Reply in Support of SACE's Cross-Motion For Summary Judgment

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA __________________________________________ ) SOUTHERN ALLIANCE FOR CLEAN ) ENERGY,

) ) Plaintiff, ) ) Civil Action No. 10-1335 (RCL) v. ) ) UNITED STATES DEPARTMENT OF ENERGY ) ) Defendant. ) __________________________________________)

PLAINTIFFS REPLY TO DEFENDANTS RESPONSE TO PLAINTIFFS STATEMENT OF MATERIAL FACTS NOT IN GENUINE DISPUTE Plaintiff, Southern Alliance for Clean Energy (SACE), hereby replies to Defendants Response to Plaintiffs Statement of Material Facts Not in Genuine Dispute. Defendant does not raise any genuine dispute with respect to Plaintiffs Statement of Material Facts. Accordingly, Plaintiff replies as follows: 1-16. Not disputed.

Dated: March 6th, 2012

Respectfully submitted, /s/ James B. Dougherty James B. Dougherty 709 3rd Street SW Washington, DC 20024 (202) 488-1140 jimdougherty@aol.com DC Bar No. 939538
/s/ Mindy Goldstein Mindy Goldstein Turner Environmental Law Clinic 1301 Clifton Road Atlanta, GA 30322 (404) 727-3432 mindy.goldstein@emory.edu GA Bar No. 727476 Pro hac vice
Counsel for Southern Alliance for Clean Energy

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