EPSA Submits Comments to EPA on Proposed Repeal of 2024 Power Plant Emissions Rule (Docket EPA-HQ-OAR-2025-0124)
Keeping the Grid Reliable in a Time of Surging Demand
As electricity demand rises sharply across the country—driven by the growth of data centers, AI, electrification, and domestic manufacturing—policymakers face a clear imperative: ensure the electric grid remains reliable, resilient, and affordable.
That’s why the Electric Power Supply Association (EPSA) has submitted comments supporting the U.S. Environmental Protection Agency (EPA)’s proposed repeal of the 2024 greenhouse gas (GHG) emissions rule for fossil fuel-fired power plants. The proposed repeal reflects a needed course correction in light of real infrastructure limitations and system reliability concerns.
📄 Read EPSA’s full comments to the EPA » Download the full filing
What Was the Rule and Why Is Repeal Needed?
The 2024 rule imposed emissions standards that would have effectively mandated the use of carbon capture and storage (CCS) technology for existing coal and new natural gas plants. EPSA member companies are some of the earliest investors in CCS technology and development. However, CCS deployment at scale faces substantial obstacles:
- A lack of nationwide CO₂ pipeline infrastructure
- Slow permitting for storage wells
- Legal and regulatory challenges
- Community opposition in many regions
Without these critical elements in place, the rule would have forced premature retirement or reduced output from dependable power plants—just as electricity demand is projected to climb by 25% or more by 2030. That would undermine grid reliability and threaten economic and national security goals tied to industrial growth and technological leadership.
EPSA’s Position: Realism, Reliability, and Innovation
EPSA’s members provide roughly 20% of the nation’s power through a competitive mix of natural gas, wind, solar, hydropower, nuclear, battery storage, and more. Many are also actively investing in carbon capture and other low-emission technologies. But successful deployment of such solutions must be grounded in what is feasible today—and planned for responsibly.
Our filing emphasizes:
- The urgent need to maintain and invest in dispatchable, reliable power resources
- The importance of tailoring emissions policies to reflect regional infrastructure readiness
- The role of well-functioning power markets in driving innovation and efficiency
EPSA supports a power system where all resources that can contribute to reliability and environmental progress have a place. That includes cleaner technologies, but also the firm generation needed to ensure the lights stay on during peak demand and extreme weather.
A Balanced Path Forward
The U.S. power sector has already achieved significant emissions reductions while meeting customer demand and keeping costs low. That progress has been driven in large part by competitive markets and private sector innovation—not rigid mandates.
Looking ahead, policymakers must focus on:
- Maintaining reliability through a diverse mix of energy resources
- Avoiding one-size-fits-all mandates not supported by infrastructure
- Creating regulatory and market certainty for investment in innovative, cost-effective solutions
EPSA appreciates the EPA’s acknowledgment of the practical challenges tied to carbon capture deployment and urges continued collaboration to shape energy policy that reflects market dynamics, regional realities, and system needs.
