Comments on Proposed Clean Power Plan Replacement
EPA recently issued a proposal to replace the Clean Power Plan (CPP) with the so-called “Affordable Clean Energy” rule, a far weaker policy that will increase greenhouse gas and soot- and smog-forming emissions from the electric sector. We submitted comments explaining why repealing the CPP is unnecessary, irrational, and harmful.
We submitted the following:
- Comments that focus on the Social Cost of Carbon (SCC) and EPA’s unjustifiably low estimates of the value of carbon reductions.
Some of our previous work on the CPP includes an article examining regulatory precedents for the rule, a report on the falling costs of complying with its requirements, an analysis of the statutory framework that governed its creation, and a New York Times op-ed on EPA’s misguided case for repeal.