For Immediate Release
August 7, 2025 

 C2ES Comments Urge Against EPA Repeal of Power Sector Carbon Pollution Standards  

Highlight increasing severity and costs of climate impacts, risks to US competitiveness, significance of US power sector emissions 

WASHINGTON—Today, C2ES submitted comments on EPA’s proposed repeal of carbon pollution standards for the power sector, urging the agency against repeal and highlighting severe economic and public health risks associated with repeal. The comments challenge EPA’s disregard for decades of scientific research and analysis of both climate pollution’s impact and the social cost of these impacts on Americans.  

It also asserts that U.S. power sector emissions are in fact significant under the Clean Air Act and therefore require well-designed regulation, contrary to EPA’s justification of the proposed repeal.  

To speak with a C2ES expert about the comments, contact Tim Carroll at press@c2es.org. 

C2ES experts developed these comments with input from the private sector and additional external partners. In the comments, C2ES concludes that repealing standards would unlawfully evade a statutory mandate under the Clean Air Act, ignore judicial precedent set by the Supreme Court in Massachusetts v. EPA, and disregard its own scientific expertise and decades of research. This science and research, which the comments describe as unequivocal, demonstrates that rising climate pollution is leading to more frequent, intense and costly extreme weather events.  

The comments state, “last year there were 27 weather disasters in the United States with losses exceeding $1 billion each; the impact of these 17 severe storms, 5 tropical cyclones, 2 winter storms, 1 flood, 1 drought, and 1 wildfire were intensified by climate change. Keeping atmospheric greenhouse gas concentrations as low as possible will help to lessen future impacts and costs.” 

The comments go on to argue against EPA’s position that U.S. power sector emissions are not significant enough to be regulated under the Clean Air Act.  

In 2024, the U.S. power sector emitted 1,428 million metric tons of carbon dioxide, the second largest U.S. source by sector. This amount exceeds the combined economywide emissions of Germany, France, and the United Kingdom. 

“By EPA’s logic…if U.S. power sector emissions are not significant because they are 3 percent of the global total, then the same would be true of emissions from aviation, shipping, or aluminum, and many other sectors that account for comparable shares of emissions. Similarly, the entire emissions of Germany, France, the UK – indeed, every other country in the world save the four mentioned above – would be deemed insignificant. The absurd result would be to effectively conclude that virtually no sector or country is “significant” – and therefore to leave the entire problem unaddressed.” 

In addition to these assertions, C2ES included comments warning EPA of the risks to U.S. innovation and competitiveness in the global economy and to stability and certainty for investments in the power sector.  

“We respectfully encourage the Administration to establish balanced and suitable regulations that facilitate change, while also ensuring stability and fairness for industries that depend on consistent regulatory frameworks. We strongly recommend against the repeal of the (Carbon Pollution Standards).”
 

Read the full comments from C2ES here. 

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