On August 7, 2025, the Environmental Protection Network (EPN) submitted comments to EPA about the proposed repeal of greenhouse gas standards for fossil fuel-fired power plants, warning it would harm public health, hinder economic growth, and ignore the legal and scientific record supporting continued regulation under the Clean Air Act.
EPN’s comments focus on the points summarized below:
- Public Health Risks: Repealing the GHG emission standards would lead to significant public health harm, including an increase in premature deaths, hospital visits, and asthma cases, costing the public an estimated $76 to $130 billion (and even more if foregone climate benefits were considered). EPA’s own analysis shows that these public health and climate costs far outweigh the projected compliance cost savings of $9.6-$19 billion. The proposal also neglects to consider the tremendous negative impacts it would have on children’s health.
- Significant Harm to Economic Growth: EPA’s own analysis shows the potential for significant job losses resulting from the proposed rule. The RIA cites the reduction in the number of construction-related jobs related to: (1) the installation of new pollution control equipment; (2) constructed new capacity; and (3) constructed battery storage systems. These job losses are estimated to exceed the potential increase in non-construction jobs and point to potential for this proposed action to be a major job killer.
- Flawed Legal and Factual Basis: The proposal is based on faulty legal reasoning and fundamentally misinterprets the Clean Air Act. The claim that Electric Generating Units (EGUs) do not significantly contribute to GHG pollution is factually incorrect, as they are the second largest source of GHG emissions in the U.S. and a major contributor globally.
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Arbitrary and Capricious Action: EPA’s proposal to repeal the standards is arbitrary and capricious. The agency has not adequately considered alternatives to a full repeal. This action is an abandonment of EPA’s mission to protect public health and the environment.