Model suggests electric fields cannot grow large enough to generate bolts.
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References
Dwyer, J. R. A fundamental limit on electric fields in air. Geophysical Research Letters, 30, 2055, doi:10.1029/2003GL017781 (2003).
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University of Florida
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Mason, B. Astrophysicist strikes blow to lightning theory. Nature (2003). https://doi.org/10.1038/news031110-19
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DOI: https://doi.org/10.1038/news031110-19