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Comments to EPA on Revised Emissions Standards for New Power Plants

The Environmental Protection Agency (EPA) recently proposed a significant weakening of greenhouse gas emissions standards for new coal-fired power plants. We submitted comments focusing on flaws in the proposal and accompanying regulatory impact analysis.

EPA’s proposal would remove a 2015 requirement that newly constructed coal plants use partial carbon-capture-and-sequestration systems (or some other technology that can achieve similarly low emissions). The agency acknowledges that the proposed change might lead to higher levels of greenhouse gas pollution, but it makes no effort to monetize harms to public health and welfare that would flow from those emissions increases, even as it values compliance costs that might be avoided under the new rule. EPA cannot claim that monetization of pollution-related harms is infeasible, because the agency did assign dollar values to such impacts when it first issued greenhouse gas standards in 2015.