The EPA's limited authority over-regulating greenhouse gas emissions was affirmed in the landmark June 2022 West Virginia vs. EPA decision.
The Clean Air Act says the EPA must craft achievable emission limitations standards that have been "Adequately demonstrated." Yet, the Carbon Capture technology that would be relied upon under this rule has never been "Adequately demonstrated" on the scale that EPA is attempting to require.
The EPA rule would lead to grid instability because operators will be forced to adopt intermittent, unreliable, and costly sources like wind and solar.
The North American Electric Reliability Corporation warned in its December 2023 Long-Term Assessment report that rigid policies like CPP 2.0 "Have the potential to influence generators" to close down their plants.
CPP 2.0 promises to reduce greenhouse gas emissions by 90% by 2032 by mandating coal and natural gas plants install carbon capture and storage or face closure.
CCS, as it stands, is expensive and will diminish coal and natural gas plant efficiency by at least 14%. Moreover, natural gas and coal plants retrofitted with first-generation carbon capture technology reportedly can expect a 50% and 70 to 80% increase in electricity costs, respectively.
In the U.S., we already have highly effective emissions technology that enables coal plants to run in an incredibly environmental way.
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