未来能源研究所-关于废除化石燃料发电机组温室气体排放标准的评论（英）

1616 P ST. NW, SUITE 600, WASHINGTON, DC 20036 • 202.328.5000 • WWW.RFF.ORG August 7, 2025 Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460 Attn: Docket ID No. EPA-HQ-OAR-2025-0124-0001 Submitted via: www.regulations.gov Dear Administrator Zeldin, On behalf of Resources for the Future (RFF), I am pleased to share the accompanying comments to the Environmental Protection Agency (EPA) on the proposed Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units. RFF is an independent, nonprofit research institution in Washington, DC. Its mission is to improve environmental, energy, and natural resource decisions through impartial economic research and policy engagement. RFF is committed to being the most widely trusted source of research insights and policy solutions leading to a healthy environment and a thriving economy. While RFF researchers are encouraged to offer their expertise to inform policy decisions, the views expressed here are those of the individual authors and may differ from those of other RFF experts, its officers, or its directors. RFF does not take positions on specific policy proposals. Several RFF experts have provided comments on the issues listed below: 1. Effect on US Power Sector Emissions 2. Net Losses and Lost Benefits of the Regulated Pollutant 3. Societal Costs 4. Effects of Repeal and Other Federal Actions on Electricity Prices If you have any questions or would like additional information, please contact Liam Burke at lburke@rff.org. Sincerely, William A. Pizer President and CEO, Resources for the Future 2 Comment on the Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units Brian C. Prest Fellow and Initiative Director, Resources for the Future 202.328.5109 | prest@rff.org Joshua Linn Senior Fellow, Resources for the Future 202.328.5047 | linn@rff.org Kevin J. Rennert Fellow and Initiative Director, Resources for the Future 202.328.5138 | rennert@rff.org Aaron Bergman Fellow, Resources for the Future 202.328.5105 | abergman@rff.org Alan Krupnick Senior Fellow and Program Director, Resources for the Future 202.328.5107 | krupnick@rff.org Introduction In this public comment, we address the following primary issues with the EPA’s proposed rule "Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units.” Researchers at Resources 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 find that: 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 as co