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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:

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.