poor socioeconomic
conditions that characterize mining-dependent economies, or to
environmental impacts from other mining techniques.
We also observed a smaller deleterious post-CAA effect for the
non-MTR Appalachian region. These areas also experienced
relatively higher mortality rates compared to the non-Appalachian
referent group. This finding may reflect the effects of non-MTR
mining that occurs in portions of this region, or it may reflect MTR
spillover effects from environmental or socioeconomic impair-
ments that do not obey county lines and impact neighboring
populations.
Significant post-CAA effects were also observed for respiratory
(mostly lung) cancer and other non-cancer respiratory disease. The
effects appear to be most pronounced for respiratory cancer. Other
respiratory diseases include chronic conditions such as bronchitis
and emphysema that may be related to long term air pollution
exposures but also includes acute illness such as pneumonia that
may reflect other etiologies.
This study does not assess environmental conditions in mining
communities. Other research has documented that air and water
pollution are impaired in communities proximate to mountaintop
removal coal mining (Kurth et al., 2014; Kurth et al., 2015; Orem
et al., 2012). Air contaminates in mining communities include
elevated levels of silica, other inorganics, and polycyclic aromatic
hydrocarbons. Elevations in ultrafine counts have also been
observed. Subsequent laboratory-based studies have documented
biological impairments from exposure to mountaintop mining
particulate matter (Knuckles et al., 2013; Luanpitpong et al., 2014;
Nichols et al., 2015). The unintended impacts that may have
resulted from the CAA likely include environmental harm caused
by this aggressive form of surface mining, but in addition may
include health consequences secondary to the social and economic
costs associated with this land use choice. These social and
economic costs include reductions in alternative employment
opportunities with corresponding increases in socioeconomic
disadvantage.
It is worth noting that large scale surface coal mining occurs in
many countries around the world. Studies have identified air
quality problems around surface mining in India, Columbia,
Australia, China, and Great Britain (Ghose 2007; Reynolds et al.,
2003; Higginbotham et al., 2010; Huertas et al., 2012; Liu et al.,
2012). Public health problems near surface mining have also been
noted outside the US (Temple and Sykes, 1992; Yapici et al., 2006;
Liao et al., 2010). Possible unintended consequences of coal mining
activities globally should be considered in the development of
energy policy, as described later in the paper.
Limitations of the study include the ecological design,
imperfect capture of covariates, and uncertain temporal relation-
ships between possible exposures and health outcomes. The
county level ecological data prohibit drawing conclusions about
exposure-mortality consequences for individuals; we can only
comment on county aggregate relationships. Covariates were
measured from a single time point, although county differences on
population sociodemographic and behavioral variables tend to be
stable over time. The relationship between the implementation of
Table 2
Final model results for respiratory cancer and for other non-cancer respiratory disease.
Respiratory Cancer Non-Cancer Respiratory Disease
Independent variables Coefficient (SE) P< Coefficient (SE) P<
Year À1.13 (0.36) 0.002 1.21 (0.26) 0.0001
Post-CAA 13.72 (2.09) 0.0001 8.02 (1.50) 0.0001
Pre-CAA (referent) – –
Smoking rate 58.69 (9.81) 0.0001 63.97 (7.04) 0.0001
Obesity rate 88.95 (16.84) 0.0001 12.50 (12.09) 0.31
Poverty rate 50.59 (7.66) 0.0001 33.18 (5.50) 0.0001
Per capita primary care physicians 0.10 (0.02) 0.0001 À0.01 (.01) 0.43
MTR*Post-CAA 11.75 (2.28) 0.0001 38.07 (1.64) 0.0001
MTR*Pre-CAA À15.54 (2.86) 0.0001 24.58 (2.06) 0.0001
Other App.*Post-CAA À6.92 (1.38) 0.0001 6.49 (0.99) 0.0001
Other App.*Pre-CAA À17.68 (1.76) 0.0001 0.07 (1.26) 0.96
Other counties (referent) – –
Table 3
Least squares means for age-adjusted deaths per year per 100,000 population,
controlling for year, county group, CAA period, smoking, obesity, poverty, and
primary care physician supply.
Effect Least square means (standard error)
MTR*Post-CAA 1158.7 (7.8)
MTR*Pre-CAA 1060.1 (8.3)
Other App.*Post-CAA 1057.8 (4.3)
Other App.*Pre-CAA 1009.2 (4.6)
Other counties*Post-CAA 1065.1 (3.8)
Other counties*Pre-CAA (referent) 1052.8 (4.1)
4 M. Hendryx, B. Holland / Environmental Science & Policy 63 (2016) 1–6

5. the CAA amendments and observed mortality differences was
imperfect. In particular, there was a period even before the
introduction of the amendments when mortality rates had
flattened in MTR areas; the difference only becomes apparent
about 10 years after the amendments, when rates began to diverge
more noticeably between MTR counties and other places. This
divergence may reflect delayed effects of chronic exposure over
time, but cannot be known with certainty. We cannot conclude
definitively with this non-experimental design that the CAA
amendments caused the additional mortality disparity, but given
the evidence that the CAA promoted MTR activity, and the
environmental and public health evidence for MTR’s impacts, it is a
possible contributing factor. Other socioeconomic and environ-
mental factors pre-dating or co-occurring with the CAA period
contribute to health disparities in MTR areas too. Despite the
uncertainty, the results provide an illustration of the importance of
considering full production costs from fossil fuels in the develop-
ment of energy policy.
4.1. General lessons
Although the issue of mountaintop removal may appear to be
confined to Central Appalachia, there are general lessons that can
be learned regarding the need for energy policies to address the
entire fossil fuel sequence of extraction, processing, transporta-
tion, combustion and disposal. These lessons have relevance to
the US but also to other nations where coal mining and other
fossil fuel extraction activities are practiced. When considering
impacts from pollution and responses to climate change, energy
policy in the US has often focused exclusively on combustion,
largely ignoring other components of production and use. Recent
plans by the US Environmental Protection Agency (EPA) to
reduce carbon emissions to fight climate change focus on coal-
fired power plants, and do not consider how coal reaches those
power plants in the first place (EPA, 2016). Epstein et al. (2011),
however, have shown that the entire production process of using
coal adds considerably to its full environmental costs. Fox and
Campbell (2010) estimated that mountaintop mining adds the
equivalent of 7–17% of conventional power plant carbon
emissions to the atmosphere. Reducing reliance on coal in favor
of natural gas has been promoted as a cleaner approach to power
generation, but again, policy attention to the environmental and
public health impacts of natural gas extraction and processing,
not just its consumption, has been missing. Hydraulic fracturing
for natural gas in shale formations harms local environments and
may impair public health (Rabinowitz et al., 2015); furthermore,
it has been estimated that shale gas has a greater greenhouse
effect than conventional gas or coal when considering the total
production cycle (Howarth et al., 2011). Future policies in the US
and globally that are designed to reduce climate change and
promote energy sustainability must consider the complete
production cycles of various fuels and not focus only on fuel
combustion.
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