State common law claims arising from fossil fuel companies' operations which harmed the environment were largely preempted by the Clean Air Act, which regulated the use of fossil fuels and emissions standards.

Trial court properly granted remittitur where jury verdict including inflated repair costs was based on testimony from witnesses unqualified to testify about inflation and increased expenses.

FERC commissioners' statements following deadlock over proposed tariff were sufficient to demonstrate that the agency's "action through inaction" found the tariff just and reasonable.