关于废除化石燃料发电机组温室气体排放标准的评论（英）

August 7, 2025 Environmental Protection Agency1200 Pennsylvania Avenue NWWashington, DC 20460Attn: Docket ID No. EPA-HQ-OAR-2025-0124-0001Submitted via:www.regulations.gov Dear Administrator Zeldin, On behalf of Resources for the Future (RFF), I am pleased to share the accompanying comments to theEnvironmental Protection Agency (EPA) on the proposedRepeal of Greenhouse Gas Emissions Standards forFossil Fuel-Fired Electric Generating Units. RFF is an independent, nonprofit research institution in Washington, DC. Its mission is to improveenvironmental, energy, and natural resource decisions through impartial economic research and policyengagement. RFF is committed to being the most widely trusted source of research insights and policysolutions leading to a healthy environment and a thriving economy. While RFF researchers are encouraged to offer their expertise to inform policy decisions, the views expressedhere are those of the individual authors and may differ from those of other RFF experts, its officers, or itsdirectors. RFF does not take positions on specific policy proposals. Several RFF experts have providedcomments on the issues listed below: 1.Effect on US Power Sector Emissions2.Net Losses and Lost Benefits of the Regulated Pollutant3.Societal Costs4.Effects of Repeal and Other Federal Actions on Electricity Prices If you have any questions or would like additional information, please contact Liam Burke atlburke@rff.org. Sincerely, William A. Pizer President and CEO, Resources for the Future Comment on the Repeal of Greenhouse Gas EmissionsStandards for Fossil Fuel-Fired Electric Generating Units Brian C. PrestFellow and Initiative Director, Resources for the Future202.328.5109 |prest@rff.org Joshua LinnSenior Fellow, Resources for the Future202.328.5047 |linn@rff.org Kevin J. RennertFellow and Initiative Director, Resources for the Future202.328.5138 |rennert@rff.org Aaron BergmanFellow, Resources for the Future202.328.5105 |abergman@rff.org Alan KrupnickSenior Fellow and Program Director, Resources for the Future202.328.5107 |krupnick@rff.org Introduction In this public comment, we address the following primary issues with the EPA’s proposed rule "Repeal ofGreenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units.” Researchers atResources for the Future (RFF) have conducted analysis, provided separately, of the proposal’s effects,including overall greenhouse gas (GHG) emissions, electricity prices, and ratepayer electricity costs. We findthat: 1. The EPA’s claim that the emissions of the power sector do not rise to the level of “significant”conflicts with multiple different thresholds for significance long held by the federal government. 2. The EPA calculates and reports changes in emissions of the regulated air pollutant (CO2) as well asco-pollutants affected by the regulation (e.g., SO2, NOX), but the EPA does not fully account for allassociated economic costs and benefits from changes in such emissions in its economic analysis. TheEPA’s approach to benefit-cost analysis in this proposal does not reflect the current state of thescientific literature and is inconsistent with the EPA’s previously held approach across multipleadministrations (including the first Trump administration) and with the Office of Management andBudget’s (OMB’s) 2003 and 2023 versions of Circular A-4. We find that, were the EPA to account forthese additional economic effects in its supporting analysis of the proposed rule, the proposal wouldyield substantial costs to Americans, and these costs would be greater than the benefits reported bythe EPA. Effect on US Power Sector Emissions The EPA states that the US power sector does not contribute significantly to greenhouse gas emissions,asserting that the sector’s emissions—about 1.5 billion metric tons of CO2annually1—do not meet its chosenthreshold of 3 percent of global emissions. There are two assumptions underlying this definition ofsignificance: the choice of the numerical value of 3 percent of emissions and the choice to calculate US powersector emissions as a percentage of global emissions rather than as a percentage of US GHG emissions. Theseassumptions are not supported in the text of the proposal. Moreover, the latter assumption conflicts with theEPA’s previous treatment of power sector emissions when it issued a finding that the power sector was indeeda significant contributor of GHGs.2 Because the term “significant” as used in Section 111 of the Clean Air Act (CAA) is not statutorily defined, wecan examine other commonly used definitions of the term "significance" from longstanding regulatory practiceand statutes.Executive Order 12866, which has long governed regulatory analysis, defines a "significantregulatory action" as one that may have “an annual effect on the economy of $100 million or more or adverselyaffect in a material way the economy, a sector of the economy, productivity, competition, jobs, theenvironment,