EPSA Submits Comments to EPA on Proposed Repeal of 2024 Power Plant Emissions Rule (Docket EPA-HQ-OAR-2025-0124)
In comments to the U.S. Environmental Protection Agency (EPA) regarding the June 17, 2025 Proposed Rulemaking to repeal greenhouse gas (GHG) emissions standards for fossil fuel-fired electric generating units, the Electric Power Supply Association (EPSA) supports the repeal of the underlying 2024 rule. EPSA commends the EPA for acknowledging the substantial challenges that hinder the feasibility of a nationwide mandate for carbon capture and sequestration (CCS) deployment, particularly in response to items C-23, C-29, and C-39 of the proposed rule.
Download the comments as filed here.
EPSA underscores several key points:
- Infrastructure Gaps: There is currently an inadequate nationwide infrastructure for CO₂ transportation and long-term storage. CO₂ pipeline capacity and Class VI well permitting are far from the levels needed to support a broad CCS mandate.
- Unrealistic Assumptions: The prior rule’s assumptions about the timely deployment of CCS technology are not grounded in the realities of permitting delays, regional opposition, supply chain constraints, and the slow pace of infrastructure buildout.
- Electric Grid Reliability Risk: Imposing unachievable emissions standards would force premature generator retirements or capacity reductions, endangering grid reliability amid sharply rising electricity demand.
- Support for Targeted CCS Deployment: EPSA remains strongly supportive of CCS investment where regionally appropriate and technologically feasible. EPSA members are leaders in CCS development and innovation, but emphasize that localized project success should not justify national mandates.
- Call for Practical Policy: EPSA urges the EPA to continue pursuing decarbonization pathways that recognize technological, regional, and market realities. The association affirms that competitive wholesale electricity markets have driven significant GHG reductions and should remain central to future emissions policy.
EPSA’s comments reflect a commitment to environmental progress and grid reliability, urging policies that enable realistic, flexible, and economically viable clean energy transitions.
