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More for Less: Strengthening EPA’s proposed carbon pollution standards can achieve greater emissions reductions at a lower cost 

August 8, 2023 Work Area: Power Plants

WASHINGTON – Today, Clean Air Task Force (CATF) submitted public comments to support and strengthen the U.S. Environmental Protection Agency’s (EPA) proposed carbon pollution standards for the fossil fuel-fired power fleet. The comments were submitted with the Natural Resources Defense Council (NRDC) and joined by The Nature Conservancy. 

“The EPA proposed an important rule this spring to curb emissions from power plants, but it can and must be strengthened to further drive reductions from the nation’s second largest source of greenhouse gas emissions,” said Jay Duffy, CATF’s Litigation Director. “Under the Clean Air Act, the EPA has the authority, and responsibility, to curb carbon pollution from power plants, and we have cost-effective and adequately demonstrated technologies readily available to do just that. By expanding the fleet covered under the stringent standard to include facilities that operate and pollute the most – a shrinking portion of the fleet – we can achieve even greater emissions reductions at an even lower cost than the EPA previously estimated. These modest and incremental standards are a step in the right direction, and we look forward to engaging with the EPA and other stakeholders to ensure the rule is finalized to the strongest degree – we don’t have any time to waste.” 

CATF and NRDC estimate these recommended changes would result in an additional 394 million tons of carbon reductions from 2028 to 2042, as compared to EPA’s proposal, and at a lower cost, saving the power sector $20 billion. These recommendations include:  

  • Advance the date for the subcategory of long-lived coal units from 2040 to 2038 subject to a 90 percent CCS-based emission limit. The eight-year period from 2030 to 2038 is sufficient to recover the costs of installing CCS in 2030. 
  • For baseload new gas-fired power plants, lower the applicable capacity factor to 40 percent and set the emission limit based on 90 percent CCS starting in 2035. 
  • Apply a CCS-based emission limit to gas-fired electric generating units located in plants with total gas-fired capacity above 600 megawatts and total capacity utilization more than 45 percent. This change would increase the emissions covered from combined cycle units by 78 percent over EPA’s proposal while increasing the number of plant sites covered by only 30 percent. 
  • Make a firm commitment to appropriately regulate the CO2 emissions of the remaining existing gas fleet as expeditiously as possible. 

The comments in their entirety can be found here.

Press Contact

Samantha Sadowski, Communications Manager, U.S.,, +1 202-440-1717

About Clean Air Task Force 

Clean Air Task Force (CATF) is a global nonprofit organization working to safeguard against the worst impacts of climate change by catalyzing the rapid development and deployment of low-carbon energy and other climate-protecting technologies. With 25 years of internationally recognized expertise on climate policy and a fierce commitment to exploring all potential solutions, CATF is a pragmatic, non-ideological advocacy group with the bold ideas needed to address climate change. CATF has offices in Boston, Washington D.C., and Brussels, with staff working virtually around the world. Visit and follow @cleanaircatf.

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