The Environmental Protection Agency (EPA) proposed to weaken technology standards adopted in 2015 that act as crucial controls on effluent and emissions from electric power generation. Our comments focus on EPA’s flawed legal and economic justifications for the proposed rule, which contravenes the Clean Water Act, creates harmful incentives to delay compliance with guidelines, and relies on flawed cost-benefit analysis. We also submitted joint comments that detail how EPA severely undervalues the proposed rule’s climate costs and must monetize the full social cost of carbon using the best available data and methodologies.
Related Reading
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Statement on EPA’s Standards for Light- and Medium-Duty Vehicles
Media Resources / March 20, 2024
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Supplemental Comments to EPA on Reliability & the Proposed GHG Regulations for Fossil Fuel-Fired Power Plants
Project Updates / December 20, 2023
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Policy Integrity Scholarship and Advocacy Shapes EPA’s New Climate Damage Valuations
Project Updates / December 2, 2023
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EPA Updates Climate Damage Estimates in New Methane Rule
Media Resources / December 2, 2023
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Analytical Clarity: How Updated Climate-Damage Values and Discount Rates Will Affect Regulatory Analysis
Publications / December 1, 2023