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American Experiment’s comments on repeal of Clean Power Plan 2.0

Center of the American Experiment submitted brief comments on the EPA’s proposed repeal of the Clean Power Plan 2.0, which would have forced coal plants to capture 90 percent of their emissions with carbon capture technology.

American Experiment argues that failing to repeal the CPP 2.0 will jeopardize grid reliability further and lead to blackouts while incurring billions of dollars in costs to maintain reliability with intermittent wind and solar. EPA has the opportunity to fully quantify those costs as it repeals the CPP 2.0. Further, wind turbines and solar panels have environmental costs and tradeoffs that EPA did not consider when mandating a shift in generation to these technologies.

Finally, CPP 2.0 is simply impractical because capturing 90 percent of carbon emissions from power plants through carbon capture and sequestration is not a “best system of emission reduction” for industry-wide, large-scale applications in a short time frame.

American Experiment’s former policy fellows Isaac Orr and Mitch Rolling modeled the proposed rule in 2023, which not only required coal-fired plants to capture 90 percent of their emissions, but also new natural gas plants.

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